New FRC Interim Guidance on Safeguarding Audits

The FRC has published Interim Guidance to support safeguarding audits in advance of the FCA's CASS 15 regime, effective 7 May 2026. The guidance applies during the transition period from 7 May 2026 until the final standard is issued in H1 2027.

What the Interim Guidance expects

The Interim Guidance establishes expectations in the following areas:

• A move to a CASS-style audit approach with a control-based focus.
• Increased focus on third-party and outsourcing arrangements, including Third Party Administrators.
• Robust assessment of IT-dependent safeguarding processes and controls (design, implementation, and operating effectiveness).
• Identification and documentation of safeguarding risks, mapped to mitigating controls.
• Safeguarding reporting in line with FCA SUP 3A Annex 1, with all breaches reported regardless of materiality.

How we are supporting firms

We are supporting firms throughout the transition period by providing practical assistance aligned to the FRC's Interim Guidance, including:

• CASS 15 gap assessments and readiness reviews.
• Safeguarding risk identification and control mapping.
• Assessment of the design of safeguarding controls, including IT controls.
• Review of third-party and outsourcing arrangements.

If you'd like to discuss your readiness for CASS 15 or the new safeguarding assurance regime, feel free to get in touch.