Kirk Rice Blog

CASS 15 impacts: 5 ways payment firms are reviewing accounting operationsWritten on May 14, 2026 by Jonathan Swarbrick

Key Points

• April 2026 changes linked to FCA safeguarding expectations under CASS 15 are prompting many payment firms and e-money institutions to review their finance operations, reporting processes and internal controls.
• As payment firms grow, higher transaction volumes across multiple providers, currencies and settlement cycles can make manual reconciliations increasingly difficult and resource intensive, particularly when new CASS 15 pressures are layered onto existing processes.
• Finance systems and processes that worked during earlier growth stages may become less effective as businesses scale, particularly where reporting and operational data are fragmented across multiple platforms.
• Delays in management reporting can reduce visibility over cash flow, forecasting, operational performance and short-term financial risks at a time when governance expectations are increasing.
• Outsourced finance and fractional FD support may help payment firms improve reporting processes, strengthen operational finance controls and support long-term scalability.

Recent CASS 15 safeguarding changes have increased focus on how payment firms and e-money institutions protect customer funds, maintain operational controls and manage financial reporting processes as they scale.

These changes are prompting many of these businesses to review their finance operations, reporting processes and internal controls.

Kirk Rice does not provide regulatory or legal advice on FCA safeguarding requirements. However, we’re increasingly seeing growing payment and fintech businesses reassess their finance functions, systems and reporting processes.

For many firms, the challenge is not simply regulatory compliance. It is whether existing finance infrastructure can continue to support a business that is scaling quickly, handling increasing transaction volumes and operating across multiple systems and payment flows.

Below are five operational finance challenges that I believe many payment firms could now be facing.

1. Manual reconciliations are becoming increasingly difficult to manage

As payment firms grow, reconciliation processes often become significantly more complex.

Many businesses operate across:

• Multiple payment providers
• Banking platforms
• Currencies
• Settlement cycles
• Disconnected finance systems

Over time, finance teams can find themselves relying heavily on:

• Spreadsheet-based reconciliations
• Manual data extraction
• Duplicate data entry
• Time-consuming investigation of discrepancies

As transaction volumes increase, these processes can place growing pressure on internal finance teams and make month-end processes increasingly resource intensive. Especially when new CASS 15 pressures are layered onto them.

Outsourced finance support can help businesses review reconciliation workflows, identify process bottlenecks and implement more scalable finance processes as operational complexity increases.

2. Reporting processes are struggling to keep pace with growth

Fast-growing businesses need timely and reliable financial information to make confident commercial decisions.

However, when finance teams are heavily focused on operational processing and manual controls, management reporting can begin to lag behind the pace of the business.

This can make it more difficult for leadership teams to maintain visibility over:

• Cash flow
• Operational performance
• Forecasting
• Resource planning
• Short-term financial risks

In many cases, improving finance processes and reporting frameworks can help businesses create clearer financial visibility and support faster decision-making.

Fractional FD support may also help businesses strengthen reporting oversight without the immediate need for a full-time senior finance hire.

3. Growing operational complexity is placing pressure on finance teams

Growth businesses often operate with lean finance teams managing a wide range of responsibilities simultaneously.

In some firms, existing teams are balancing:

• Day-to-day finance operations
• Reconciliations
• Reporting
• Compliance administration
• Forecasting
• Wider operational support

Over time, capacity constraints can begin to affect both efficiency and reporting quality.

Rather than immediately expanding permanent headcount, some businesses choose to supplement their internal teams with outsourced finance support, providing additional operational capacity and specialist expertise during periods of growth or change.

4. Businesses are seeking stronger financial oversight without a full-time FD hire

Not every growing business is ready to recruit a full-time finance director.

However, many firms still reach a stage where they would benefit from more senior financial oversight, particularly when:

• Finance processes need improving
• Reporting frameworks require strengthening
• Systems are becoming more complex
• Finance teams need additional strategic direction

Fractional FD and outsourced finance leadership can help businesses improve operational finance controls, strengthen reporting processes and support long-term scalability without the commitment of a permanent senior hire.

5. When to consider external finance support

External finance support may be worth considering if:

• Reconciliation processes are becoming increasingly manual
• Reporting delays are affecting commercial decision-making
• Finance systems are struggling to keep pace with growth
• Internal finance teams are operating at capacity
• Additional financial oversight is needed during a period of operational change

Alongside legal and regulatory advisers, many payment firms are now reviewing whether their finance operations, systems and reporting processes can support increased safeguarding expectations and continued business growth.

Get in touch

If recent safeguarding changes have highlighted pressure points within your finance operations, reporting processes or internal controls, Kirk Rice’s outsourced finance and fractional FD teams can help.

Our team can review existing processes and support the development of a more scalable finance function. Get in touch via email info@kirkrice.co.uk

Please note: This article is correct as at the publication date. The answers are given for general guidance only and specific advice should be taken before acting on any of the suggestions made. The information is based on current tax legislation which may change in future. Information is based on our current understanding of taxation legislation and regulations. Any levels and bases of relief from taxation are subject to change. The Financial Conduct Authority does not regulate tax planning.