Payments Safeguarding & Conduct Register (PSCR)
An RMCA programme
PS-05
Safeguarding, FSCS, Insolvency and Return-of-Funds Notice
- Version
- Version 1.0
- Effective
- 26 August 2026
- Last updated
- 26 August 2026
Direct answer: Safeguarding is not deposit protection. A payment or e-money balance is not automatically an FSCS-protected bank deposit, and safeguarding does not guarantee full or immediate return if a firm fails.
01
Five essential distinctions
02
Safeguarding is not deposit protection
Payment and e-money firms may be required to safeguard relevant customer funds under applicable rules. Safeguarding is intended to separate or protect funds through specified arrangements. It is not the same as a bank deposit guarantee and does not by itself promise full or immediate recovery.
The applicable position depends on the exact entity, regulated activity, customer category, jurisdiction, contract, payment flow and period.
03
FSCS and eligibility
Money held with an electronic-money institution or payment institution is not protected in the same way as an eligible deposit held directly with a UK-authorised bank. FSCS may apply to a separate underlying bank failure or another eligible claim only according to its rules.
Users must not assume that a payment or e-money balance is an FSCS-protected deposit or that failure of an underlying bank automatically creates a direct customer claim.
04
Firm failure, insolvency and administration
If a payment or e-money firm fails, administrators or other office-holders may identify safeguarded funds, verify claims, deduct lawful costs and distribute available funds under the applicable regime. Delays, shortfalls, record issues, disputes and intermediary failures may affect returns.
Segregation or another safeguarding method is not a promise of full, immediate or cost-free return.
05
Exact legal entity and service
A brand may use several legal entities, agents, distributors, processors or banks. The customer contract, service, country and payment flow determine the legal position. One entity's licence or safeguarding does not cover another entity merely because they share a brand.
This general notice makes no assertion about any named firm's safeguarding and creates no institution-specific assurance.
06
Practical checks
- Identify the exact legal entity and official category.
- Check the relevant authority, permission, activity and service.
- Read the customer terms and safeguarding disclosure.
- Understand whether funds are received, held, passed through or exchanged.
- Check complaint, insolvency and return-of-funds routes.
- Treat claims such as “fully protected” or “insured” with caution unless scope and evidence are clear.
07
No assurance by PSCR
PSCR organises educational information and, in future functions, may organise scoped evidence and dates. It does not hold customer funds, operate a compensation scheme, audit a firm, guarantee a provider or substitute for the provider, safeguarding bank, auditor, administrator, regulator, FSCS, court or adviser.
08
Urgent issues and time limits
Suspected fraud, an unauthorised payment, insolvency or inability to access funds may require prompt contact with the provider, bank, card issuer, regulator, administrator, police or professional adviser. A PSCR page does not stop a limitation, complaint or procedural time limit.
09
No advice
This notice is general educational information, not legal, financial, accounting, audit, insolvency or other professional advice. Users remain responsible for obtaining advice suited to their facts, jurisdiction, product, customer category and legal obligations.
