SUP15 Explained: Notifying the FCA When Safeguarded Funds Are Invested
Industry Insights | 29th December, 2025
SUP15 notifications are often required before issues are fully understood.
Waiting for certainty can increase regulatory risk.
Why SUP15 Matters In Practise
SUP15 (Notifications to the FCA) is one of the most frequently misunderstood, and often overlooked, parts of the regulatory framework for Electronic Money Institutions (EMIs) and Payment Institutions (PIs).
While safeguarding and treasury operations tend to receive significant attention, the obligation to notify the FCA when material events occur is just as critical. Many firms only discover issues with SUP15 during audits, regulatory reviews, or supervisory engagement.
This article explains what SUP15 is, when it is triggered, and how it commonly applies to safeguarding and treasury activities.
What Is SUP15?
SUP15 is part of the FCA Handbook and sets out the circumstances in which regulated firms must notify the FCA of certain events, changes, or issues.
In simple terms, SUP15 requires firms to notify the regulator promptly and transparently when something happens that could be relevant to the FCA’s supervisory objectives.
These notifications are not optional, and they are not limited to serious failures. In many cases, early notification is expected even where an issue is still being assessed internally.
Where Firms Commonly Get Caught Out
In the context of safeguarding and treasury, SUP15 is often triggered by:
- Errors or delays in safeguarding reconciliations
- Shortfalls or discrepancies in safeguarded funds
- Issues with safeguarding accounts or custodians
- Operational failures affecting the segregation or protection of client funds
- Changes to safeguarding structures or methodologies
- Treasury events that may impact liquidity, access to funds, or risk profile
A common misconception is that notification is only required once a breach is confirmed. In practice, the FCA often expects firms to notify when a material issue is identified, even if root-cause analysis is ongoing.
Treasury Activity and SUP15 Considerations
As firms explore more sophisticated treasury arrangements - including the use of qualifying Government Money Market Funds (MMFs), custodians, or multi-currency structures - SUP15 considerations become increasingly relevant.
Examples of treasury-related events that may require notification include:
- Material changes to how safeguarded funds are held or invested
- Issues affecting liquidity or timely access to safeguarded funds
- Errors in treasury execution that could impact safeguarding outcomes
- Any event that could reasonably be considered relevant to the FCA’s assessment of risk
Importantly, even permitted and compliant treasury activity can still give rise to SUP15 notifications if something goes wrong operationally.
Timing: “Immediately” Means Promptly, Not Eventually
SUP15 notifications are generally expected to be made without undue delay.
Waiting for perfect information, full internal reports, or external advice before notifying can itself be viewed negatively. In many cases, firms submit an initial notification followed by further updates as more information becomes available.
Early, transparent communication is almost always preferable to late, complete disclosure.
Governance and Internal Sign-Off
SUP15 notifications should always be treated as a formal governance matter.
In practice, this means:
- Clear internal escalation procedures
- Involvement of compliance, risk, and senior management
- Appropriate documentation of decisions and rationale
- Internal review and approval before submission
Responsibility for SUP15 notifications always remains with the regulated firm. Even where third parties are involved in safeguarding or treasury operations, the obligation to notify the regulator cannot be outsourced.
How EMI Treasury Fits In
EMI Treasury supports firms by helping them design robust, well-documented safeguarding and treasury frameworks that reduce operational risk and support regulatory expectations.
This includes:
- Treasury structures aligned with safeguarding requirements
- Documentation that supports audit and supervisory review
- Operational processes designed to minimise errors and uncertainty
- Support in preparing information that may be required for regulatory engagement
- Drafting notifications and suggesting timelines
In practice, many firms treat the first-time investment of safeguarded funds as a SUP15 notifiable event, enabling early supervisory engagement with the FCA before implementation.
EMI Treasury can assist compliance teams with the initial notification and any follow-up queries, while responsibility for compliance remains with the regulated firm.
Final Thoughts
SUP15 is not just a compliance technicality - it is a core part of how the FCA expects firms to operate transparently and responsibly.
For EMIs and PIs running safeguarding and treasury operations, understanding when SUP15 applies, and having clear internal processes to respond, is essential to maintaining regulatory confidence.
Well-designed treasury structures reduce risk, but good governance and timely communication are what ultimately protect firms when issues arise.
This article is provided for informational purposes only and does not constitute legal, regulatory, or investment advice. EMIs and PIs should seek independent professional advice before implementing safeguarding changes.
