The Resolution Pack
Firms must maintain a CASS Resolution pack to provide the necessary information to assist an insolvency practitioner in returning relevant client funds. This must include a master document detailing the contents of the pack as well as how to access all the other documentation and information.
Any systems needed by the insolvency practitioner, including those needed to provide the Resolution pack documentation, must be accessible after insolvency and arrangements must be in place to ensure this access.
Firms must be able to retrieve initial documentation immediately and full pack within 48 hours when required (under circumstances prescribed in CASS 10A.1.7R..)
The resolution pack is also intended to assist the FCA in their duties and, in the event of a firm’s resolution, assist the Bank of England or FSCS.
Living Documents
Resolution packs help ensure payments firms maintain, and can easily retrieve, information that would help achieve a timely return of relevant funds to consumers.
The FCA states that the most effective examples of resolution packs it has seen under CASS 10 tend to be ‘living documents’ which link directly to the latest versions of the relevant records. This approach may also reduce the effort involved in keeping a pack up to date.
Contents of the Pack
Next Steps
The changes will come into force on 7 May 2026. Before then, firms need to familiarise themselves with the new rules and guidance and establish systems and controls to meet the new requirements.
The full document can be found at https://www.fca.org.uk/publication/policy/ps25-12.pdf
We will also be posting additional information for firms, including further details on the Resolution Pack, Audits and Reconciliations as well as feedback from our consultants over the coming weeks.
How Neopay can help
At Neopay, we understand how crucial it is to be prepared for the unexpected, especially when it comes to the safeguarding of client funds. Our team can support you in designing and maintaining a compliant, well-structured Resolution Pack that meets the FCA’s expectations and can be accessed swiftly when needed. We help firms build ‘living documents’ that stay up to date with minimal effort, ensuring key systems and documentation are always accessible in the event of insolvency or regulatory intervention. From developing your master document to reviewing system access arrangements and preparing your team for retrieval obligations, Neopay provides the practical, tailored support you need to stay prepared and confident under pressure.
Contact our team to find out how we can support your business.
