meta_id 3340989

On July 16, 2026, the Gibraltar Financial Services Commission (GFSC) published comprehensive guidance on safeguarding relevant funds for payment institutions and electronic money institutions operating under Gibraltar's regulatory framework. The guidance applies to institutions that safeguard funds in accordance with regulation 84 of the Payment Services Regulations and regulation 30 of the Electronic Money Regulations. It sets out the GFSC's expectations regarding safeguarding relevant funds, safeguarding resolution packs, audit requirements, and safeguarding returns. The guidance complements existing legislation and should be read in conjunction with the Payment Services Regulations and Electronic Money Regulations. Key areas covered include requirements for maintaining safeguarding resolution packs to assist insolvency practitioners in returning funds to clients; proper identification and allocation of relevant fund receipts; segregation methods for protecting funds through secure, liquid assets; and the insurance or guarantee method as an alternative protection mechanism. The guidance specifies that safeguarding institutions must establish policies and procedures for reconciliations, including internal and external safeguarding reconciliations performed at minimum on each reconciliation day. Institutions must maintain accurate records and accounts of all relevant funds held, including those not held in relevant funds bank accounts. For institutions required to safeguard more than £100,000 of relevant funds for at least 53 weeks, the guidance outlines audit requirements and the role of external auditors in monitoring compliance. Auditors must prepare safeguarding reports and communicate matters of material significance to the GFSC. The guidance also provides detailed requirements for safeguarding account acknowledgement letters, including specifications for account identification, signatures, and governing law provisions. Safeguarding institutions should review this guidance and ensure their systems and procedures align with the GFSC's expectations to maintain compliance with the relevant funds regime.