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CASS Audit

CASS 5, 6 and 7 audits for FCA-regulated firms — client asset reports delivered to the FCA on time, by auditors regulated by both the ICAEW and the FRC.

If your firm holds client money or safeguards client assets, the FCA expects an annual CASS audit and a client assets report filed within four months of your period end. We plan around that deadline from day one, focus testing on the rules that actually apply to your permissions, and keep the process off your operations team's desk as far as possible.

Understanding CASS Audits

CASS audits are specialist regulatory audits required by the FCA for firms that hold client money or assets. They verify compliance with the FCA Client Assets Sourcebook rules designed to protect client assets and ensure proper segregation from firm assets. The CASS regime is one of the most stringent regulatory frameworks in UK financial services, and weaknesses carry significant regulatory consequences — which is why the quality and timeliness of your CASS audit matters.

Deadlines, Assurance Types and the Breaches Schedule

Under SUP 3.10 of the FCA Handbook, your auditor must deliver the client assets report to the FCA within four months of the end of the period it covers. Firms that hold client money or custody assets need a reasonable assurance report; firms claiming not to hold client money or assets (or not permitted to) need a limited assurance report confirming that position.

The report must identify every individual CASS rule breached during the period — or state explicitly that none were identified. We help you understand what will appear in the breaches schedule well before filing, so your management responses are considered rather than rushed.

CASS 5 Audits: Insurance Intermediary Client Money

CASS 5 applies to insurance intermediaries that hold client money, requiring strict segregation of client funds from the firm's own money. Our audit verifies compliance with the client money rules, covering segregation, client money calculations and reconciliations, statutory and non-statutory trust arrangements, approved banks, record-keeping and the internal controls that prevent misuse or misappropriation.

CASS 6 and CASS 7 Audits: Custody Assets and Client Money

CASS 6 applies to firms safeguarding custody assets and CASS 7 to investment firms holding client money. Our work covers internal and external client money reconciliations, the client money resource and requirement calculation, segregation and acknowledgement letters, custody record-keeping and asset reconciliations against custodian records, internal controls, and the CMAR and related regulatory reporting environment.

Reducing Your CASS Audit Workload

We reduce your workload through a dedicated audit portal that minimises audit emails and queries, remote working where possible to minimise office time while maintaining audit quality, extensive experience across accounting and ERP systems, and streamlined procedures focused on the areas of highest regulatory risk for your specific permissions profile.

Our CASS Audit Experience

Our audit team includes members who previously worked on audits for major international corporations including Apple, British Steel, Airbnb and Fujifilm. Our current audit portfolio includes 10 listed entities featuring brands such as Sharp Electronics, Linguaphone and Kuoni, and we are regulated by both the ICAEW and the FRC — the regulatory standing CASS work demands.

CASS Audit Process

Our structured process has six steps: 1) Planning and scoping — mapping your permissions, CASS classification and key risk areas; 2) Systems and controls review — evaluating CASS-related systems, processes and internal controls; 3) Testing and verification — detailed testing of reconciliations, segregation arrangements and record-keeping; 4) Compliance assessment — identifying deficiencies and improvement areas; 5) Reporting — preparing the client assets report for FCA submission, including any breaches schedule and management responses; 6) Follow-up — supporting remediation so next year's report is cleaner than this year's.

What You Get With Acumon

  • CASS 5, CASS 6 and CASS 7 audit coverage matched to your FCA permissions
  • Client assets report filed with the FCA within the four-month deadline
  • Reasonable and limited assurance engagements under SUP 3.10
  • Client money segregation, reconciliation and calculation testing
  • Custody asset reconciliations against custodian records
  • Breaches schedule managed early, with considered management responses
  • Dedicated audit portal minimising emails and queries
  • Remote-first fieldwork to reduce disruption to your operations team

Why Acumon for CASS Audit?

  • Regulated by both ICAEW and FRC
  • Audit team members previously worked on audits for Apple, British Steel, Airbnb and Fujifilm
  • Current audit portfolio includes 10 listed entities including Sharp Electronics, Linguaphone and Kuoni
  • Over 50% of the audit team come from top-4 and top-5 firms
  • Holds a PIE audit licence
  • Only £37k short of the top 100 in the Accountancy Age 50+50 list for 2024

Get a Fixed-Fee Quote

Tell us what you need and we'll come back within one business day with a clear scope and a fixed price — no hourly-rate surprises. Call 020 8567 3451 or use the form and we'll be in touch.

Common Questions

Frequently Asked Questions

What is a CASS audit and who needs one?
A CASS audit is an annual assurance engagement required by the FCA for firms subject to the Client Assets Sourcebook — typically investment firms holding client money (CASS 7), firms safeguarding custody assets (CASS 6) and insurance intermediaries holding client money (CASS 5). The auditor reports to the FCA on the firm's compliance with the CASS rules.
When must the CASS audit report be submitted to the FCA?
Under SUP 3.10, the client assets report must be delivered to the FCA within four months of the end of the period it covers. We build the audit timetable backwards from that deadline so filing is never a scramble.
What is the difference between a reasonable assurance and limited assurance CASS report?
Firms that hold client money or custody assets need a reasonable assurance report — a full opinion on compliance with the applicable CASS rules. Firms that do not hold (or are not permitted to hold) client money or assets need a limited assurance report confirming nothing came to the auditor's attention suggesting they held client assets during the period.
What happens if breaches are found during a CASS audit?
The client assets report must identify each individual rule breached, however minor, alongside management's responses. A breaches schedule does not automatically trigger enforcement — the FCA is primarily interested in how quickly issues were identified and remediated. We flag likely breaches early so you can remediate and respond before the report is filed.
Do insurance brokers need a CASS audit?
Insurance intermediaries that hold client money under CASS 5 generally need a client assets audit; firms operating solely under risk transfer agreements may not. The analysis depends on your terms of business and permissions — we can review your position and confirm what applies.
How can we prepare for our first CASS audit?
Have your CASS resolution pack, reconciliation records, acknowledgement letters and breach log ready, and make sure your CF10a/CASS oversight arrangements are documented. At planning we issue a clear request list through our portal and walk your team through exactly what evidence we need.
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