Are you a Payment or E-Money Institution (EMI) struggling to recruit CASS 15 compliance professionals? You are not alone in this dilemma. This struggle is spreading across the industry, especially with the rumoured publication of cass 15 rules at the end of August and May 2026 (9-month) implementation deadline for interim state rules; it is only going to get more competitive.
It’s a combination of regulatory demands, limited talent and shifting work expectations. As a result, it is creating a high-pressure environment filled with the stress of staying compliant and competitive.
This article explores why these CASS 15 recruitment challenges are escalating. Also, you will learn what’s driving the CASS 15 talent shortage and how your business can take steps to keep up.
*** You can also read our CASS 15 Recruitment Guide to help you: What Is CASS 15? A Recruiter’s Guide – Payments/E-Money Firms ***
The Regulatory Bar Is Getting Higher
The Financial Conduct Authority (FCA) has made it very clear that firms must take safeguarding very seriously. The FCA introduced CASS 15 to help guide Payment and EMIs in protecting client funds.
As regulatory pressure continues to grow, CASS 15 recruitment is a strategic priority for businesses, particularly in the payment and EMI sectors.
Firms could use this situation as a commercial and competitive opportunity by evaluating the effectiveness and efficiency of their data, product offerings and client relationships.
An example of this is examining how automation can add value while meeting the new CASS requirements.
Regulatory Expectations for CASS 15
As a business, you must have clear and documented policies for the following areas:
- Organisational Arrangements
- Books and Records
- Governance and Oversight
- Reporting
- Training
The size and complexity of these implementations are huge. Hiring the right people with the right CASS experience is no longer optional. It is a business-critical decision. Firms that do not have the right talent for CASS 15 will face issues such as:
- Increased regulatory risk
- Operational disruption
- Serious reputational damage
The CASS 15 Talent Shortage Is Real (and Growing)
A CASS 15 talent shortage is one of the most pressing issues facing compliance teams. The demand for safeguarding knowledge is increasing daily, and the supply of experienced professionals is shrinking.
This mismatch is creating a highly competitive market that is becoming increasingly difficult to recruit in. Few professionals have the real practical expertise of CASS 15. Some of the key areas are:
- Books and Records
- CASS Monitoring and Reporting
- CASS Audit
- Stakeholder engagement
Also, people with general compliance experience often struggle with CASS 15 roles. Because the specificity and technical nature of CASS 15 is so complex, CASS experience is essential.
This CASS 15 talent shortage is across the board, for example:
- Consultancies are deploying CASS consultants to clients at record rates
- FinTechs and scale-ups are aggressively competing for specialists
- Large firms are expanding compliance functions and absorbing senior talent
All these issues are creating a growing list of CASS recruitment challenges. If you want to have a quick look at our existing roles or need help, you can find CASS 15 talent here.
The Talent War in CASS Recruitment
CASS recruitment challenges are creating intense competition between firms. This constant war is not only about offering the best salary; it’s also about providing the best overall employee value proposition.
Moving through processes quickly, offering flexibility, and aligning with candidate expectations are essential. For example, in the market, timing is everything. We have seen companies lose ideal hires because their process took too long.
Candidates are looking for:
- Clear progression opportunities
- Flexible working options, such as hybrid or remote
- Trust in leadership and purpose-driven environments with genuine buy in for CASS implementation
The new reality is that a generous salary may not be enough to secure a candidate who has multiple job offers. CASS 15 recruitment is now a front-line business strategy, not a back-office task.
The Return of a Candidate-Driven Market?
At the same time, offering other attractive incentives apart from a higher salary may work, but a high salary could be a deciding factor. In the past, paying more has always helped businesses secure the best talent.
As an example, cast your mind back to the PS14/9 changes and when the Financial Reporting Council (FRC) assurance standard was introduced. At that time, rates increased, and it became a candidate-driven market where job seekers had real power and were far more selective and demanding.
The Rise of the CASS Contractor
There is a shift to hybrid work creating opportunities and challenges within safeguarding recruitment. Businesses with hybrid models can expand their talent pool and attract new candidates.
But, managing remote compliance professionals can become quite complex for businesses. Think of reconciliations, oversight, and stakeholder meetings, and you can see the impact they can have on a business.
This current situation has increased the demand for CASS contractors. These contractors are an ideal solution as they can step in for short-term contracts and deliver results.
CASS Contractors – A Smart, Cost-Effective Option
With the growing need for CASS 15 professionals, bringing back independent CASS contractors can be a smart, cost-effective solution.
For smaller investment firms and pension providers, such as EMIs and PSPs, the cost of hiring a large consulting firm is very high. Additionally, their compliance burdens are increasing, particularly in areas such as fraud, financial crime, and new payment regulations.
Hiring an independent CASS contractor can provide smaller firms with the help they need without the high price tag. It can be a crucial and affordable way for these companies to stay compliant and manage risk.
Interim vs Permanent: A Strategic Balancing Act
We are now also seeing innovative firms use a blended model. For example, they are stabilising safeguarding teams with permanent hires. Additionally, they are utilising CASS contractors for the initial CASS readiness assessments, implementation projects, and audits. It’s also a valuable opportunity for firms to assess their resource capability across the three lines of defence and identify any urgent gaps that could impact compliance.
This dual approach to recruitment offers firms several significant advantages. The companies:
- Gain flexibility
- Boost their resilience
- Can support consistent governance.
This balance also works well for businesses that are undergoing changes or expansions to their operations.
Why Payments and EMI Firms Must Have CASS 15 Professionals
So why is it so critical that you have specialised CASS 15 professionals in your business? As a Payment or EMI firm, it is clear that you are in one of the most vulnerable industries out there.
CASS 15 was made specifically with you in mind, and safeguarding client money is a non-negotiable regulatory requirement. If you fail to resolve your CASS 15 recruitment challenges, it could affect you in many ways.
Here are some examples:
- Stressful and costly audits
- Regulatory supervision or enforcement action
- Long-term reputational damage
As you can see, a CASS 15 talent shortage isn’t only a hiring issue; it is also a risk management issue.
How Kohort Helps You Win the Cass Recruitment Battle
It may seem provocative to say that a battle is going on. The reality, though, is that there is such a high demand and so little choice. A recruitment battle is underway in the industry to secure the best talent.
Kohort Recruitment is a proactive recruitment partner, and we understand this specialist niche market. We have candidates ready to go, large and fully qualified networks and industry knowledge. In this article, we explain in more detail why specialised recruiters, like ourselves, can secure top CASS talent.
Unique Challenges of CASS 15 Recruitment
At Kohort Recruitment, we understand the unique challenges of CASS 15 recruitment. Over the years, we’ve built a recruitment model to help you stay ahead. We work with a network of pre-qualified professionals that have expertise in:
- CASS frameworks and governance structures
- CASS reconciliations and reporting
- CASS resolution packs
- Safeguarding implementation
- Stakeholder engagement and compliance strategy
Whether you need a CASS contractor or a long-term hire to build your internal capability, we have it covered. We like people to think of us as partners, not recruiters, in your compliance journey.
Next Steps for CASS 15 Recruitment
In 2025, CASS 15 recruitment is now more challenging than ever. The CASS 15 talent shortage is real. This shortage is affecting everything from compliance performance to audit readiness.
There is a triple threat in the compliance world, with an increase in regulatory pressure, competition, and evolving workplace demands. Your firm must take action to protect its internal compliance functions.
Are you ready to start solving your CASS 15 recruitment challenges? Whatever role you must fill for CASS 15, the right talent can’t wait. Kohort Recruitment offers expert, strategic support in the complex recruitment world of CASS15.
Book a Free CASS recruitment consultation with us by filling in our easy contact form. We’re ready to help you secure the right CASS talent for your business.
Sources:
- What is CASS 15? A Recruiter’s Guide for Payments and E-Money Firms – Kohort Recruitment
- 7 Reasons Why Specialised Recruiters Secure Top CASS Talent – Kohort Recruitment