The questions this tool walks you through
Here is what the checker asks and why each step matters. Prefer to talk it through? Contact us and we will help directly.
Does the entity receive safeguarded funds from customers for payment execution or e-money issuance?
PSP regulations define safeguarded funds as amounts received from customers held for payment transactions or e-money issuance, excluding fees and commissions retained by the provider.
No safeguarded customer funds are received, so client-money recognition analysis is not required; account for amounts received under the guidance that governs their character (IFRS 9.3.1.1; IFRS 15 for fees).
Official guidance: IFRS issued standards
Are customer funds segregated from the entity's own operating cash in dedicated safeguarding accounts?
Segregation supports regulatory compliance but does not alone determine on-balance-sheet recognition; assess control and insolvency protection together.
Use the interactive tool above to see how this applies to your situation.
Official guidance: IFRS issued standards
Does the entity bear credit risk if the safeguarding bank defaults on the deposited balance?
When the PSP remains liable to customers for the par value of funds despite bank insolvency, the entity controls an economic resource and typically recognizes an asset and matching liability.
Use the interactive tool above to see how this applies to your situation.
Official guidance: IFRS issued standards
Can the entity invest safeguarded funds and retain investment returns under contract or regulation?
Decision-making power over investment returns is an indicator the entity is principal rather than agent and supports on-balance-sheet recognition of controlled economic benefits.
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Official guidance: IFRS issued standards
Does a legal opinion confirm funds are bankruptcy-remote from the entity under applicable insolvency law?
Without legal isolation, consultation memos typically conclude on-balance-sheet recognition when the PSP controls access and bears customer credit exposure on bank default.
Bankruptcy-remote trust or nominee funds the entity cannot use for its own benefit are not the entity's asset; do not recognize the cash and disclose material custodial activity instead (IAS 32.11; IFRS 9.3.1.1).
Official guidance: IFRS issued standards
Does the entity have a present contractual obligation to return or transfer an equivalent amount to clients?
The liability may be owed to wallet holders even when settlement occurs through merchants, banks, or payment networks on demand.
Recognize the controlled cash without a client-money liability only if no contractual obligation to any counterparty meets the IAS 32.11 financial liability definition.
Official guidance: IFRS issued standards
Should the recognized asset and liability be presented gross on the statement of financial position?
Consultation conclusions typically require gross presentation of safeguarded cash and customer payables unless IAS 32 offset criteria are both satisfied.
Use the interactive tool above to see how this applies to your situation.
Official guidance: IFRS issued standards
Is there a legally enforceable right to set off the recognized cash asset and client liability?
Offsetting requires both a current legally enforceable right and an intention to settle net or simultaneously in the normal course and in default.
Without a currently enforceable right of set-off the IAS 32.42(a) criterion fails; present the recognized asset and liability gross.
Official guidance: IFRS issued standards
Does the entity intend to settle the asset and liability net or simultaneously in the normal course and in default?
Operational settlement mechanics must eliminate or make insignificant credit and liquidity exposure for net presentation.
Both IAS 32.42 criteria appear satisfied; net presentation may be appropriate if the set-off right survives the normal course, default, insolvency, and bankruptcy (IAS 32.AG38B). The settlement-intention criterion in IAS 32.42(b) is not met, so present the recognized asset and liability gross.
Official guidance: IFRS issued standards