Revolut keeps your money in separate accounts at major banks or in regulator-approved low-risk investments, so it is kept apart from Revolut's own money and protected if Revolut becomes insolvent.
This analysis describes what Revolut's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The safeguarding mechanism is the primary consumer protection for Revolut account holders in lieu of FSCS coverage, and the choice of safeguarding counterparty banks and approved assets affects how quickly and completely funds could be recovered in an insolvency.
Your money is held in client accounts at large commercial or central banks or in low-risk regulator-approved assets, which means it is protected from Revolut's creditors in an insolvency; however, the specific banks or assets used are not disclosed in these terms, meaning you cannot independently assess the counterparty risk.
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"When we receive that payment or the money you add, we quickly either: place it into one of the dedicated client money bank accounts that we hold with large commercial or central banks (client money accounts keep your money separated from our own money, and the types of banks we can use are set by regulations); or invest it in low-risk assets that have been approved by our regulator, which are also kept in dedicated client accounts with financial institutions.— Excerpt from Revolut's Revolut Terms of Service
REGULATORY LANDSCAPE: This provision directly implements the safeguarding requirements of the Electronic Money Regulations 2011 (regulations 19-22) and the FCA's Approach Document for Payment Institutions and Electronic Money Institutions. The FCA is the enforcement authority. The 2024 FCA Policy Statement on safeguarding reform is directly relevant; the FCA has proposed moving from the current safeguarding regime to a more bank-like statutory trust framework, which may require future terms amendments. GOVERNANCE EXPOSURE: Medium. The current disclosure is consistent with EMR requirements, but the FCA's evolving safeguarding expectations, particularly around disclosure of specific safeguarding arrangements and asset quality, may require enhanced disclosures. The reference to 'low-risk assets that have been approved by our regulator' is appropriately qualified but does not specify asset classes, which may become a disclosure gap under updated FCA rules. JURISDICTION FLAGS: UK-specific under EMR 2011. EU/EEA equivalents exist under the Electronic Money Directive and PSD2. The identity of safeguarding counterparty banks is not disclosed in the terms, which may become a transparency issue if the FCA implements enhanced safeguarding disclosure requirements. CONTRACT AND VENDOR IMPLICATIONS: Institutional or corporate customers should note that safeguarding applies per account and that the absence of FSCS coverage means counterparty bank risk at Revolut's safeguarding banks is indirectly borne by customers. The terms do not specify a cap on safeguarding balances or a maximum concentration per safeguarding bank. COMPLIANCE CONSIDERATIONS: Monitor the FCA's safeguarding reform process for required changes to disclosure obligations and safeguarding mechanics. The adequacy of the current disclosure should be assessed against both current EMR requirements and anticipated new FCA rules. Internal records should confirm that safeguarding arrangements are reviewed and updated in line with FCA guidance.
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The safeguarding mechanism is the primary consumer protection for Revolut account holders in lieu of FSCS coverage, and the choice of safeguarding counterparty banks and approved assets affects how quickly and completely funds could be recovered in an insolvency.
Your money is held in client accounts at large commercial or central banks or in low-risk regulator-approved assets, which means it is protected from Revolut's creditors in an insolvency; however, the specific banks or assets used are not disclosed in these terms, meaning you cannot independently assess the counterparty risk.
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