Can you fund an
orderly wind-down?
An orderly wind-down is now a supervisor expectation, not a courtesy — MiCA Article 47 for CASPs, the FCA's Wind-Down Planning Guide and FG20/1 for payments firms. Model the runway your liquid resources buy against monthly burn and the indicative wind-down cost, and see whether you are funded or short. Safeguarded client balances are ring-fenced and never count toward it. Directional bands only.
● E-money redemption and safeguarding reconciliation extend the run-off period and the cost band.
The cost run-rate during run-off — staff tail, premises, suppliers, supervision. Drives the runway.
Own-funds the firm can actually deploy to fund the wind-down. This is NOT client money.
Ring-fenced. Returned to clients in full — never counted toward liquid resources or runway.
Dataset version 2026-06-02. No data is sent or stored. Computation runs locally. Bands are indicative, not a quote.
Liquid resources (€2,000,000) divided by monthly burn (€350,000). Shown as a band with a one-month stressed low.
E-money redemption and safeguarding reconciliation extend the run-off period and the cost band.
Own-funds the firm can deploy to fund the wind-down. Excludes safeguarded client balances entirely.
Liquid resources exceed the upper indicative wind-down cost, with runway covering the resolution window.
Funded — liquid resources cover the indicative wind-down
- Safeguarded / ring-fenced client balances (€20,000,000) are NOT available to fund the wind-down. They are client money, held under EMD2 Article 7 safeguarding obligations, and must be returned to clients in full. They are never counted toward liquid resources in this model — and counting them is the single most serious and most common wind-down modelling error.
- Runway is months, not certainty. The orderly wind-down has to be executed across a resolution window (roughly 4 months of burn at the upper cost band) — liquid resources must cover both the cost and the time to run it off, not just the headline number.
- Wind-down cost is dominated by people and client-asset return, not technology. The resolution staff tail, safeguarding reconciliation, and (for custody) client-asset return mechanics are the cost drivers — model them against your own run-off plan.
- Use this alongside the Capital Floor Calculator: the wind-down reserve sits on top of the regulatory own-funds floor, not inside it. A firm at its capital floor is not, by that fact, funded for an orderly exit.
For orientation only — not financial, legal, regulatory, or investment advice. Outputs are directional and based on generalised inputs. Decisions should be taken only after consultation with a qualified adviser on your specific facts — book the full assessment before acting on anything you read here.
Numbers shown exclude finconduit fees and any third-party costs (legal, audit, regulator-mandated experts, banking-relationship fees, document-translation, ongoing supervisory levies, or local agent / service-provider charges). Real-world authorisation budgets typically exceed the headline regulator-side numbers by a meaningful multiple.