Some banks and FIs will miss the November 22, 2025, compliance deadline for the ISO 20022 cutover. Being unprepared for this landmark day in cross-border payments, cash reporting, and financial messaging isn’t good, but a little hustle can go a long way now.

Here’s what it all means, why it’s important, and some things to do now.

It’s possible that some financial institutions (FIs) haven’t prioritized this change because it’s not well understood by all. The transition is more than a technological upgrade; it’s a fundamental shift in cross-border payments. This messaging means a new world of efficiency and security.

However, the window for last-minute fixes is rapidly closing.

The industry’s years-long coexistence of old and new message types is ending, and the Swift CBPR+ program ushers in a redefined future where both inbound and outbound payment flows for cross-border payments must be supported in the MX format.

It’s a global directive affecting all Swift-connected FIs with a registered BIC and while most banks sending cross-border payments have made noteworthy progress, others are scrambling. Their urgency is now palpable.

The November deadline is not just another box to tick. It’s ushering in a new era of clarity in cross-border payments, and those who aren’t ready for it face operational disruptions, regulatory scrutiny, and potentially even reputational damage.

For those behind the eight ball on the ISO 20022 implementation, Tara Little, Portfolio Strategy Director - Financial Messaging Bottomline, advises acting now, and with purpose: “There are translation services offered through Swift, and through payment technology companies like Bottomline, that can help translate financial messages from the existing MT structure to the new MX structure,” she says.

But Little adds that it’s long past time to get this done. Any FIs still playing catch-up need to understand what the November deadline means for them, and for their clients.

 

Consequences and Remedies

Before moving on to what is or isn’t possible for FIs unprepared for the November deadline, let’s consider the consequences.

The most pressing concern is the impact on customers: delays in payment processing, operational disruptions, and the outright rejection of non-compliant messages.

Payments that fail to meet new messaging standards are sure to fail more often, resulting in bottlenecks that could have far-reaching effects on operations. While Swift has indicated that a translation service will be available, it comes at a premium, and is intended only for minimal exceptions, not as a substitute for full compliance.

Moreover, this service does not cover all message types, and some are being retired entirely. The regulatory landscape adds another layer of complexity.

Emergency mitigation strategies, such as engaging third-party processing solutions or enhanced correspondent banking arrangements offer a lifeline, but it’s important to acknowledge that these are stopgap measures.

“Customer impact is always foremost in my mind,” Little said. “Missing the deadline means delays in payment processing and operations, and ultimately rejection of non-compliant messages. Payments simply will not get out the door.”

The reality is stark: non-compliance will not only disrupt payment flows but could also expose institutions to financial penalties and reputational damage. As Little said, “It’s late in the process for remedies.” For those finding themselves scrambling, she added that emergency mitigation services – third-party processing solutions such as Bottomline – and enhanced correspondent banking arrangements are excellent resources now.

 

The Risks of Relying on Correspondent Banking

After mentioning “enhanced correspondent banking arrangements” as a resource for those arriving late to the ISO 20022 party, Little added a caveat: “A common misconception during the coexistence period has been the belief that correspondent banks would shoulder the burden of compliance, acting as translators for institutions not yet ready for the new standard,” she said.

This assumption is no longer valid with outgoing payments now in scope.

Under the forthcoming Swift rules, every Swift BIC member (banks and FIs) must be compliant by the November deadline, regardless of correspondent relationships. Previously, FIs could depend on their correspondents for inbound payments, but with outbound transactions now in scope, the responsibility for compliance rests squarely with the originating bank.

This change exposes a significant risk for those who have not fully internalized the requirements of ISO 20022. “During coexistence, some institutions may have been lured into the false sense of security,” Little says, “thinking their correspondent bank would take care of the burden as a translator.” This is not the case. While many institutions have put in place temporary mapping services to transform messages, they must now ensure their own systems are up to the task.

 

Why ISO 20022 Matters: Unlocking Strategic Value

While the immediate focus is on meeting the compliance deadline, forward-thinking FIs recognize that ISO 20022 offers opportunities beyond mere compliance.

The MX standard’s data-rich format, offering up to ten times the data capacity of legacy MT messages, enables banks to enhance their internal processes, improve customer experiences, and even develop new revenue streams.

Little stressed that the benefits are substantial: improved straight-through processing, greater automation, reduced manual intervention, and enhanced reconciliation for corporate clients. She noted that using temporary workarounds is critical for many customers to be compliant in time, but that it means “…you’re really missing the strategic value that ISO 20022 offers.”

What is that strategic value? Enhanced data flows that support better liquidity management, real-time cash forecasting, and advanced analytics, all of which contribute to operational efficiency and customer satisfaction.

There is even the potential for banks to monetize these improvements by offering premium services to corporate clients, turning compliance into a competitive advantage.

As the deadline nears, Little said, “Those who look beyond the minimum requirements will be best positioned to thrive in the new era of payments, and to realize the value that’s being added with this initiative.”

 

ISO 20022 Last Minute Checklist for FIs

Emergency Mitigation:

  • Engage Swift: Explore translation services for short-term message conversion.
  • Engage Third-Party Solutions: PSPs like Bottomline can help bridge the gap.
  • Review Correspondent Banking Arrangements: Only as a last resort, and only if your partners are fully compliant and willing to support you temporarily.
  • Prioritize Critical Payment Flows: Focus resources on the most business-critical payment types to minimize disruption.

Communicate Proactively:

  • Inform Customers: If possible, be transparent about potential delays or issues.
  • Engage Regulators: Share your remediation plan to demonstrate good faith and reduce the risk of penalties.

Accelerate Your Compliance Program:

  • Reallocate Internal Resources: Bring in external consultants, fast-track testing and increase internal focus.
  • Leverage Industry Support: Tap into vendor forums and industry networks for best practices and troubleshooting.