It has always been clear that the market would not all move at one single pace. Some currency clearing and settlement banks would follow Market Infrastructure’s ISO 20022 adoption, while other institutions would be guided by cash bank and counterparty readiness.
However, what is a common denominator is that the adoption of enhanced data is from November 2023 and not before. This avoids complexity in data handling through payment chains – a position that has been endorsed by Market Infrastructures, SWIFT and cash banks alike.
Market Data from SWIFT shows us that 25% of institutions are testing ISO 20022 messages. This percentage will increase before March, but we can be confident that a sizable proportion of institutions will go into the Co-existence period being ready to receive ISO 20022 as mandated, but still sending and receiving MT. The strategy being to move to ISO 20022 later next year when strategic road-maps are less busy.
In line with our earlier advise to clients, it is critical that you engage with your correspondents and cash banks to understand their adoption of ISO 20022.
The following information is guidance aligned to key influencers:
‘Not being ready will mean a break in the continuity of your business operations, with payment instructions coming from your correspondents that cannot be processed.’
– SWIFT Quote, LinkedIn, Aug 22.
SWIFT messaging is clear. Technical readiness for March. Start sending and receiving ISO 20022 when you can. Avoid enhanced data until November 2023.
For direct participants, migration timelines are known, and, in most cases, this is a hard cut-over. For indirect participants and those offering accounts in impacted currencies, you are likely to need to send and receive in ISO 20022 from the time that the market infrastructure moves to ISO 20022.
Cash management banks
Guidance is coming out from banks on their preferred adoption timelines. Whilst most are ready to support ISO 20222 from March, there is some advice against using ISO 20022 until November 2023. It is critical that you speak to your bank to understand and clarify fully their individual position.
Managing your project
Our recommendation is to use ISO 20022 as soon as you can so you can close out your market facing migration. Additionally, to manage any translation requirements internally. Most importantly, please do not wait until you get a deadline from your correspondents.
Initial projects continue to complete in the lead up to the March deadline. However, plan your strategy for the remainder of the year now. Be reassured that many institutions are not going to be ‘Native’ in March and so you still have time to boost your competitive advantage.
There will be increasing requirements for ISO 20022 and enhanced data in 2023 and beyond.
Bottomline are running a series of webinars in early January 2023 to investigate these areas in more detail.
Stay close to your cash management banks and correspondents to understand their position and any planned change to their adoption strategy.
“Not being ready will mean a break in the continuity of your business operations, with payment instructions coming from your correspondents that cannot be processed.”
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