ISO 20022: The Final Chapter Begins

While many banks and payment providers have made great steps toward compliance, there’s still a significant gap between regulatory readiness and strategic enablement. Many financial institutions have focused on ticking the compliance box, racing to meet deadlines and implement translation layers, but true value lies beyond simple adoption. November 2025 is not just about ticking a box — it’s about unlocking new value from structured, rich data that can transform payments, compliance and customer experience.

A quick look back

The shift toward ISO 20022 in Europe began in earnest with the completed migration of TARGET2 and EBA Clearing in March 2023. In international context other important markets and their systems did the loop already before Europe or followed in 2023. A big milestone was the start of the Cross-border payments and reporting plus (CBPR+) program in March 2023 by SWIFT. This initial release brought 15 usage guidelines covering key message types — payment initiation (pain), clearing and settlement (pacs), and cash management (camt) — all made available through SWIFT’s MyStandards platform. Interoperability was supported by features like in-flow translation and the Transaction Manager, enabling financial institutions to exchange ISO messages even if their counterparties hadn’t fully migrated.

Momentum continued throughout 2023 with the addition of new message types and increased Transaction Manager traffic. By November, further use cases were introduced — including cheques, direct debits, and margin collections — alongside guidance from the Payments Market Practice Group (PMPG) and CBPR+ working group to encourage use of ISO’s rich data fields. The focus shifted towards maintaining full transaction data and enforcing integrity across the payment lifecycle.

In 2024, attention turned to exceptions and investigations, with new usage guidelines covering notifications and charge requests — all signaling a deeper integration of structured payments into the global system.

Where we are today

As of May 2025, most institutions are technically compliant — SWIFT is currently reporting an average of over 1.6 million daily payment instructions exchanged in ISO 20022 format — but that doesn’t mean they’re ready. Many market participants are still relying on message translation rather than native ISO 20022 processing. Structured data is often flattened or shortened, and operational models have yet to evolve in line with the richer information now available. True interoperability remains a work in progress, and many banks are only just beginning to assess the broader impacts on their infrastructure, workflows, and customer propositions.

November 2025 & beyond: What’s changing?

The upcoming milestone marks a major shift: key MT messages — including MT103 and MT202 among others — will be retired, making ISO 20022 mandatory for all payment instruction messages. Nevertheless, SWIFT will leave the door slightly ajar until November 2026, when they introduce additional technical validations on messages and charges for all institutions that still send payment instructions in the MT format. Institutions should do their best to avoid using this fallback scenario. Alongside this transition, address formats are also being standardized to improve data quality and interoperability. One of the most important updates is the introduction of the hybrid (or semi-structured) address format.

Curious how the different address types compare — and what the hybrid format really means?

Check out the info box below for a quick overview.

ISO 20022 isn’t just about updating payment instructions — it also impacts a range of related processes and message types. To support a smooth transition, these changes are being rolled out in phases. The timeline below outlines the key milestones.

Except for the hybrid address, which was explained above, the ISO 20022 roadmap introduces several additional concepts:

• SWIFT Case Management: Standardized messages for handling investigations, exceptions, and returns. It also includes E&I (Exeptions & Investigations) message types, which are ISO-based formats for managing follow-ups, claims, and enquiries
  • It is already available on an opt-in basis.
  • From November 2026, banks must be able to receive camt.110 messages (MT199).
• SWIFT non-instruction message types: Supporting messages like status updates, confirmations, and notifications — all moving to ISO-native formats.
• SEPA 3.7: updated version of the SEPA payment standard.
  • SEPA version 3.6 will be decommissioned in November 2025 and SEPA 3.7 becomes mandatory.
  • New formats: pain.001.001.09 for credit transfers, pain.008.001.08 for direct debits, and pain.002.001.10 for status reports.
• DTAZV: German DTAZV format for cross-border payments will be discontinued and replaced by the pain.001 AXZ format, based on ISO 20022.
  • Sender and beneficiary addresses must be fully structured. Unstructured address fields will no longer be accepted.

Being aware of these timelines is crucial for planning upgrades and ensuring readiness across all impacted areas.

What still needs to be done

The true value of ISO 20022 lies not in compliance, but in the data it enables. The richer the data, the more intelligent and efficient the processes that rely on it.

With the November 2025 deadline approaching, institutions need to shift focus from compliance to capability. A robust transition plan should include a full impact analysis, covering system compatibility, infrastructure upgrades, and the operational impacts of migrating to structured data. Data field alignment is critical — ensuring existing formats are properly mapped to ISO 20022 structures to avoid truncation or data loss.

Regulatory compliance remains a core requirement, particularly in areas like data privacy and security, where richer information introduces new obligations. Institutions must also ensure stakeholder alignment across departments and external partners to coordinate migration timelines, budgets, and change impacts.

Risk management and contingency planning are vital during the transition period, alongside contingency monitoring to detect and address issues in real-time. End-to-end testing, ideally with counterparties or in sandbox environments, will be essential to validate readiness.

Internally, staff training on enriched message data and its business implications must not be overlooked. Banks will need to equip teams with the knowledge to manage and interpret structured data effectively. At the same time, organizations should re-evaluate their data strategies — moving from a focus on compliance toward leveraging ISO 20022 as a driver of value and competitive advantage. Finally, future milestones must be factored into today’s planning.  Institutions should prepare for structured address requirements by November 2026, when all unstructured postal addresses will need to be converted to a standardized, structured format in alignment with ISO 20022. This deadline is particularly critical, as it marks a significant shift in how address data is handled across payment systems. Institutions must prioritize this change to ensure they meet the requirements and avoid disruptions in payment processing.

Additionally, they should begin assessing readiness for the retirement of Exceptions & Investigations (E&I) messages in November 2027. These are not isolated phases, but part of the broader ISO 20022 journey toward fully modernized, data-driven payments.

Conclusion: The countdown has begun

With less than seven months to go, the end of coexistence is coming fast. But treating November 2025 as the finish line would be a mistake. It’s not just about being compliant — it’s about being competitive in a landscape defined by data, intelligence, and interoperability.

Those who approach ISO 20022 as a strategic investment, not just a regulatory necessity, will unlock its full potential. The future of payments is clearer, richer, and more connected — but only if we build the right foundation now.