SWIFT ISO 20022: Payments and more …
SWIFT payments and related messages are changing to ISO 20022 standard in the coming years. Domain Matters have developed this senior management briefing to guide accountable executives in terms of the key issues, delivery approaches, risks, timeframes and potential next steps. These changes will be market mandatory over the medium term.
At this point the key action item is to approve seed funding to develop detailed Impact Assessment(s) and Implementation Plans during 2021.
Context – what’s changing, why, and when
Message standards and transport are fundamentally changing in the medium term, primarily driven by a rebuild of the Payments Market Infrastructures in the US, UK, EU and elsewhere. Securities, FX, and Trade Finance are less of a priority at this point.
SWIFT are currently proposing a rolling implementation approach, with transition commencing November 2022 through to 2025. We expect the ECB to align the adoption of 20022 within Target2 to this time frame.
We also expect SWIFT to offer a centralised, subscription-based translation service, starting in November 2022. However, this potentially helpful in-line offering will likely require significant per-firm configuration and testing effort at the firm level and will not resolve the issues around message truncation for 20022 data overflows. A centralised tool will not insulate banks from needing to invest and resource to manage change to 20022.
The key business change provides end-to-end traceability of the beneficiary which should reduce friction in cross-border payments and the need for intervention and repairs: increasing efficiency and visibility. Dealing with errors and tracing payments becomes easier, and there are also positive implications for KYC, AML and sanctions screening.
However a new and richer message language needs to be learned, both functionally and technically; not only for payments, but also for statements and reconciliations.
These changes are business-critical, significant in scale, and market wide.
There are three visible strategies as a response:
- Market leader/prime mover, re-engineer processes, extend products and services such as Instant Payments, Real Time Liquidity View, and intraday reconciliation;
- Mid-range response, keeping pace with market and competitor changes, though this is likely to result in loss of market share; or
- De minimis delayed response, assuming either market wide slippage and/or vendor driven translation and migration solutions become ubiquitous and ongoing.
Running BAU in the interim is a non-trivial task and managing change control for existing payments servicing has to be executed in parallel unless the de minimis path is taken.
ISO20022 is XML based, and most organisations will have little difficulty in managing the technical migration to XML, since almost all recently developed package and bespoke applications are XML-friendly. There will however be legacy applications that can’t handle XML – and translation or transformation strategies will need to be developed.
Various risks will arise as a function of ISO20022 migration:
- Reputational – market leader/follower and client response;
- Operational – process, data and reconciliation changes which is poorly handled will lead to real world operational cost and risk uptick;
- Liquidity : opportunity to reduce liquidity buffers and associated regulatory capital could be harvested, or missed; and
- Vendor – need to manage multiple vendors in the delivery chain and ensure your firm has the priority and visibility or User Group voice needed.
The regional approach proposed by SWIFT, aligned to Market Infrastructure players, will have variable impacts and risks since few if any firms are unlikely to have globally consistent internal infrastructure and application architectures. Prima facie, AsiaPac and home markets will be the particular focus here.
If the migration to 20022 is not well managed, firms will attract negative attention from Regulators and Clients, whilst watching margins decline. Not an attractive scenario.
At this point, we believe that seed funding for initial planning needs to be approved for 2021 such that the initial strategy is socialised and agreed, meaning that build and implementation plans are ready to go by end 2021.
Domain Matters: Planning Playbook
Domain Matters have prepared an outline 2020-20022 Planning Playbook, which complements the planning information SWIFT have recently published: https://www.swift.com/sites/default/files/files/SWIFT_ISO20022_Bugdet_Reference_2021_0.pdf
Our playbook includes multiple segments so that the full landscape can be understood well in advance of commitment to material program spend. Our overall approach is based on the following philosophy in terms of total effort and costs:
- 10% Assess and confirm strategy
- 30% Detailed Build and Implementation Plan
- 20% Build
- 40% Test and Migrate
It is worth noting that, depending upon the client and product matrix approach, 20022 adoption can deliver a positive Business Case for larger (Tier 1 or Tier 2) Banks, particularly where migration to the new standard is used as an opportunity to create consistency across legacy regional payments stacks via a global operating model.
The Domain Matters Playbook has 7 segments:
1. Impact Assessment
A wide ranging and multi-disciplinary assessment is a critical first step. Leading Banks are already considering the impact on their Payments business and Infrastructure.
- Entities and Network Management
- Client and competitor readiness
- Technology and application landscape – focus on legacy and APIs
- Real time requirements
- Operations and process catalogue
- Data layer
- AML and KYC processes
- Funding and liquidity modelling including intraday impacts
- Secondary impacts to Securities, FX, Trade Finance and Reconciliations
- Process improvements ranked by RoI, plus mandatory process improvements
- Product management roadmaps
2. Business Case and Program Funding
- Three year budget horizon for the program and approval process
- Agent and clearing cost deltas
- Potential revenue opportunities
- Regulatory capital impacts
- Vendor cost profiles
- SWIFT fees
- Map gap for MT1xx; MT2xx; MT3xx; MT9xx categories and potentially MT5xx series
- Functional solutioning; vendor assumptions
- Phasing decisions
- Traceability, data lineage and data management
- Technical gateways, security and capacity
- Communications and Industry engagement approach
4. Delivery Plan
- Technology build plans
- Client readiness
- Agent readiness
- Operations readiness
- Reference Data build and remediation including cleansing
- Test strategy
- Tooling and automation
- Traceability matrix
- Sink files
- Non-functional testing including stress testing and cyber
- Market test windows and CUG membership
- Co-existence and cutover switches
6. Implementation and Migration
- Market implementation strategy
- Alignment to SWIFT regional windows
- Internal and external training and education
- Rollback/recovery approach
- BAU monitoring
7. Change Control
- Aligning ongoing BAU and Product/Client changes to in-flight delivery and build plans
- Code freeze approach
- Vendor release roadmaps
About Domain Matters
We offer operations and technology advisory services, interim management and change delivery services to the Financial Markets, Securities Services, Wealth Management and Private Equity industries.
Why Domain Matters?
Our Industry leads have been working with SWIFT for more than 30 years, across asset classes, functions, regions, and Industry segments.
We strongly believe that we must understand our clients’ industry in order to provide insight and deliver productively. Each of our consultants has two or more decades of experience delivering solutions in the financial markets and technology industries. We have access to a significant pool of Subject Matter Experts in the post-trade messaging space together with associated technology counterparts.
We’re not simply subject matter experts, we can deliver action – through our consulting experience we bring a structured, rigorous approach to delivery and are able to follow through from recommendation to action.
Please don’t hesitate to contact us if you want to know more:
Domain Matters Ltd
Registered in England and Wales
Company number 10682935
58 Burnt Ash Road
London, England, SE12 8PY