One way or another, all international Swift payments will follow the ISO 20022 standard by the Nov. 22 deadline, according to the financial messaging provider.
"We will no longer deliver payment instructions in anything but ISO 20022 after the deadline," Stephen Lindsay, head of market infrastructures and standards for Swift, told American Banker. Swift supervises the ISO 20022 standard for international payments.
Most cross-border payments are already compliant with the new standard, Swift said.
One of the stressors around ISO 20022 is that it's a new format and a new requirement, not a payment transition where both old and new are supported, similar to the shift in payment cards from magnetic stripe to EMV, Jessica Pinkston, a senior director at Cornerstone Advisors, told American Banker.
Swift is continuing to prepare a contingency solution that will convert legacy message formats to ISO 20022 systems after the deadline if need be. This will end a period of co-existence between ISO 20022 and non-ISO 20022 payments that dates to 2023, when Swift's migration window began. Swift did not comment on potential added costs if the messaging organization needs to provide compliance on behalf of member banks, or the potential delays or disruptions to settlements required by the additional work to convert non-compliant payments.
The contingency may be necessary due to a number of banks not being ready by November. In December, less than 34% of banks were compliant with ISO 20022, according to
The cross-border payments market is massive. There were $194 trillion in cross-border payments in 2024, according to
Compliance with ISO 20022 is top heavy in the banking industry, covering most cross-border payments. The top 175 banks in Swift's community handle 80% of cross-border transactions and generate 86% of payment messages.
"For the big banks, the signs are all good," Lindsay said of ISO 20022 compliance. "For the smaller banks or maybe even smaller branches of bigger banks, we have a plan to make sure they can go through the end of co-existence cleanly and still do business with their counterparts."
While the top 175 banks are mostly compliant, they are not the majority of the banks. Swift has more than 11,500 banks in its messaging network. About a third of those banks are ISO 20022 compliant.
Compliance for smaller banks is generally outsourced, a more difficult task than for large banks that managed their upgrades internally. And banks of all sizes are also managing other payment-related deadlines, particularly in Europe. These include the Digital Operational Resilience Act, the PSD3 and PSR European Union payment security updates that include an 18-month transition period during 2025 and 2026, according to
The ISO 20022 migration affects treasury management, enterprise resource planning and dozens of other bank departments that touch payments or transaction processing.
ISO 20022 replaces MT standards, which have been used for years to guide domestic and cross-border payments. The new standards add data and context to payments to mitigate security and operational risks.
"In the end, there will be less complexity to manage overall, everyone will be using the same data structure," Lindsay said.
Projects that are designed to make real-time processing interoperational across borders will also get a boost via full ISO 20022 compliance, because most of the world's largest instant payment schemes, such as FedNow and The Clearing House's RTP network, use ISO 20022 messaging.
"It's important to have the same standard for payments end to end, so the payment doesn't get corrupted and has a lot of value," Lindsay said.
ISO 20022 is an incredibly complex migration so undoubtedly some won't be ready, Gareth Lodge, a senior analyst at Celent, told American Banker.
"Indeed, no migration even close to this size has ever been 100% ready on time," Lodge said.
Through its contingency, Swift has already committed to maintain a conversion process for banks, which will be difficult to "turn off" because it's hard to know how many banks won't meet the deadline and how long it will take these banks to get up to speed, he said.
"That will also be a tough discussion," Lodge said, noting that the largest banks on Swift account for most of the traffic.
"So should every other bank wait until the very last and very smallest bank is ready?" he asked. "The answer is no, but how many is enough will be a challenging question to address. This will also be true for the FedWire migration."
