Austria, Belgium, Cyprus, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Portugal, Slovakia, Slovenia, and Spain.
Breaking news (28/07/2020): Following requests by the European financial community and the subsequent survey conducted by the AMI-Pay and AMI-SeCo among a wide range of market stakeholders and in light of the challenges posed current pandemic and SWIFT’s decision to delay the cross-border messaging migration to ISO 20022, the Market Infrastructure Board has reviewed the timeline of the T2-T2S consolidation project and has concluded that postponing its go-live by one year, from November 2021 to November 2022, would best accommodate the industry’s preferences. The Governing Council of the ECB has decided to extend the timeline of the T2-T2S consolidation project by one year, following discussions with Europe’s financial community. The project is now scheduled to go live in November 2022. 
Currency: EUR (Euro)
Clearings in scope of migration: TARGET2 + EURO1. EBA Clearing has committed to “maximal alignment” with TARGET2 timelines and formats.
ISO 20022 Adoption in Eurozone: All SEPA (Single European Payments Area) compliant messages (including SCT, SCT-inst, and SDD) use ISO 20022 formats. As such, ISO 20022 market penetration is quite strong with corporates, particularly for payment initiation.
Message format currently in use: SWIFT MT in use until November 2022. On 20 November 2022, MX messages will replace MT messaging.
Suggested Migration Approach:
Migration approach: Big bang approach. All HVPS payment messages will be replaced by fully rich ISO messaging at the same time during the migration weekend in Nov 2022, i.e. no phased approach, coexistence period, or clearing-side message conversion service.
As Europe is going for full-fledged, rich ISO as of 2022, it is strongly recommended that banks do not rely purely on translation services for their payments. Whereas the solution could be appropriate for smaller retail banks, the market penetration of corporates using ISO 20022 for payment instruction and reporting dictate that banks seeking to cater to these larger customers should ensure that information can be adequately passed along to their beneficiaries and integrated into their reporting. Correspondent banks, in light of FATF-16, face significant compliance risk if they truncate ultimate creditor/debtor information. They will also face commercial risks if they do not have a solution to ensure that they are not truncating their FI customers’ payments. If a full overhaul of their payment solutions is not possible within the November 2022 timeframe or at a reasonable cost, they should consider overlay services.
The European HVPS messaging format has been published by the ECB and is available in MyStandards in the T2 RTGS group. Access is automatically granted if requested. The current latest version is UDFS 2.1, which was released in December 2019. UDFS 2.2 is expected to be published in November 2020 and will incorporate the final change requests.
The Eurosystem supports ISO messages for payments and associated reporting and recall requests through the TARGET2 module, securities processing through the T2S module, as well liquidity management through the CLM module.
Batch Payments: Each pacs.008 can only contain a single credit transfer, TARGET2 and EBA Clearing will not support batch payments.
End-to-end identification: if provided in the payment instruction, should be carried throughout the payment chain. If none is provided, the value NOTPROVIDED should be used. This should not be confused with SWIFT’s UETR, and cannot be mapped to MT messages.
Structured Party Information:
The following two rules related to parties (eg. debtor, creditor, ultimate debtor, ultimate creditor) in UDFS 2.0, when taken together, result in the requirement to submit structured addresses:
- If OrganisationIdentification/AnyBIC and LEI are absent then Name, TownName and Country are mandatory to identify the Debtor
- If PostalAddress is used and if AddressLine is present, then all other optional elements in PostalAddress must be absent.
UDFS 2.1 did away with the requirement to use structured addresses, with several national banks commenting that this requirement would likely be reinstated at the end of SWIFT’s coexistence period in 2025.
Structured Remittance Information is supported by UDFS 2.1 and allows for up to 9000 characters of structured remittance information, tags not included. Structured remittance information cannot be mapped to MT and can provide essential information for compliance and reconciliation purposes. Banks should ensure they are not truncating remittance information, and take into account that extended remittance information can significantly bloat message sizes. Banks should ensure they either isolate their payment systems are adequately dimensioned.
Ultimate debtor/creditor: Ultimate creditor and debtor information is enabled, as well as instructing party. None of these fields can be structurally mapped to an MT message. Passing this information down the chain is not only essential for reconciliation by corporate customers making use of payment/collection factories, but a legal requirement for correspondent banks in light of FATF recommendation-16.
Tax: Unlike in CBPR+ messages, Tax fields are not supported.