T+1 komt dichterbij: focus op implementatie en testen
AI Analysis
AFM is relaying ESMA’s confirmation that the EU T+1 settlement framework is complete and that securities transactions will move from T+2 to T+1 on 11 October 2027. The immediate compliance priority is the first phased requirement, applying from 7 December 2026, for investment firms and their professional clients to exchange allocations and confirmations through electronic, standardised and machine-readable channels; industry commentary highlights material impacts on automation, matching, settlement instructions, custody, FX, liquidity and cross-border operating models.
Key dates
- 2026-12-07 Deadline
- First phased requirements under the amended RTS on settlement discipline and related ESMA guidelines apply to allocations and confirmations, including electronic, standardised and machine-readable communications, subject to the temporary technical disruption exception.
- 2027-07-01 Deadline
- Additional phased requirements under the amended RTS on settlement discipline become applicable, as specified in the regulation’s transitional provisions.
- 2027-10-11 Deadline
- Regulation (EU) 2025/2075 applies and the EU standard securities settlement cycle changes from T+2 to T+1; the final phase of related settlement-layer requirements also applies.
Suggested considerations
- Firms should map every affected transaction type, market, currency, venue, CSD, custodian, broker, client and outsourcing provider across the full trading and settlement ecosystem rather than assessing only internal readiness.
- Compliance and operations teams may wish to confirm whether allocations and confirmations can be completed on trade date and transmitted through electronic, standardised and machine-readable channels from 7 December 2026, including accurate place-of-settlement data where required.
- Firms should assess and test ISO or other applicable international messaging standards, matching platforms, standing settlement instruction governance, exception handling and the documented process for temporary technical disruptions.
- Firms should identify manual processing steps that cannot reliably operate within the shortened timetable and consider automation, straight-through processing, reconciliation, controls over data quality and resilient fallback arrangements.
- Firms should obtain implementation commitments and test plans from clients, brokers, custodians, CSD participants, CSDs, CCPs, vendors and outsourcing providers, with evidence of end-to-end testing and defect remediation.
- Firms should review liquidity, collateral, margin, FX funding, corporate-action, securities-lending, fund dealing and investment-operation processes for the reduced interval between trade and settlement.
- Firms should maintain a regulatory change plan covering the phased milestones on 7 December 2026, 1 July 2027 and 11 October 2027, with senior management oversight, documented risk acceptance and escalation of unresolved dependencies.
What changed
Regulation (EU) 2025/2075 amends Regulation (EU) No 909/2014 (CSDR) and provides for the EU settlement cycle to apply on a T+1 basis from 11 October 2027. Commission Delegated Regulation (EU) 2026/1536 amends the RTS on settlement discipline in Commission Delegated Regulation (EU) 2018/1229, with phased application beginning on 7 December 2026. From 7 December 2026, the allocation and confirmation process must use electronic, standardised communication channels and international messaging standards, with machine-readable communications required except during temporary technical disruptions. The amended RTS and associated ESMA guidelines also support same-day processing of allocations and confirmations, inclusion of place-of-settlement information, and later settlement-layer changes, includ
Compliance impact
This is a high-priority operational and regulatory change rather than merely a future-market convention: the 7 December 2026 allocation and confirmation requirements are binding requirements under the amended settlement-discipline framework, while the 11 October 2027 T+1 date is established by Regulation (EU) 2025/2075. ESMA and national competent authorities have indicated that compliance monitor
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original AFM source before acting. Full disclaimer.
What the AFM said
Met nog een jaar te gaan tot de invoering van T+1-settlement op 11 oktober 2027 roept ESMA marktpartijen op hun voorbereidingen af te ronden, hun operationele gereedheid te beoordelen en zo snel mogelijk te starten met testen in de handels- en afwikkelingsketen. Met de publicatie van de laatste technische standaarden…
Extract from AFM . Read the full notice at the source for the authoritative text.