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Feature

Time to test T+1


14 April 2026

With the move to a next-day settlement cycle approaching, a taskforce has been established between the UK, EU, and Switzerland to advise firms on the best ways to prepare themselves. Andrew Douglas, chair of UK T+1 Taskforce, and Giovanni Sabatini, chair of the EU T+1 Industry Committee, discuss the readiness plan with Hansa Tote

Image: stock.adobe.com/Sensvector
The UK Accelerated Settlement Taskforce (AST), the EU T+1 Industry Committee (IC), and the Swiss Securities Post Trade Council T+1 Task Force (swissSPTC), have published a unified Testing and Readiness Plan to guide the European financial industry through its transition to T+1 settlement on 11 October 2027.

The plan is the first of its kind to span the EU, UK, and Swiss financial markets simultaneously, and provides a framework for all market participants and financial infrastructures (FMIs) to assess their readiness for the shorter settlement timeline, in addition to de-risking the transition prior to its go-live.

Andrew Douglas, chair of UK T+1 Taskforce, and Giovanni Sabatini, chair of the EU T+1 Industry Committee, discuss the aims and objectives of the taskforce, lessons learnt from the US’s transition to T+1, and how to measure success.

What should firms already be testing today to stay on track for T+1 in 2027?

Andrew Douglas: Everything.

A common question I get is ‘what should I do to be compliant with T+1?’ and the reality is, it is impossible to know how every firm currently conducts their processing, whether they have outsourced processes, how much is in house, and how much is automated.

So to answer that question, I encourage firms to review the report published by the AST in February 2025, reverse engineer the recommendations into their own back office, and work out what they need to do to be compliant.

A simple example of this is the automation of standard settlement instructions (SSIs). It is important that firms automate that SSI process, and there are a number of solutions in the market to allow them to do this. If a firm has already adopted an automated SSI solution, then there is no need to test it, because they are currently using it, and probably have been for some time.

However, if a firm has not automated their SSI process, then they will need to work out what they are going to implement to meet that requirement. If it means that they have to build something or buy something, then they will need to test. So, for the rest of this year, the key message is to start testing today where you have changed your existing process.

If a firm has built or modified a proportion of its processing cycle to include automation, it can test it with its automation provider. What we as a taskforce are arranging, in conjunction with our colleagues in Switzerland and the EU, are periods in 2027 where companies will be able to do full end-to-end testing, meaning they can replicate the entire value chain from the creation of a transaction through to the settlement of that transaction and dealing with post-trade activities, such as corporate actions.

What do firms need to test now? Whatever they have changed. What will you need to test in the future? Whatever they change in the future.

I would recommend that everybody does at least one end-to-end test before the go-live of T+1. Firms can operate a T+1 environment within the existing T+2 setup, therefore, they are currently able to implement their T+1 solutions.

Firms are able to self-certify that they are compliant with the requirements for T+1 on a readiness register hosted on the Taskforce website, with Baillie Gifford and Swiss Re already having stated they are able to comply with the shorter settlement timeline.

Firms should be working on implementing their solutions for T+1 now, so by the end of this year, they are ready to go into the end-to-end testing phase.

Giovanni Sabatini: The main message from the joint testing plan is that firms should not wait for the formal 2027 market-wide testing windows. The plan says “begin preparation NOW”, use existing business-as-usual test environments now, and spend 2026 getting operationally ready so that 2027 can be used to prove the full transaction lifecycle under T+1 conditions. In practice, that means testing whether allocations and confirmations are completed on trade date, whether settlement instructions are sent early enough, whether matching happens fast enough, and whether firms can actually settle on the intended settlement date under compressed timelines.

Firms should also prioritise testing the things that tend to break under time compression: SSI workflows, partial settlement and hold/release usage, inventory and liquidity management, securities lending recalls, FX funding and cut-off alignment, and corporate-action flows that still rely on manual touchpoints. The testing plan explicitly points firms toward scaled use of tools like auto-partial, hold and partial release, while the EU handbook pushes straight through processing SSI exchange, more automation in buyer-protection and corporate-action processing, and tighter FX lifecycle control.

This is the first unified testing framework spanning the EU, UK, and Switzerland. What are the biggest operational challenges in aligning the three jurisdictions with different regulatory structures and market practices?

Douglas: The biggest challenge was the initial one: agreeing that all three jurisdictions should sign up to the same testing process as participants requested a single testing environment, not three separate ones, and Giovanni Sabatini, Florentin Soliva, chair, Swiss Securities Post-Trade Council T+1 task force, and myself agreed to provide this.

Despite the hurdle of being three parties having largely separate project teams, sharing the same goal unified our thought processes in creating an environment where all market participants can cross the finish line together on 11 October 2027.

The UK and Switzerland, as evidenced in the report, have a similar structural setup with a single infrastructural silo, with a single central securities depository (CSD) supported by a limited number of central counterparties (CCPs). Europe is a different beast, with multiple CCPs and CSDs operating at Member State level.

The testing plan is therefore almost identical for the UK and Switzerland, and identical in structure but different in detail to that of the EU , harmonising as far as is possible, requirements of all three jurisdictions.

I am astounded by how well the jurisdictions have worked together to deliver such a significant result in such a short period of time. The work only began at the end of November, and to be able to deliver that plan in March meant it was essentially finalised by the beginning of this year, it is a remarkable achievement, proving that jurisdictions can work together when they share a common goal. The secret is establishing the common goal.

Sabatini: The main challenge is that, while the target (T+1) is aligned, the operational models are not. Markets differ in settlement workflows, levels of automation, cut-off times, and reliance on manual processes, so firms are not starting from the same baseline.

Fragmentation is the bigger issue. Europe spans many markets, CSDs, currencies, and time zones, with different matching practices, SSI standards, and funding/FX timelines. This makes it harder to standardise key processes like allocation, confirmation, and instruction input.

A key constraint is limited end-to-end connectivity in testing. Even where trading venues and CCPs are linked, that often does not extend to CSDs, so firms cannot always test the full chain. The result is that success depends on synchronising multiple interdependent workflows across infrastructures and compressing them into T+1.

Finally, operational differences are reinforced by differing legal and regulatory frameworks across the three jurisdictions, which adds another layer of complexity to alignment. In the EU, the transition sits inside a formal public-private governance structure and a Central Securities Depositories Regulation (CSDR)-based legislative framework, with the European Securities and Markets Authority (ESMA) also preparing regulatory standards. In the UK, the move is being enabled through amendments to UK CSDR plus a market Code of Conduct. In Switzerland, the report is explicit that there is no CSDR-equivalent settlement-cycle regime and that the migration is based on self-regulation. So, the industry has one testing framework, but three different legal and supervisory architectures to map it onto.

The framework draws on lessons learnt from the US move to T+1. Which lessons are most relevant for Europe, and where do you think Europe’s transition will differ?

Douglas: European markets operate differently to the US. Focusing on the UK, superficially, there are some similarities between that market and the US, but the differences can be quite profound.

I frequently caution firms that, even though they may have completed the US migration, they should not assume that they are set up for the UK, the EU, or Switzerland, because of the differences in markets.

For example, in the US, they start with the affirmations process, however, the UK does not use affirmations, we use confirmations. The UK in particular, is a big user of partial settlement, something that is not widely used in the US and hardly used at all in Europe. So, there are differences between the jurisdictions and T+1 at its heart, encourages environment harmonisation between jurisdictions.

Regarding relevant lessons learnt from the US, they did a splendid job of providing a very clear and robust testing plan and environment for participants, which we have sought to emulate. This is why we produced such a comprehensive testing plan, ahead of our original timeline of the end of 2026. The industry wanted the plan sooner, so the taskforce used the experience from the US to provide a clear plan ahead of time.

Sabatini: The most relevant US lesson is that settlement-cycle compression is really an operational-discipline project. The testing plan borrows directly from the US focus on same-day allocation, confirmation and affirmation discipline, and it translates that into concrete metrics for Europe: timing of allocations and confirmations, timing of instruction input, matching rates, and settlement efficiency on intended settlement date.

Where Europe differs is in structure and complexity. The EU handbook is clear that Europe will not mirror the US because the US has one central CSD, one currency and a centralised regulatory framework. In contrast, Europe has many markets, many CSDs, multiple currencies and more heterogeneous market practices. So, Europe could reuse the US playbook on automation and metrics, but not assume a US-style implementation path.

The testing plan highlights that participant readiness depends on the entire settlement chain. Where do you currently see the weakest links across that chain?

Douglas: The settlement chain is highly dependent on each participant ‘doing their bit’ according to the recommendations, whether that is the asset manager submitting allocations on time, automating their instruction matching and submitting according to custodian deadlines; the intermediary they choose to for providing specific services; or the custodian being ready to send the instruction into CREST.

It is a chain of events, and each leg requires the previous leg to have done their job properly and on time. So, who is the weakest link? It is whoever has not geared up for T+1, and that could vary from chain to chain. So, it could be the asset manager, or the intermediary or the global custodian. Success very much depends on the readiness of everyone.

Firms need to satisfy themselves that the chain of which you are a part is ready.

Sabatini: My read is that the weakest links are wherever the chain still depends on manual intervention or on hand-offs between institutions rather than straight-through processing. The joint plan itself points to a structural weak point: testing connectivity often stops at the CCP/CSD boundary, which means firms may prove their own segment works without proving the entire chain works. It also stresses that readiness depends on the whole chain, including underlying clients, and says FMI users should bring those clients into testing where relevant.

Beyond that, the recurring pressure points across the EU documents are pre-settlement matching, SSI quality, funding/FX readiness, and inventory mobilisation. The roadmap highlights pre-matching, resource management, SSIs, and messaging standards as core areas for improvement; the handbook says SSI exchange and storage need to become much more standardised and STP; and both the roadmap and handbook flag FX timing, partial settlements, and securities financing optimisation as sensitive points.

What does success look like for industry testing? Is it about participation levels, settlement efficiency, or measurable reductions in fails?

Douglas: Success will look like all of the above. It will be all participants crossing the finish line together; there will be no joy in seeing firms fail to do so. We are currently in the process of working out what we would expect as a fail rate post go-live.

Going back to what we learnt from the US, we know specifically from them that good preparation and good testing means that fail rates do not increase post go-live, so we will be expecting to see equivalent levels of preparation, equivalent levels of testing, and equivalent levels of success post go-live.

Our ‘targets’ are yet to be finalised, but my expectation is that post implementation, settlement rates should not be worse than they are currently.

When we started this process, I was asked what I expect to happen on 11–12 October, and my honest answer, which has not changed, is, I hope nothing happens on those days.

I hope firms will have prepared adequately, will have tested appropriately, and it will simply be business as usual. In fact, I would hope that many of them are already operating on the T+1 cycle when it does become live, because as an asset manager, you can operate on a T+1 cycle today, and some firms already do operate on the T+1 settlement cycle. Statistics show that roughly 80 per cent of matched instructions are already received by CREST by the specified T+1 deadline of 05.59 on T+1.

Firms should focus on the 20 per cent of transactions that currently do not meet the T+1 requirement, and work out why that is, because there is the possibility that they might not need to reengineer everything that they do, there might simply be something that needs a little bit more focus, a little tweak to get their rate up from mid 80s to mid 90s, which is where firms need to be, because the broader settlement rate today is 97 per cent on T+2 and we want to replicate that on T+1.

Sabatini: Success is not just high participation. Participation matters, especially because the plan is trying to synchronise testing across the transaction chain and across jurisdictions, but the documents are clear that the real objective is de-risking the live transition. That means proving firms can run the full lifecycle in T+1 time, proving dependencies on agents and providers are understood, and proving that enough of the chain is ready at the same time for cross-market and cross-border flows to work.

I would define success in measurable terms: earlier allocations and confirmations, earlier instruction input, higher same-day matching, strong settlement efficiency on intended settlement date, and no material increase in settlement fails at go-live. The testing plan’s own metrics framework points exactly there, and the EU roadmap says the move will be undermined if it causes a significant increase in settlement fails. In other words, participation is the input; settlement efficiency and fail reduction are the outcome.

How will the Taskforce measure whether early testing has been successful in ensuring readiness ahead of October 2027?

Douglas: We will be looking at who is testing and what they are testing. We will rely on intermediaries telling us how they are progressing and when I say an intermediary, I mean a provider of automated processing solutions such as SSI, matching, workflow automation etc., and we will be asking them what testing and success levels have they seen? We work very closely with the global custodians, mostly via an organisation called the Association of Global Custodians, and the taskforce will be asking them the same questions.

The regulator is obviously very interested in how implementation goes because part of its role is to protect the financial stability of UK markets. Therefore it is important that we do not see potential instability brought in as a result of excessive trade fails. This means it is important that every involved participant treats this with the degree of attention that it warrants.

T+1 is a regulatory requirement, there will be a change to UK CSDR, which will state that firms are required to settle on T+1.

The UK Financial Conduct Authority (FCA) has specifically said it will be taking a “more intrusive approach”, by engaging directly with firms to ask them how their implementation is progressing, and critically, will require evidence of their progress.

Within the Accelerated Settlement Taskforce, we will also continue to conduct engagement surveys which will specifically test the water regarding preparations. We do these every six months, one in Q1 and one in Q3, providing an indication of progress.

Why is T+1 a “pillar of the Savings and Investment Union” in practical terms?

Sabatini: In practical terms, T+1 is not just a post-trade plumbing change or a compliance exercise — it is a competitiveness and integration measure. By reducing settlement risk, margin drag and cross-border friction, it makes capital markets cheaper and more efficient to use, supporting deeper liquidity and more attractive conditions for issuers and investors.

There is also a clear strategic dimension. As global markets have already moved to T+1, misalignment creates cost and complexity for EU participants. Aligning with that standard is therefore essential if Europe wants to remain competitive and globally connected.

Ultimately, calling T+1 a pillar of the Savings and Investment Union means recognising that you cannot build deeper, more integrated capital markets while core post-trade processes remain slower, fragmented and manual. T+1 forces the standardisation, automation, and integration needed to support that goal.
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