Nearly half of banks are behind on ISO 20022

I grew up in Gwalior, India, but I’ve lived in London, England, with my family since 2013. 

There are many differences between the two. The weather is the first thing that springs to mind. Food is another. But one difference that most people are less familiar with is postal addresses. 

See, in the West, addresses typically start with a house number or name and end with a postcode (House > Street > City > State > Country). In India, however, it’s often different. Addresses frequently include landmarks to help identify a location — “near City Mall, opposite the bus stop,” for example. It is left to the delivery person to interpret the information to determine the exact location. 

These differences matter in payments. Not only from a routing and processing perspective, but also from a regulatory compliance and reporting standpoint. 

And in 2026, they sit at the heart of one of two major ISO 20022 challenges facing the industry.

Challenge One: Structured addresses migration

ISO 20022 is introducing structured data formats to reduce ambiguity and increase transparency. For addresses, that means defined fields for House, Street, City, and more. Hybrid addresses — combining structured and limited unstructured elements — will help accommodate global variations. But the direction of travel is clear: free-text flexibility is ending. 

From November 2026, fully unstructured address information will no longer be accepted in CBPR+ messages. This change will begin with specific mandatory fields, not the entire address, but the implications are significant. 

For many institutions, address data remediation touches core banking systems, client data files, screening processes, sanctions checks, and customer onboarding workflows. It is not a simple format update — it is a data transformation challenge. 

Challenge Two: Exceptions and Investigations handling

At the same time, the industry faces a second, equally complex shift: the modernisation of exceptions and investigations (E&I). 

For nearly 40 years, E&I processes have relied heavily on manual workflows and free-text messaging. When payments fail or require clarification, resolution often depends on human intervention across operations and client-facing teams. 

Consider how much payments have changed in four decades. Internet and mobile banking did not exist. Volumes were dramatically lower. Yet the way we manage payment issues has remained largely unchanged. 

Swift is now modernising this framework. By November 2026, banks must be able to receive structured ISO 20022 E&I messages, including new message types and purpose codes. By November 2027, they must also be ready to send them. 

This transition replaces informal, free-text workflows with structured CAMT messaging. It demands system upgrades, process redesign, and operational retraining. 

A defining year for ISO 20022

Taken together, structured address enforcement and E&I modernisation represent two parallel transformations. Both are mandatory. Both are technically complex. Both affect core systems, data, and operations. 

And both must be delivered under fixed deadlines. 

Against this backdrop, we surveyed 308 senior payments professionals across Europe and North America about their ISO 20022 readiness for 2026 and beyond. 

This report explores how institutions are approaching these twin challenges — where confidence is strongest, where risks remain, and where deadline pressure may still be underestimated. 

Some institutions are using ISO 20022 as a platform for data transformation and operational improvement. Others risk treating it as a compliance exercise. 

The difference will become clear as enforcement begins. 

We hope you find this research useful. If you have any questions about the ISO 20022 requirements, please do not hesitate to get in touch. We are always happy to help. 

Download the report.