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How to transition from a tactical to strategic adoption of ISO 20022

ISO 20022 adoption has lagged in the face of competing global deadlines. But a strategic mindset shift may help bring a successful migration.

With special contributions from Colin Williams, Global Lead of Clearing Transformation at J.P. Morgan Chase, and Jesús De Lara, ISO Head of Business Readiness & Commercialization for J.P. Morgan Chase.


In brief
  • The migration to the ISO 20022 messaging standard is a crucial initiative for the financial services industry.
  • However, adoption has been slower than expected.
  • Financial institutions need to shift from a minimal compliance mindset to a long-term, strategic vision to fully take advantage of the new standard.

The year 2023 was a breakthrough year for ISO 20022, with many global Market Infrastructures (MIs) migrating their Real Time Gross Settlement Systems (RTGS) to the modern messaging standard. This included the Bank of England for CHAPS, European Banking Authority (EBA) for EURO1, the Eurosystem for the new T2 wholesale payment system overseen by the

European Central Bank (ECB), and the start of Swift’s ISO 20022 cross-border payments and reporting (CBPR+) migration period in March 2023. While members institutions have met requirements for migration, the focus has been on implementing minimal changes that enable like-for-like translation vs. strategic planning for enhanced ISO 20022 data in the back office. With Clearing House Interbank Payment System (CHIPS), Federal Reserve, and Swift deadlines coming throughout 2024 and 2025, institutions should not only work toward basic compliance, but consider how to strategically position themselves to achieve the intended benefits of ISO 20022 migration for their clients, their shareholders and the greater financial community.

 

When the CBPR+ coexistence period began in March 2023, 15% of payments instructions were initiated in ISO 20022. As of November 2023, the adoption rate has only increased to 18%. This has not met the industry’s expected pace, raising concerns about the readiness of the financial industry for 2025 requirements. While the majority of banks are doing the minimum to comply with the standard, leading banks are forging their own path by using ISO 20022 natively in their back office and planning to leverage enriched data fields offered by the standard. This disparity in adoption approaches will create increased risk of interoperability issues and operational disadvantages in the competitive landscape. It also raises concerns that the wider adoption needed to achieve the full benefits of ISO 200221 will not come to fruition.

 

In this article, we worked with J.P. Morgan Chase (JPMC) to delve into the current state of ISO 20022 migration, exploring the challenges and lessons learned on the ISO journey to adoption and recommending how institutions can take actionable steps to start accelerating their strategic adoption journeys and narrowing the competitive divide.

 

Industry observations: challenges in ISO 20022 migration

Many financial institutions have taken a tactical approach focused on minimal compliance, rather than a long-term strategic approach focused on moving toward an ISO 20022 native back office to enable enriched data fields within the migration roadmap. Institutions focusing on minimal compliance have experienced challenges delivering against multiple migration deadlines, struggling to block out enough time for testing and running out of funding after one migration, only to have to request additional budget for upcoming 2024/2025 migration requirements. Quickly approaching deadlines between now and 2025 will only continue to exacerbate resource and time pressures for institutions.

 

Many financial institutions initially assumed that migration would be a quick “technical” exercise, but are now overwhelmed by the complexity and scale of the effort. Smaller institutions relied on their correspondent banking relationships and vendors instead of owning the migration efforts in-house. These institutions are now realizing that there are still significant internal requirements to get ready for the ISO 20022 cutover, including aligning systems downstream of payments applications and training operations and technical teams on the standard. Training is particularly critical, as a lack of education, both internally and with customers, has hindered the understanding of the adoption process and its strategic benefits. Jesús De Lara, ISO Head of Business Readiness & Commercialization for JPMC, notes that “our ISO 20022 Global Program has a workstream dedicated to business readiness and commercialization, which continuously provides materials to all JPMC’s Sales, Operations and Client Service teams, including a detailed list of frequently asked questions. This working group also has numerous resources² available to all clients that holds all ISO 20022-related information, including a recent eBook titled, ISO 20022: First 120 days live³, which provides insights into our lessons learned and aims to help others financial institutions to adopt ISO 20022 standards.”

JPMC invested a lot of effort in defining and maintaining over 5,000 end-to-end test cases, so we could prove our ISO capability based on the roles we can play as a bank

Testing is an additional area where tactical approach has created additional challenges. Institutions have struggled to bucket the appropriate time and resources required to complete user acceptance testing (UAT), system integration testing (SIT) and industry peer testing for ISO 20022. This has proved especially difficult to manage alongside other internal priorities, with many banks challenged with test environment availability. Although costly, there are benefits to investing time and dollars in the testing requirements to move to ISO 20022. Colin Williams, Global Lead of Clearing Transformation at JPMC, shares that “connecting and maintaining an end-to-end test environment that could support our global business and connect to multiple MIs that had different timelines was very challenging. We dealt with this by having a dedicated global team in place who developed monitoring and alerting tools so that we could ensure our test environments were available when needed. JPMC also invested a lot of effort in defining and maintaining over 5,000 end-to-end test cases, so we could prove our ISO capability based on the roles we can play as a bank – one as a direct clearer in multiple markets, and the other in the many roles we cover depending on our position in the correspondent banking value chain.”

The JPMC architectural approach was to deploy ISO 20022 native components wherever possible and manage legacy systems issues by holding a golden copy of the native ISO 20022 message

Lessons learned: transitioning to a strategic ISO 20022 adoption approach

To overcome these challenges and accelerate adoption, financial institutions need to shift from tactical minimal compliance to a strategic approach. The first step is to drive internal alignment on the benefits of structured data, extending the reach beyond operations and product teams to include technology and sales teams. 

Second, a defined plan for going ISO 20022 native should be developed, as delaying full adoption can put an institution at a long-term disadvantage. Many institutions have coupled their plans to migrate to ISO 20022 native applications with strategic goals to modernize and consolidate their back office applications, designing target state architecture that can capitalize on the benefits of structured data across payment rails. In his experience, Colin Williams shares that “we adopted a full ISO 20022 approach from day 1 in March 2023 and were initially responsible for ~68% of ISO 20022 CBPR+ messages, which has now stabilized to ~50%. The JPMC architectural approach was to deploy ISO 20022 native components wherever possible and manage legacy systems issues by holding a golden copy of the native ISO 20022 message that could be referenced as needed by those legacy systems”.

Lastly, banks should start moving now to allocate enough time for the upcoming 2025 deadlines, recognizing that preparation is key to success. It is critical to have a program stood up now, as time will start to move quickly as the deadline approaches. A central team, containing leaders from product, technology, testing, operations, legal, compliance and network management teams that develop defined milestones to hit in the lead-up to 2025, is the best way to ensure your team can avoid scrambling to meet deadlines.

Takeaway – global adoption needs to start today

There is no time to waste in the lead-up to 2025 – the future of payments and the realization of full benefits hinge on the industry’s ability to embrace ISO 20022. Follow our ISO 20022 series with JPMC for detailed advice, insights for unique use cases and how to navigate the journey ahead.

Alexis Sisko, Senior, Financial Services, Ernst & Young LLP contributed to this article.

Summary 

There is no time to waste in the lead-up to 2025 – the future of payments and the realization of full benefits hinge on the industry’s ability to embrace ISO 20022. Follow our ISO 20022 series with JPMC to for detailed advice, insights for unique use cases and how to navigate the journey ahead.

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