Rappel de l’importance de participer aux initiatives T+1 (enquêtes et consultations publiques)
Executive Summary
CSSF is pressing Luxembourg market participants to complete T+1 readiness surveys by **9 June 2026** and to engage with ESMA’s broader T+1 consultation work, because the EU settlement cycle moves to **T+1 on 11 October 2027** under CSDR. The publication matters because it signals that supervisors are already assessing industry preparedness and that firms must accelerate post-trade process changes, especially around allocations, confirmations, and electronic messaging. #
What Changed
- - CSSF is requiring market participants to complete the national competent authorities’ T+1 readiness survey by 9 June 2026, with responses visible only to CSSF and ESMA.
- CSSF is strongly encouraging participation in the EU T+1 Industry Committee second readiness survey to support a Union-wide assessment of market preparedness.
- CSSF is flagging that the transition to T+1 settlement on 11 October 2027 under CSDR will require coordinated changes across the trading and post-trading chain.
- CSSF is warning that forthcoming amendments to the RTS on Settlement Discipline are expected to be endorsed by the European Commission and will further define operational requirements for the T+1 transition.
- ESMA’s revised guidelines on standardised procedures and messaging protocols are intended to make post-trade communication faster, clearer, and more consistent across the EU.
- The proposed guideline updates will reflect the move to mandatory electronic, standardised communication channels and international messaging standards.
Suggested Considerations
- Complete the CSSF T+1 readiness survey before 9 June 2026 and ensure the submission accurately reflects the firm’s current operational readiness.
- Participate in the EU T+1 Industry Committee second readiness survey to demonstrate engagement with the EU-wide readiness process.
- Review the firm’s allocation and confirmation workflows to ensure they can operate within T+1 timeframes.
- Replace any reliance on oral, manual, or non-machine-readable communications with electronic, standardised messaging channels unless a temporary technical disruption justifies an exception.
- Align internal messaging standards with international messaging protocols used for post-trade communication.
- Assess whether current settlement, reconciliation, and exception-handling processes can support the 11 October 2027 T+1 deadline.
Key Dates
Compliance Impact
Non-participation in the surveys will not itself appear to be the substantive T+1 breach, but it will materially weaken supervisory visibility and may invite follow-up scrutiny from CSSF and ESMA. Firms that fail to adapt allocations, confirmations, and messaging processes risk being unprepared for the 7 December 2026 guidance phase-in and the 11 October 2027 settlement-cycle change, which could c
Who is Affected
References
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