Reminder of the importance of participating in T+1 initiatives (surveys and public consultations)

What Changed

• - The EU settlement cycle for in‑scope financial instruments under CSDR will shorten from T+2 to T+1 with effect from 11 October 2027, materially reducing the time to complete front‑to‑back trade, confirmation, and settlement activities.
• CSSF has launched a national competent authorities’ T+1 readiness survey and sets a firm completion deadline of 9 June 2026 for Luxembourg market participants, treating it as a critical supervisory input to assess market preparedness and identify gap
• In parallel, CSSF strongly encourages Luxembourg firms to complete the EU T+1 Industry Committee (EUIC) second readiness survey to support an EU‑wide view of T+1 readiness and potential systemic blockers.
• ESMA’s final draft amendments to the CSDR RTS on Settlement Discipline will introduce additional operational requirements specifically designed to support T+1 (e.g. tightened timelines, additional settlement discipline processes), with application th
• ESMA has launched a consultation on updated guidelines on standardised procedures and messaging protocols for allocations, confirmations and affirmations, explicitly aimed at facilitating the T+1 transition.
• The updated ESMA guidelines will mandate the use of electronic, standardised communication channels and international messaging standards (e.g. ISO‑based messages) for post‑trade communication.

Suggested Considerations

• Identify all group entities and business lines in Luxembourg that are in scope of CSDR T+1 (trading, clearing, settlement, custody, collateral, fund dealing) and formally designate a T+1 programme owner at senior management level.
• Complete the CSSF T+1 national competent authorities’ survey in full and by 9 June 2026, ensuring that responses accurately reflect current readiness, key risks, dependencies on third parties, and planned remediation milestones.
• Arrange for appropriate internal review and sign‑off (e.g. by Compliance and relevant senior management) of the responses to both the CSSF survey and the EUIC second readiness survey before submission.
• Participate in the EU T+1 Industry Committee second readiness survey and ensure the firm’s answers are consistent with the information provided to CSSF and with internal T+1 project documentation.
• Perform a comprehensive T+1 impact assessment of front‑to‑back trade flows, covering trade execution, allocation, confirmation, affirmation, clearing, settlement, collateral movements, cash and liquidity management, and corporate actions.
• Map current post‑trade communication channels and message formats, and plan the migration to fully electronic, standardised messaging protocols in line with ESMA guidelines (e.g. adoption or enhancement of ISO‑standard messaging where applicable).

Key Dates

Who is Affected