Following the North American transition, Europe is set to follow suit in October 2027. While previous preparations for the North American transition will provide some firms with a sense of what is required, the European transition will be significantly more complex given the wider scale of venues, depositories, regulators and currencies that will be impacted.
Firms that are successful will be operationally ready in good time, have systems that ensure data accuracy and deliver prompt reconciliations, and automate processes to the extent possible. Typically, the transition is being owned by COOs in firms with significant support and input from individuals responsible for operations, technology, risk, compliance, client money and assets and finance and treasury teams.
The FCA has set out its expectations in several publications (including most recently in its wholesale markets priorities) and will closely supervise implementation. Firms are likely to find industry initiatives useful to identify best practice to meet regulatory expectations, such as that defined by the UK Accelerated Settlement Taskforce (AST) guidance.
Firms will want to focus on the overall strategic approach (tactical fix vs meaningful long-term solution), ensuring data quality and accuracy and weighing up the cost of change vs resilience trade-offs.