ISO 20022 for ‘Exceptions & Investigations’: What banks need to consider

By Steffen Grenzheuser

The transition to ISO 20022 also affects institutions with xBorder services – new deadlines, new formats, new effort.

Back in June 2024, in our article “ISO 20022: Is the end of the MT-MX coexistence period being softened?”, we pointed out an initially inconspicuous but far-reaching adjustment to the SWIFT schedule: For messages in the “Exceptions & Investigations” (E&I) area, the end of MT/MX coexistence has now been postponed to November 2027. Even then, it was clear that this step would be part of a more comprehensive changeover – with consequences for all institutions that process payment complaints. The revised SWIFT roadmap is now available and confirms exactly that.

MT will be replaced by structured case management

The changes are centered on the goal of replacing today’s free-form MT messages with structured ISO 20022 formats. Bilateral communication will be replaced by centralized case management that fully supports interaction via messaging, API, and GUI. The message types affected are ubiquitous in payment transactions:

  • MT192 (e.g., recall) → camt.056
  • MT196 (response) → camt.029
  • MT195 (request, e.g., from compliance) → camt.110
  • Response to MT195 (currently MT196) → camt.111

This means that even if your own institution does not use GPI processes, the processing of callbacks, rejections, or queries in xBorder payments will be placed on a new footing in the medium term – both technically and organizationally.

The new schedule – two mandatory milestones

The transition will take place in several phases. Following recent consultation with the community, SWIFT has adjusted the roadmap. Two points that will become mandatory from 2026 are particularly noteworthy:

From November 2026:

  • New: All payment cancellations (camt.056/camt.029) must be processed via Stop & Recall or Case Management. Both syntax variants (FIN or ISO) are permitted.
  • New: All institutions will be required to receive camt.110 messages with embedded MT199, regardless of previous process models.

From November 2027:

  • Support for inflow translation will end completely.
  • Only ISO 20022 messages may be sent and received via Case Management.
  • The legacy MT messages MT192, MT195, and MT196 will be completely discontinued.

 

What institutions need to know and prepare now

This transformation affects not only institutions with GPI connections, but all banks that process payment complaints. In practice, this means that existing workflows, interfaces, and systems must be reviewed and, if necessary, redesigned. Transition processes are particularly critical here, as inflow translations with embedded MT messages will only be supported for a limited time.

The fact that response messages may only be sent as structured camt.111 messages in the future will also have an impact on automated processing, routing, and monitoring.

Early planning pays off

What is still running in parallel today will become mandatory in a few years. The mandatory deadlines announced now underscore that the changeover is no longer a peripheral ISO issue – it affects operational processes at the heart of payment transactions. Those who plan early can not only reduce complexity, but also leverage synergies with other ISO 20022 projects.

Act now instead of catching up later

The changeover in the E&I area may be overshadowed by payment messages, but it brings with it comparable challenges. Precisely because today’s processes are often cross-departmental and have evolved over time, institutions should start analyzing them early on.

DPS has been supporting banks in their migration to ISO 20022 for years – even beyond traditional payment transactions. Whether you need help with strategy, implementation, or test management, we are happy to assist you in your transition to the new E&I target model.

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