Not Another ISO 20022 Article (But One You Ought to Read)

The contents of this blog are for general information purposes only and do not constitute legal advice. Association of Foreign Banks disclaims liability for actions taken based on the materials. Readers should consult their legal advisers.

Yes, we know. ISO 20022 has been the topic for what feels like half a decade. But this isn’t another generic explainer or history lesson. This is a practical, punchy reminder of what you need to do (and what happens if you don’t), written for the person who has to make it all work.

So, before you get caught by surprise—or worse, with a surprise invoice—here are the top things to know and act on now.

1. Unsubscribe from the Swift In-flow Translator

Yes, really. If you don’t unsubscribe, you’ll be automatically opted in—and billed—starting January 2026.

This isn’t a real-time process either, so make sure to unsubscribe before December 2025. Otherwise, you’re subject to the charges which, apply based on your tier (see table below) and will increase at 3 months’ notice. Swift In-flow Translator can be found here.

Swift’s goal is to disincentivize reliance on the translator—and you’ll feel that disincentive in your budget.

2. ‘Last Resort’ Contingency Measures Are Available

As of November 2025, all payment instructions must be exchanged using ISO 20022. If you’re not ready, Swift will provide contingency measures, but they come at a cost.

Here’s what’s happening:

• Low-volume MTs? Swift will offer an auto-conversion service to MX, but charges will apply.
• Still using In-flow Translation? It will remain optional—for now—but expect higher costs.
• Unsupported MT messages? These will be rejected (NAK’ed).

What’s removed?

• MT102
• MT103 STP
• MT103 REMIT
• MT202
• MT203

You’ll also need to deal with stricter validation, field/identifier restrictions, and limited volumes (up to 15,000 messages/month). And yes, you’ll need to handle ISO 20022 return/rejection messages even under contingency plans.

3. MT Senders: Expect Extra Costs Too

If you’re planning on sending MTs after November 2025 – under contingency measures – that require Swift’s conversion to ISO 20022, there are separate charges:

• A monthly service fee, based on your Global Tier (tied to your Swift invoice).
• A monthly usage fee, based on your Traffic Band (message volume).

Global Tier – Monthly Service Fee

Traffic Band – Monthly Usage Fee

These fees stack—so if you’re a Tier 6 institution sending 6,000 MTs a month, you’ll pay €334 (service) + €1,000 (usage) = €1,334/month.

4. Check Your Conterparty Readiness

Double-check that your counterparties are also ISO 20022-ready.

You can do this via the SwiftRef data portal (for anyone registered under a connected BIC). There, you can:

• Confirm if your counterparty is sending/receiving ISO 20022 messages.
• View supported message types.
• Look up Level 3 DNs or BIC 11 details.

5. Case Manager Timeline Explained

Some good news: the migration deadline for Exceptions and Investigations (Case Manager) has been pushed back to November 2027, from the previously stated 2026.

In the meantime, take advantage of free Swift tools to help you get ready:

• ISO 20022 training resources on key topics and tool registration
• CBPR+ Test Sparring Partner access
• Project Navigator for managing and tracking your ISO 20022 implementation

In Summary

You’re not alone if this feels like a moving target—but don’t sleep on this. The costs for being unprepared aren’t just financial, they’re operational. Act now to:

• Unsubscribe from services you don’t need
• Prerare for increased fees if relying on translation tools
• Ensure counterparties are ready
• Utilise the free tools available

Because in this case, “not another ISO 20022 blog” might be the one that saves you hours – and euros.

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