Responses to the EU T+1 Industry Committee’s roadmap consultation has revealed industry sentiment and preparedness for the transition to T+1 settlement.

Feedback from market participants, including asset managers, custodians and market infrastructures, showed that many organisations are still in the early stages of their readiness journey, noted the Industry Committee in its latest article, which also highlighted key concerns.

Timeline and implementation concerns

A portion of feedback focused on timeline-related questions, particularly around cut-off times and settlement processes. Several respondents sought clarification on the “adhere or explain” approach, demonstrating the need for clearer guidance on how organisations can adapt the recommendations in the roadmap to their specific operational contexts. This approach was taken to encourage firms to start their own impact assessment with the recommendations as a guide, explains Industry Committee Chair Giovanni Sabatini in a recent interview with PostTrade 360.

Questions emerged about alignment with other regional timelines, particularly regarding APAC market participants and their ability to meet European cut-offs.  

Settlement process clarifications

Some responses revealed misconceptions about settlement alternatives. The Committee’s article affirmed that “missing overnight settlement cycles doesn’t prevent T+1 settlement – trades can still settle through real-time gross settlement during daytime cycles. This flexibility is built into the system design, but requires proper planning and understanding of each organisation’s specific settlement flows.”

Geographic and structural considerations

Feedback highlighted the need for education about European market structures, particularly among non-European participants. “Questions about why EU cut-offs don’t align exactly with UK timelines, for instance, reflect the need to explain the different settlement infrastructures (T2S versus CREST) and their respective operational requirements,” said the Committee’s article.

Misconceptions management

The Committee said it aims to address common misconceptions around the transition. This includes a belief that T+1 is a settlement-only issue and mainly affects custodians. “Each organisation operates with different business models, client bases, technology infrastructures, and operational processes. What works for one institution may not be suitable for another. every organisation must conduct its own comprehensive impact assessment.”

The Committee article indicated there would not be a formal response to the feedback, suggesting that the road map recommendations and ESMA’s CSDR amendments and regulatory technical standards on settlement discipline provide the framework to enable firms’ budgeting, planning and implementation.

What next?

The Committee said it will publish a detailed implementation manual, providing technical guidance for specific operational challenges, and the first of several readiness surveys designed to guide implementation, in January 2026.

The Committee consulted on its roadmap during the summer of 2025.