Speaking at the Banque de France’s Paris headquarters, Verena Ross, chair of ESMA, set out a pointed set of expectations for the industry on settlement discipline and operational efficiency.
Ross was direct about where the burden now sits on EU T+1 readiness. “No one can be ready in isolation,” she told delegates. “Each firm must, of course, assess its own readiness, but that alone is not enough.” Firms, she said, need to check the readiness of their entire ecosystem — clients, brokers, custodians, CSDs, trading venues, CCPs, vendors and outsource providers — because “readiness has to be tested up and down the trading and settlement chain, and one weak link can create pressure throughout that chain.”
She set out three concrete asks. First, firms should respond to ESMA’s consultation on revised guidelines on allocations and confirmations before it closes next week — a short window, but one she said was needed to make sure “the final guidance is clear, workable and align[ed] with the realities of the different business models” firms operate under. Second, firms should move “beyond program mobilisation and into concrete deliveries” — upgrading systems, cleaning up static data and standing settlement instructions, and agreeing procedures with clients and counterparties. Automation, she said, “is not an operational enhancement… it is an absolute precondition.” Third, firms should prepare now for coordinated testing in 2027, building it into implementation planning rather than treating it as “a final check after implementation is complete.”
Regulatory timeline
Ross confirmed that the European Commission’s endorsement of ESMA’s final report on amendments to the CSDR settlement discipline RTS — delivered last October — is now imminent. Once endorsed, the text will proceed through the remaining institutional steps toward publication and entry into force, a milestone she said will signal to the broader market that the new settlement framework “is no longer a distant project” but “implementation reality.”
Alongside that, Ross said ESMA is preparing further guidance of its own on allocations and confirmations, designed to operationalise the CSDR amendments and sit alongside the Industry Committee’s recommendations, giving firms “a clear basis for finalising… electronic, standardised and timely communication processes.” She also flagged that new requirements on allocations and confirmations take effect from 7 December 2026, since delays here “will quickly translate into settlement pressures” the next day.
On monitoring, Ross said ESMA, the European Commission, the ECB, national competent authorities and national central banks are working closely together through fora such as ESMA’s post-trade standing committee, tracking preparedness alongside the Industry Committee’s own readiness surveys — which she said “are not just box ticking exercises” but help authorities see whether smaller firms, cross-border participants, vendors and custodians are moving forward with the rest of the market.
She closed with a sporting analogy of her own: the transition, she said, “is not a solo sprint, but it is a relay” — every participant must be ready to take the baton, run their leg, and pass it on so that Europe crosses the finish line together.
