12th T2S Harmonisation progress report : harmonisation of European securities settlement and collateral management arrangements.
Date: 2022-05-03
Institutions: European Central Bank
Subjects: banking, central bank, cross-border cooperation, euro area, exchange transaction, financial services, money-market liquidity, report, securities

Advisory Group on Market Infrastructures for 
Securities and Collateral 

12th T2S Harmonisation 
Progress Report 

Harmonisation of European 
securities settlement and collateral 
management arrangements 

February 2022 

Disclaimer: This paper should not be reported as representing the views of the European Central Bank (ECB). The 
views expressed are those of the authors and do not necessarily reflect those of the ECB. 

 
Contents 

1 

2 

3 

Key messages 

Introduction 

Current state of progress on securities settlement harmonisation 
in T2S markets 

3.1  Overview of progress on harmonisation activities 

3.2  Monitoring results for each T2S market 

3.3  Migration of the Finnish market to T2S 

4 

Collateral management harmonisation – SCoRE 

Annex 

Annex 1: Core T2S settlement and wider post-trade harmonisation activities 

Annex 2: Detailed monitoring information per T2S market 

Annex 3: Impact assessment of non-compliance 

Annex 4: Methodology 

2 

3 

4 

4 

8 

13 

15 

16 

16 

17 

63 

64 

12th T2S Harmonisation Progress Report – Contents 

1 

 
 
 
1 

Key messages 

This is the twelfth progress report on the harmonisation of European securities 
settlement and collateral management arrangements published by the 
Eurosystem’s Advisory Group on Market Infrastructures for Securities and 
Collateral (AMI-SeCo). In pursuit of the objective of further integrating European 
financial markets and in line with its mandate, AMI-SeCo has advanced harmonisation 
in the areas of securities settlement and collateral management. This report covers 
AMI-SeCo’s TARGET2-Securities (T2S) harmonisation agenda (covering the T2S 
markets) and also gives an update on AMI-SeCo’s recent progress in the area of 
collateral management harmonisation. 

As regards the T2S harmonisation agenda, T2S markets have achieved a slight 
further increase in their level of compliance with the T2S harmonisation 
standards. Overall, T2S markets have reached a compliance level of 91.6% 
(measured as the number of cases of full compliance compared with the overall 
number of assessments), which is a slight improvement on the already high level of 
89.0% observed in the previous harmonisation progress report. Five T2S markets 
have achieved full compliance with various T2S harmonisation standards in the review 
period. T2S markets have also made a number of incremental improvements since the 
previous harmonisation report which were not, however, reflected in a change of 
status because they did not result in full compliance. 

The most difficult harmonisation area remains corporate actions, where a 
significant number of T2S markets have yet to reach full compliance with the 
T2S corporate actions standards and with the corporate actions market 
standards. Nevertheless, progress has continued in this area, with three markets 
achieving full compliance, while a number of others have increased the number of 
corporate actions standards that they are compliant with. Overall, in many of the 
non-compliant markets the level of compliance with the corporate actions standards is 
high, but still falls slightly short of full compliance. 

In the area of collateral management harmonisation, AMI-SeCo continued 
monitoring progress by stakeholders against the three sets of collateral 
management standards (namely triparty collateral management, billing 
processes and corporate action handling for debt securities). Most markets 
updated their plans for adapting to these standards in the first half of 2021. The results 
of the monitoring of progress on implementation confirm the strong commitment and 
willingness shown by all relevant stakeholders to implement the standards in line with 
the agreed roadmap. 

12th T2S Harmonisation Progress Report – Key messages 

2 

2 

Introduction 

The Advisory Group on Market Infrastructures for Securities and Collateral 
(AMI-SeCo) considers the harmonisation of post-trade processes, including collateral 
management, to be a critical objective to be met in the pursuit of financial market 
integration in Europe. 

In the area of securities settlement harmonisation, TARGET2-Securities (T2S) has 
contributed significantly to the integration of financial markets in Europe by 
harmonising post-trade processes across all T2S participating markets. The extent to 
which the potential benefits of T2S will materialise depends largely on all relevant 
stakeholders adapting to and using T2S in a harmonised manner. 

In the area of collateral management, AMI-SeCo is also making significant progress. 
The standards it has endorsed – covering business processes, workflows and 
messaging for triparty collateral management, corporate actions handling and billing 
processes – are being implemented by European markets. 

In this twelfth harmonisation progress report from AMI-SeCo, progress is presented on 
the basis of an established methodology1  and compared with the situation at the time 
of the previous report (the Eleventh T2S Harmonisation Progress Report) which was 
published in January 2021. The purpose of this report is to give an overview of the 
activities of AMI-SeCo in two broad areas: first, compliance and harmonisation 
activities related to the T2S harmonisation agenda, focusing on securities settlement,2 
and, second, AMI-SeCo’s harmonisation work on collateral management3. Given that 
the work on securities settlement and the work on collateral management have 
different scopes and are at different stages of harmonisation, progress in these areas 
is presented in separate sections: Section 3 focuses on T2S harmonisation and 
Section 4 focuses on collateral management harmonisation. Annex 1 presents the 
securities settlement harmonisation activities in detail, Annex 2 provides an overview 
of individual T2S markets, Annex 3 contains an impact assessment of cases of 
non-compliance with core T2S settlement harmonisation standards, and Annex 4 
presents the methodology for monitoring compliance with the securities settlement 
standards. 

1    For further details, see the methodology for progress assessment on AMI-SeCo securities settlement 

harmonisation activities. 

2    For further details, see the description of AMI-SeCo’s core T2S settlement and wider post-trade 

harmonisation activities. 

3    For further details, see the AMI-SeCo report on Collateral Management Harmonisation. 

12th T2S Harmonisation Progress Report – Introduction 

3 

3 

Current state of progress on securities 
settlement harmonisation in T2S 
markets 

This report is an update on the eleventh T2S harmonisation progress report published 
by AMI-SeCo in January 2021. This section focuses on the progress made in the 
period between September 2020 and September 2021 

3.1 

Overview of progress on harmonisation activities 

Table 1 gives an overview of the current status of T2S harmonisation activities and 
shows their status with regard to (i) whether a standard or rule has been defined, 
(ii) whether a monitoring process has been launched, and (iii) the aggregate
compliance status of all T2S markets, as observed in September 2021.

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

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Table 1 
Status dashboard of T2S harmonisation activities 

(as at September 2021) 

Core T2S settlement harmonisation 

Definition 

Monitoring 
process 

Compliance 
(number of non-compliant 
markets) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

T2S messages 

T2S ISO 20022 messages 

T2S matching fields 

Interaction for registration 

Interaction for tax information 

Schedule of settlement day 

T2S corporate actions standards 

Legal harmonisation 

Settlement finality I (moment of entry) 

Settlement finality II (irrevocability of 
transfer order) 

Settlement finality III (irrevocability of 
transfer) 

Outsourcing of IT services 

Settlement discipline regime 

Settlement cycles 

13  CDS account structures 

Availability of omnibus accounts 

14 

Restrictions on omnibus accounts 

15  T2S account numbering 

Securities accounts numbering 

16 

Dedicated cash accounts numbering 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

G 

X 

G 

G 

G 

G 

G 

B 

R (1) 

B 

B 

R (1) 

R (6) 

B 

B 

B 

B 

X 

B 

B 

R (1) 

B 

B 

Harmonisation of post-trade environment of securities 
settlement 

Definition 

Monitoring 
process 

Compliance 

17 

Legal harmonisation 

Location of securities account/conflict of 
laws 

18 

19 

20 

21 

22 

23 

24 

Corporate actions 
market standards 

CA market (CAJWG) standards 

Place of issuance 

Tax procedures 

Withholding tax procedures 

Shareholder transparency/registration 

Market access 

Securities amount data 

Portfolio transfer 

G 

G 

G 

Y 

R 

G 

G 

Y 

X 

G 

X 

X 

X 

X 

G 

X 

X 

R (17) 

X 

X 

X 

X 

R (1) 

X 

Definition process. Overall, 21 out of the 24 core T2S settlement harmonisation 
activities and wider post-trade harmonisation activities have reached green status in 
the definition process, as the relevant stakeholder bodies (inside or outside the T2S 
community) have defined and agreed or endorsed standards for these activities. As 
noted in previous harmonisation progress reports, progress in the implementation of 
the Central Securities Depositories Regulation (CSDR)4  at the European and national 
levels contributed to the completion of the definition process for most T2S 

4    Regulation (EU) No 909/2014 of the European Parliament and of the Council of 23 July 2014 on 
improving securities settlement in the European Union and on central securities depositories and 
amending Directives 98/26/EC and 2014/65/EU and Regulation (EU) No 236/2012 (OJ L 257, 28.8.2014, 
p. 1). 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

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harmonisation activities where this was still to be done (settlement discipline, market 
access and place of issuance). All activities in the T2S settlement harmonisation 
group have been defined while, in the wider post-trade group, the three activities listed 
below still lack a defined set of standards and rules:5 

•

•

•

On withholding tax procedures, the status remains yellow. AMI-SeCo has
closely monitored developments related to the implementation of the European
Commission’s Code of Conduct on Withholding Tax (which sets out high-level
requirements and recommendations for national tax authorities) and has also
provided its concrete recommendations for future work in the context of the
discussions on the new action plan on the capital markets union. AMI-SeCo
stands ready to assist the European Commission in its impact assessment and to
contribute to any further follow-up work on the European Commission’s
announced initiative to introduce an EU-wide system for withholding tax relief at
source.

On shareholder transparency and registration, the status remains red.
AMI-SeCo maintains the view that divergent registration requirements across
T2S markets remain a barrier to further harmonisation and to cross-border
post-trade services in general. AMI-SeCo welcomes the improvements resulting
from the amended Shareholder Rights Directive (SRD II)6, which was
implemented across EU markets by September 2020, but expects them to be
limited, in particular in the area of debt instruments, and does not expect them to
result in the harmonisation of registration practices across the EU.

On portfolio transfers, the status remains yellow, despite the ongoing work by
AMI-SeCo on portfolio transfers in T2S aimed at establishing a pan-European
handbook containing current local practices and setting out high-level principles
for cross-border portfolio transfers. Full harmonisation based on a single,
detailed set of procedures for portfolio transfers across T2S markets remains the
long-term goal.

Monitoring process. The number of monitored markets remained stable in the review 
period at 20 markets, while the number of central securities depositories (CSDs) using 
T2S decreased to 21, as two T2S CSDs (SK – NCDCP and FR – ID2S) ceased 
operations. In line with the AMI-SeCo monitoring framework, there are 
well-established and agreed monitoring activities, deadlines and responsible actors 
for further action in each market. The number of harmonisation activities that are 
currently being monitored remained stable at 17 (15 core T2S settlement 
harmonisation standards and two standards related to the wider post-trade 
environment of securities settlement). 

Compliance status. For assessing the overall compliance of T2S markets with the 
standards, only the blue (i.e. fully compliant) and red (i.e. not fully compliant) statuses 

5    Core T2S settlement harmonisation activities are necessary to ensure efficient and safe cross-CSD 

settlement in T2S. The T2S community should view the resolution and implementation of these activities 
as the top priority before the migration of markets to T2S. 

6    For more details see Directive (EU) No 2017/828 amending the original SRD and Implementing 
Regulation (EU) No 2018/1212 laying down minimum requirements for implementing the SRD. 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

6 

are used. At the aggregate level, a standard is deemed to be complied with if all T2S 
markets comply with it. An individual T2S market is deemed to be compliant with a 
standard if all of its relevant actors comply with the standard. 

Core T2S settlement harmonisation 

Out of the 15 core T2S settlement harmonisation standards that are monitored, all 
T2S markets are compliant with ten standards. For the remaining five standards in this 
category, the aggregate level of T2S market compliance is assessed as red, since 
implementation gaps remain in at least one T2S market for each standard. Except for 
Standard 6, no more than one T2S market remains non-compliant for each of these 
five standards. Compared with the previous harmonisation progress report there has 
been slight progress on the core T2S settlement harmonisation standards, with two 
markets (Euroclear France and Euroclear Netherlands) achieving full compliance with 
Standard 6 on T2S corporate actions. In addition, the absolute number of 
non-compliance cases has fallen, owing to the fact that SK – NCDCP (previously 
assessed as non-compliant with two of the standards) and FR – ID2S (previously 
assessed as non-compliant with three of the standards) both ceased operations and 
hence are not monitored any longer. One market (Italy) became compliant with 
Standard 4 owing to a change to the standard that was agreed by AMI-SeCo in 
December 2021. The remaining cases of non-compliance with core T2S settlement 
harmonisation standards are the following: 

•  On Standard 2 – T2S matching fields – one T2S market (Spain) is assessed as 
non-compliant. AMI-SeCo notes that the compliance gap is very small and only 
materialises in specific scenarios.7 

•  On Standard 5 – T2S calendar and schedule of the settlement day – one T2S 

market (Hungary) is still assessed as non-compliant, owing to not fully following 
the T2S schedule of the settlement day. 

•  On Standard 6 – T2S corporate actions standards – two T2S markets (Euroclear 

France and Euroclear Netherlands, as noted above) have achieved full 
compliance since the previous report, but the overall number of non-compliance 
cases remains significant, with six T2S markets still not fully complying. 

•  On Standard 14 – restrictions on omnibus accounts – one market (France) is 
assessed as non-compliant. Euroclear France does not comply with the legal 
requirement under Standard 14 to separate registered securities from bearer 
securities under the same international securities identification number (ISIN) at 
CSD level. 

7    The compliance gap stems from the fact that, for intra-CSD settlements of equities, there is a market 

practice in place in the Spanish market by which the T2S optional matching field “Client of the CSD 
participant” is filled in with the details of the end-investor which is not always the client of the CSD 
participant. Therefore, when both parties to the transaction fill in the optional matching field, the use of 
this field may not be fully in line with T2S matching rules. 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

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Harmonisation of the post-trade environment of securities 
settlement 

Since the publication of the previous report one market (Switzerland) has achieved 
compliance with T2S Standard 18 (comprising market standards for corporate actions 
processing drawn up by the Corporate Action Joint Working Group – CAJWG). This 
brings the number of markets that are compliant with T2S Standard 18 to five, but still 
leaves seventeen other markets that are non-compliant. Nevertheless, some of these 
other markets have also made progress at the level of individual (sub-)components of 
the CAJWG standards since the previous report, as detailed further in the Corporate 
Events Group report. 8 

Overall assessment 

Further progress has been made on compliance with monitored T2S harmonisation 
standards, primarily because some markets have achieved compliance with the T2S 
corporate actions standards and with the market standards for corporate actions. 
Nevertheless, the key areas where there is still pronounced non-compliance continue 
to be Standard 6 on T2S corporate actions and Standard 18 on market standards for 
corporate actions where a number of non-compliant markets have announced further 
implementation delays and others have not developed any concrete plans. The 
statistical impact on the overall – already high – level of compliance by T2S markets 
has further been influenced by to two CSDs ceasing operations and leaving T2S in the 
review period (FR – ID2S and SK – NCDCP, both of which did not comply with a few of 
the standards). 

AMI-SeCo continues to pay particular attention to the remaining non-compliance 
cases and to the plans to resolve them in accordance with the established framework 
as agreed by the T2S community.9  In a few cases, achieving full compliance depends 
on further action involving public authorities or even on changing long-standing 
national legal requirements, which is outside the control of the T2S community. In 
many of these cases there are no concrete plans in place to secure the compliance of 
the affected T2S markets, but discussions are ongoing with the relevant authorities 
(tax authorities, finance ministries and national legislatures) on removing the related 
barriers. AMI-SeCo expects all T2S markets to work towards securing full compliance, 
including developing plans and implementing them, regardless of whether the plans 
may be dependent on third parties. 

3.2 

Monitoring results for each T2S market 

Table 2 provides detailed harmonisation compliance results for each T2S market. 
Further details can be found in Annex 2. 

8    For more details see Corporate Events Compliance Report 2021. 
9    See Annex 3 on the assessment of the impact of existing non-compliance cases. 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

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Table 2 
Compliance status for each T2S market 

(as at September 2021) 

Priority 1   
standards 

Priority 2   
standards 

T2S markets 

1 

AT 

B 

2 

B 

3 

4 

B 

B 

5 

B 

6 

7 

8 

9 

10 

12 

13 

14 

15 

16 

18 

23 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

BE – 
Euroclear 

BE – NBB 
SSS 

CH 

DE 

DK 

EE 

ES 

FR – 
Euroclear 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-Q4 
2023 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

N/A 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-Q4 
2021 

R-Q4 
2023 

R- 
2023 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

R-?  R-? 

GR – BOGS 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

HU 

IT 

LT 

N/A 

B 

B 

B 

R-Dec 
2021 

R-Q4 
2023 

B 

B 

B 

B 

B 

B 

B 

B 

N/A 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-Q4 
2024 

R-Q4 
2025 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

LU – LUX 
CSD 

B 

B 

B 

B 

B 

R-Q4 
2023 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-Q4 
2023 

B 

LV 

MT 

NL 

PT 

RO 

SI 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-Q4 
2023 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

SK – CDCP 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

R-? 

B 

Note: The three statuses marked “N/A” (not applicable) concern two instances where the local national central bank does not provide 
liquidity (standard for cash accounts) and one instance of non-applicability of ISO messages (no application-to-application connectivity to 
T2S). 
Priority 1: Core T2S settlement harmonisation. 
1. T2S messages - ISO 20022. 
2. T2S matching fields. 
3. Interaction with T2S (registration). 
4. Interaction with T2S (tax procedures). 
5. Schedule for the settlement day. 
6. T2S CA standards. 
7. T2S settlement finality I. 
8. T2S settlement finality II. 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

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9. T2S settlement finality III. 
10. Outsourcing IT (settlement) services. 
12. Settlement cycle. 
13. Availability of omnibus accounts. 
14. Restrictions on omnibus accounts. 
15. Securities account numbering. 
16. Cash account numbering. 
Priority 2: Harmonisation of post-trade environment of securities settlement. 
18. CA market standards (CAJWG). 
23. Securities amount data. 

Table 2 shows the current compliance statuses for 20 T2S markets. However, where 
more than one CSD exists in a particular T2S market, each CSD “market segment” is 
monitored separately. For example, in the case of Belgium, NBB-SSS and Euroclear 
Belgium are treated as two different “market segments” (or two segments of a single 
national market). AMI-SeCo focuses its analysis on T2S markets rather than on 
specific T2S actors (CSDs, etc.), since there is a common understanding that 
harmonisation compliance is a coordinated effort across the entire national market. 
This usually involves national market infrastructures, their clients and, where relevant, 
national public authorities (for example, for issues related to tax and corporate 
actions). 

With regard to its methodology for assessing compliance, AMI-SeCo assesses the 
status of all migrated T2S markets as either blue (full compliance has been achieved) 
or red (full compliance has not yet been achieved). More details on the colour scheme 
methodology used by AMI-SeCo can be found in Annex 4. 

Table 3 provides a statistical summary of developments in compliance cases: 

• 

• 

91.6% of the statuses are blue, which is a slight improvement compared 
with the eleventh harmonisation progress report (89.0%). This increase is 
due to the resolution of five non-compliance cases during the review period 
(related to standards 2, 4, 6 and 18) and the statistical impact of two CSDs 
leaving T2S. 

The share of red (non-compliance) statuses decreased from 10.0% to 7.6%. 
This is the mirror effect of the above-mentioned changes in blue statuses, i.e. five 
non-compliance cases were resolved and two CSDs with existing 
non-compliance cases left T2S. 

Table 3 
Summary of compliance statistics for T2S markets 

(as at September 2021) 

Eleventh HPR (September 2020) 

Twelfth HPR (September 2021) 

Priority 1 

Priority 2 

% of total 

Priority 1 

Priority 2 

% of total 

Blue 

Red 

N/A 

Total 

323 

18 

4 

345 

25 

21 

0 

46 

89.0% 

10.0% 

1.0% 

100% (391) 

303 

9 

3 

315 

24 

18 

0 

42 

91.6% 

7.6% 

0.8% 

100% (357) 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

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Table 4 shows changes in compliance assessments, broken down by T2S market and 
by harmonisation standard, compared with the previous harmonisation progress 
report. 

In terms of the impact of non-compliance, there has been some progress among the 
remaining non-compliance cases observed in several markets, leading to a lower 
overall impact on the T2S community.10 

10    For full details on the assessed impact of non-compliance with the core T2S settlement standards for 

each market, see Annex 3. 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

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Table 4 
Changes in compliance statuses compared with the eleventh harmonisation progress 
report 

(as at September 2021) 

Priority 1   
standards 

Priority 2   
standards 

T2S markets 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10  12  13  14  15 

18 

23 

R- 
2025 

R-Q4 
2023 

R 

B 

R-? 

R-? 

R-Q4 
2023 

R- 
2023 

R-Q4 
2021 

R-? 

R-? 

R-Q4 
2025 

R-? 

R-Q4 
2023 

R-Q4 
2021 

R-Q4 
2023 

R-Q1 
2021 

R-? 

R 

B 

R-Dec 
2021 

B 

R-Nov 
2022 

R-Nov 
2023 

R 

B 

R 

B 

AT 

BE – 
Euroclear 

BE – NBB 
SSS 

CH 

DE 

DK 

EE 

ES 

FR – 
Euroclear 

GR – BOGS 

HU 

IT 

LT 

LU – LUX CSD 

LV 

MT 

NL 

PT 

RO 

SI 

SK – CDCP 

Priority 1: Core T2S settlement harmonisation. 
1. T2S messages - ISO 20022. 
2. T2S matching fields. 
3. Interaction with T2S (registration). 
4. Interaction with T2S (tax procedures). 
5. Schedule for the settlement day. 
6. T2S CA standards. 
7. T2S settlement finality I. 
8. T2S settlement finality II. 
9. T2S settlement finality III. 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
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12 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
10. Outsourcing IT (settlement) services. 
12. Settlement cycle. 
13. Availability of omnibus accounts. 
14. Restrictions on omnibus accounts. 
15. Securities account numbering. 
16. Cash account numbering. 
Priority 2: Harmonisation of post-trade environment of securities settlement. 
18. CA market standards (CAJWG). 
23. Securities amount data. 

Table 5 
Compliance statuses of markets that have not yet migrated to T2S 

(as at September 2021) 

T2S markets 

FI 

1 

B 

2 

B 

3 

B 

4 

B 

5 

6 

7 

G  Y-2024  B 

8 

B 

9 

B 

10 

12 

13 

14 

15 

16 

18 

23 

B 

B 

B 

Y 

B 

G 

R-? 

B 

Priority 1   
standards 

Priority 2   
standards 

Priority 1: Core T2S settlement harmonisation. 
1. T2S messages - ISO 20022. 
2. T2S matching fields. 
3. Interaction with T2S (registration). 
4. Interaction with T2S (tax procedures). 
5. Schedule for the settlement day. 
6. T2S CA standards. 
7. T2S settlement finality I. 
8. T2S settlement finality II. 
9. T2S settlement finality III. 
10. Outsourcing IT (settlement) services. 
12. Settlement cycle. 
13. Availability of omnibus accounts. 
14. Restrictions on omnibus accounts. 
15. Securities account numbering. 
16. Cash account numbering. 
Priority 2: Harmonisation of post-trade environment of securities settlement. 
18. CA market standards (CAJWG). 
23. Securities amount data. 

3.3 

Migration of the Finnish market to T2S 

In 2020, by officially confirming its target date for joining T2S, Euroclear Finland 
commenced the process for the migration of the Finnish market to T2S. As confirmed 
by the Market Infrastructure Board in 2021, Euroclear Finland will migrate to T2S in 
September 2023. 

Euroclear Finland operates a “direct holding market” (with each end-investor having a 
separate account), so it has a significantly larger number of securities accounts to be 
maintained in T2S than is the case for markets using an indirect holding model (in 
which typically CSD participants have omnibus accounts containing the securities of 
several end-investors). The potential impact and technical adjustments needed to 
ensure a smooth migration are currently being analysed by Euroclear Finland and the 
Eurosystem. 

As part of the migration process, the Finnish market is also reporting its compliance 
status, as shown in Table 5. While full compliance (blue) has already been achieved 
for many of the standards, there are some that still require additional efforts. The buyer 
protection and transformation standards, which are part of the T2S corporate actions 
standards (Standard 6), are intended to be implemented when Euroclear Finland joins 
T2S, whereas full compliance with the market claims standards (which are part of the 
corporate actions market standards – Standard 18) will require major technical and 
process changes that are unlikely to be in place by the migration date. For 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

13 

 
 
Standard 14 on restrictions on omnibus accounts, there is national legislation in 
Finland that obliges account service providers to maintain securities holdings of 
Finnish investors in segregated accounts. Unless such national legal requirements 
change, the Finnish market will probably not be able to secure full compliance with 
Standard 14. Nevertheless, from the perspective of the objectives and spirit of 
Standard 14, for foreign custodians serving non-Finnish customers with holdings of 
securities issued in Euroclear Finland and for foreign investor CSDs that have a link to 
Euroclear Finland, the issue is mitigated by the fact that in these cases the use of 
omnibus accounts (and nominee registration) is allowed. 

12th T2S Harmonisation Progress Report – Current state of progress on securities settlement 
harmonisation in T2S markets 

14 

 
 
4 

Collateral management harmonisation – 
SCoRE 

Collateral management harmonisation is critical to the integration of European 
financial markets. Market participants in AMI-SeCo agreed to establish a Single 
Collateral Management Rulebook for Europe (SCoRE), which identifies ten collateral 
management harmonisation activities11  where further harmonisation is needed. A 
series of milestones and timelines have been defined, against which progress will be 
measured in order to ensure transparency regarding the status of compliance of all 
relevant actors with the AMI-SeCo SCoRE standards. 

In 2019 AMI-SeCo endorsed the first set of SCoRE standards relating to three of 
the ten activities, namely triparty collateral management, corporate actions 
handling and billing processes. Endorsement of the standards is the first step in the 
AMI-SeCo monitoring process. On corporate actions, AMI-SeCo continued refining 
and updating the standards based on additional input from market stakeholders during 
2021. The results of the monitoring of progress on implementation for the first half of 
2021 were published in June 2021 by AMI-SeCo. Most stakeholders reported being on 
schedule with the implementation of the SCoRE triparty collateral management, billing 
processes and corporate actions standards. The results confirm the strong 
commitment and willingness shown by all relevant stakeholders to implementing the 
standards in line with the agreed roadmap. 

The objective is to have a first set of harmonised rules and processes for 
collateral management implemented across Europe by November 2023. 
Stakeholders will then be able to use a common set of business processes and data, 
with interactions between relevant actors being based on the latest international 
messaging standards (thereby enabling the frictionless movement of cash, securities 
and collateral). 

11    These ten activities comprise triparty collateral management, corporate actions, taxation processes, 
bilateral collateral management, margin calls, billing processes, cut-off times, collateral dynamic and 
static data, sourcing of collateral and non-euro collateral. 

12th T2S Harmonisation Progress Report – Collateral management harmonisation – SCoRE 

15 

 
 
 
Annex 

Annex 1: Core T2S settlement and wider post-trade 
harmonisation activities 

See Description of AMI-SeCo core T2S settlement and wider post-trade 
harmonisation activities published on the ECB’s website. 

12th T2S Harmonisation Progress Report – Annex 

16 

Annex 2: Detailed monitoring information per T2S market 

T2S harmonisation activities: Austria 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

1. T2S ISO 
20022 
messages 

Fully 
compliant 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

Priority 1 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

B 

B 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

89% 

100% 

R-? 

Major 
technical 
changes/ 
Market 
practice 
changes 

Not 
available 

Not 
available 

CANIG and 
T2S NUG 
(CSD/ CCP, 
banks and 
Issuers) 

100% 

Fully 
Compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Further comments 

No barriers identified for 
achieving full compliance 
before migration to T2S. 

No barriers identified for 
achieving full compliance 
before migration to T2S. 

Info source: HSG survey May 
2013. Registration information 
is not transferred via 
settlement messages 

Info source: HSG survey May 
2013. Registration information 
is not transferred via 
settlement messages 

Info source: Compliance 
monitoring update May 2019. In 
line with the T2S community 
needs, the AMI-SeCo supported 
the adaptation of the T2S 
calendar as of 2019 based on 
the principle that T2S should be 
open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second T2S 
settlement currency in October 
2018 this will mean that T2S will 
be closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

Info source: September 2021 
CEG monitoring. The AT 
market does not comply with 
MC standards 6 and 7 (related 
to treatment of ex/cum and 
opt-out indicators) as well as 
MC standard 23 as no user 
friendly facility is provided to 
control the interdependence 
of the settlement of the market 
claim with the underlying 
transaction. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. Only 
bilateral cancellations are 
possible after matching 
status. 

12th T2S Harmonisation Progress Report – Annex 

17 

 
 
 
B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

B 

N/A 

N/A 

N/A 

N/A 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

Further comments 

Info source: SP2 and bilateral 
input. Market already 
complies with the standard. 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: 2013 HSG survey 
and bilateral input. Fully 
compliant with omnibus 
accounts availability. 

Info source: 2013 HSG survey 
and bilateral input. No 
restrictions on omnibus 
accounts. 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013 
and Q3 2013 CSD status 
gathering template. 

Info source: HSG survey on 
T2S DCA numbering, April- 
May 201. Bilareral exchanges 
with NUG. 

Info source: CEG Survey 
(2021). The statistics are 
based on the 123 CAJWG 
prioritised standards. 

Info source: T2S NUG survey 
and bilateral input. Full 
compliance with European 
market practice. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

90% 

R-? 

Straight-forwa
rd to 
implement 

N/A 

Project set 
up for 2018 

Austrian 
Corporate 
Actions 
National 
Implement- 
ation Group 
(CANIG) 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

18 

 
 
 
 
T2S harmonisation activities: Belgium (Euroclear) 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

1. T2S ISO 
20022 
messages 

Fully 
compliant 

2. T2S 
matching 
fields 

Fully 
compliant 

3. 
Interaction 
for 
registration 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

Priority 1 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

100% 

N/A 

100% 

R-? 

N/A 

Q4 2017 

Q1 2021 

Euroclear 

94% 

N/A 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

Info source: SP2, White Paper 
and bilateral input. Matching 
rules that will apply are those 
of the T2S platform. Full 
compliance for testing. 

Info source: May 2013 HSG 
survey. Registration 
information is not transferred 
via settlement messages. 

Info source: May 2013 HSG 
survey. Tax information is not 
transferred via settlement 
messages. 

Info source: Compliance 
monitoring update May 2019. 
In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S 
calendar as of 2019 based on 
the principle that T2S should 
be open when any of the T2S 
settlement currency RTGS 
are open. As the Danish 
Kroner will join the euro as the 
second T2S settlement 
currency in October 2018 this 
will mean that T2S will be 
closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

Info source: September 2021 
CEG report. Euroclear 
Belgium achieved full 
compliance with the market 
claims and transformation 
standards after migrating 
mandatory events to its new 
CA platform on 15 March 
2021. However, the CEG 
agreed to downgrade the 
compliance status for four 
standards (Mandatory 
Reorganisations with Options 
Standards 12, 13 and 14 and 
Buyer Protection Standard 9) 
on the basis that capital 
increase events (which occur 
once or twice a per year) are 
not processed in accordance 
with the standards. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

12th T2S Harmonisation Progress Report – Annex 

19 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Further comments 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. EoC (BE) 
already complies with only 
bilateral cancellation after 
matching status. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. Terms and 
conditions will be updated to 
implement SFIII in T2S. This 
update will have to be 
presented and approved, 
where applicable, by the 
Belgian regulator (Nationale 
Bank van België/Banque 
Nationale de Belgique). No 
barriers identified in this 
process. 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. There are 
no issues with omnibus 
accounts availability for the 
ESES countries. 

Info source: T2S NUG survey 
and bilateral input. No 
restrictions on usage of 
omnibus accounts. 

Info source: HSG survey on 
T2S securities account 
numbering, May 2013. No 
barriers identified. 

Info source: HSG survey on 
T2S DCA numbering, 
April-May 2013 and bilateral 
input from BE NUG. No 
barriers identified. 

Info source: CEG survey 
(Sept 2021). The statistics are 
based on the 126 CAJWG 
prioritised standards. Final 
implementation was expected 
with the Euroclear launch of 
Stream 6 in February 2018. 
Although ESES CSE6 
functionalities were fully 
delivered, a change to the 
Belgian Code of Companies & 
Associations was required for 
events with quoted rights 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

98% 

R-? 

N/A 

N/A 

N/A 

N/A 

12th T2S Harmonisation Progress Report – Annex 

20 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

(mostly capital increase 
events). Full technical 
compliance was achieved in 
January 2020 with a change 
to the Belgian Code of 
Companies & Associations. 
The CEG assessed the 
market as non compliant since 
in 2020 two capital increases 
announced by 2 entities as 
NOSE (no service). 

Info source: T2S NUG survey 
and bilateral input. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

21 

 
 
 
T2S harmonisation activities: Belgium (NBB-SSS) 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

B 

N/A 

N/A 

N/A 

N/A 

Info source: BE NUG input. 

1. T2S ISO 
20022 
messages 

Fully 
compliant 

2. T2S 
matching 
fields 

Fully 
compliant 

3. 
Interaction 
for 
registration 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: NUG confirmation 
that the market is now fully 
operational according to the 
T2S standards following 
implementation of the new 
technical platform. 

Info source: T2S NUG 
surveys 2013. Registration 
process is paper-based. No 
need to include registration 
info in settlement messages. 

Info source: T2S NUG surveys 
2013. No additional information 
is requested in settlement 
messages for tax processing. 

Info source: Compliance 
monitoring update May 2019. In 
line with the T2S community 
needs, the AMI-SeCo 
supported the adaptation of the 
T2S calendar as of 2019 based 
on the principle that T2S should 
be open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second T2S 
settlement currency in October 
2018 this will mean that T2S will 
be closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

Info source: September 2021 
CEG survey. NBB-SSS 
complies fully with the T2S CA 
standards relevant for the 
securities it serves. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: NUG 
confirmation. 

12th T2S Harmonisation Progress Report – Annex 

22 

 
 
 
Activity 

Sub- 
activity 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: NUG confirmation 
that the market is now fully 
operational according to the 
T2S standards following the 
implementation of the new 
technical platform in February 
2015. 

Info source: 2014 HSG survey 
on IT outsourcing. No 
regulatory barrier for 
outsourcing of settlement 
services by the CSD to the 
Eurosystem. 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. NBB-SSS 
offers omnibus accounts. 

Fully 
compliant 

B 

Market 
practice 
change 

N/A 

N/A 

NBB-SSS 

Info source: NBB-SSS. 
Compliant since June 2017. 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

93% 

R-Q4 
2023 

N/A 

N/A 

N/A 

N/A 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: NUG confirmation 
that the market is now fully 
operational according to the 
T2S standards following the 
implementation of the new 
technical platform in February 
2015. 

Info source: HSG survey on 
T2S DCA numbering, 
April-May 2013. 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 113 CAJWG 
prioritised standards. 

Info source: T2S NUG survey 
and bilateral input. NBB-SSS 
is in line with European 
market practice. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

23 

 
 
 
 
T2S harmonisation activities: Switzerland 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

B 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

In terms of the T2S calendar 
day the Swiss CSD is 
compliant with ECB/T2S 
requirements. 

Info source: Sep 2021 CEG 
report. Transformation 
Standard No. 2: Swiss Market 
Practice is currently different 
to the T2S Standard. The 
Transformation is only once 
on record date EOD. Change 
of practice is considered to be 
a major technical change in 
the SIX Settlement System 
“SECOM” with a 
disproportionality in terms of 
costs versus current number 
of affected transactions. Due 
to a different market practice 
the Swiss market is not 
compliant with 
"Transformation Standard 
No 2". 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

92% 

R-? 

N/A 

N/A 

N/A 

N/A 

100% 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

4. 
Interaction 
for tax info 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Market 
claims (28 
standards) 

100% 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

12th T2S Harmonisation Progress Report – Annex 

24 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

N/A 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
Swiss NSG. 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

100% 

B 

N/A 

N/A 

N/A 

N/A 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG (Sep 2021). 
The statistics are based on 
the standards for CA 
Processing (CAJWG). Fully 
implemented, except for 
Swiss (national) Tender Offers 
(Voluntary Reorg Standards 
No. 13 and No. 14): According 
to the CH regulation the 
Guaranteed Participation 
Date and Market Deadline are 
on the same day which is 
assumed to be for the benefit 
of shareholders/offerers. 
Reason for change of 
compliance percentage: Only 
local market participants 
impacted. 

Info source: Confirmation from 
Swiss NSG. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

25 

 
 
 
 
T2S harmonisation activities: Germany 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

B 

B 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for transmission 
of registration information. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for transmission 
of tax information. 

Info source: Compliance 
monitoring update May 2019. 
In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S 
calendar as of 2019 based on 
the principle that T2S should 
be open when any of the T2S 
settlement currency RTGS 
are open. As the Danish 
Kroner will join the euro as the 
second T2S settlement 
currency in October 2018 this 
will mean that T2S will be 
closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

See notes below for more 
information. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

75% 

Market 
practice 
change 

100% 

N/A 

R-? 

Testing 
readiness 
achieved 

Market 
practice 
change 

Not 
available 

- For high 
impact 
standards: 
2Q 2020 

- For low 
impact 
standards: 
no 
confirmed 
plan 

CBF/ 
national 
authorities/ 
SWIFT 
format: 
DESSUG 

B 

N/A 

N/A 

N/A 

N/A 

Info Source: T2S NUG/NSG - 
Settlement finality 
questionnaire, bilateral 
confirmation. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

94% 

Fully 
Compliant 

Fully 
compliant 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

12th T2S Harmonisation Progress Report – Annex 

26 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Info source: HSG survey on 
T2S settlement finality rule III. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 
No barriers identified. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: confirmation from 
the DE NUG. 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

82% 

R-Q4 
2021 

N/A 

N/A 

Q4 2021 

N/A 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 111 CAJWG 
prioritised standards. 

Info source: T2S NUG survey 
and bilateral input. 

Notes: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 
Standard 6 further notes: 
Info source: bilateral input, 2020. 
German market developed a functional model to generate PFODs and integrated tax calculation to fulfil the tax obligations for last paying 
agents by generating market claims on dividends. CASG approved the model as standard compliant. Implementation of that market rule 
was introduced in June 2020. All standards with relation to PFOD are fulfilled. 
• Regarding the CUM flag, German market recommend to launch a survey of the standard especially regarding the actual usage of the 
"CUM" flag. It needs to be clarified if the "CUM" flag is still needed for operations, because in the beginning of the standards some 
markets haven't the possibility to instruct a transaction with backdated trade date and would like to use as trigger for MC entitlement the 
"CUM" flag instead of the trade date. However nowadays, from our point of view "CUM" flag isn't needed anymore since markets can 
instruct with backdated trade dates. 
• Regarding generating of MCs independently of settlement of the underlying transaction, German market would like to highlight current 
discussion regarding status of irrevocability. Market participants asked for support by cancelation of MCs when underlying matched but 
don’t settled transactions on Payment Date (or ISD) which was/is the case in T2S by a handful of transactions. CAJWG and CASG 
Standards apply on „irrevocable transactions“ which would not be fulfilled by „matched transactions“ solely as said in definition/example 
of irrevocableness. There the underlying OTC transaction could be set „on hold“ (without settlement) in T2S while the MC settles. In line 
with the definition of irrevocability the German market does not treat a matched underlying transaction as irrevocable. 
• In the context of T2S cross-border activities, the non-compliant lack of market claim generation for OTC transactions on debt securities 
raised issues for investor CSDs. Implementation Date: after successful implementation of German PFOD model in June 2020 and 
CSD-R in 2019/2020 it is indicated to implement missing standard in next releases (tbd). 

12th T2S Harmonisation Progress Report – Annex 

27 

 
 
 
 
Transformation standards #12 and #13 set on red based on concern from market participants. Analysis of technical development started, 
foreseen target date for implementation 2Q/2021 (tbc). 
Info source: bilateral input June 2020: 
In its aim to fully comply first with the standards where non-compliance is assessed as having a high impact on the rest of the community 
the German market has developed some time ago a special functional model also approved beforehand by the T2S CASG as being 
standard compliant. With the installation of Clearstream’s June 2020 release the aforementioned functionality has been successfully 
implemented. In consequence, the German market now fully complies with the former high-impact market claim standards 9, 10, 14 and 
15 as all cash entitlements deriving from market claims on DE ISINs are settled via T2S in line with the standards. The German market 
has therewith overcome the last vital non-compliance issue. In the end, only a few minor issues remain where the German market is not 
fully standard compliant. However, according to the outcome of the latest impact analysis assessment these issues do not pose any 
major obstacle for the community. 
•In principle the CUM flag is not intended to be implemented without prior approval by the ministry of finance. The German market has 
already started discussion with the ministry to get approval for this cum-flag processing. In general, there seems not to be a real need to 
implement such a flag since CUM processing can in today’s environment also be achieved by changing the trade date (which did not 
exist at the time the standards had been established). In this vein the German market recommended repeatedly to conduct a broad 
market survey regarding the factual usage of the CUM flag. 
•As to the issue of market claims being generated in Germany based on settled transactions(deemed as irrevocable transactions in line 
with the common definition) the German market currently discusses the status of irrevocability. The German market has therefore 
proposed to also discussing this terminology issue in the context of standards maintenance. Moreover, German market participants 
(often) ask for support by cancelling market claims in case the underlying transactions does not settle in the end. Furthermore, a general 
tax concern could not yet be solved. 

12th T2S Harmonisation Progress Report – Annex 

28 

 
 
T2S harmonisation activities: Denmark 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Priority 1 

Activity 

Sub- 
activity 

1. T2S ISO 
20022 
messages 

Fully 
compliant 

2. T2S 
matching 
fields 

Fully 
compliant 

3. 
Interaction 
for 
registration 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Further comments 

Info source: SP2 and bilateral 
input. VP is planning to fully 
comply with the relevant T2S 
standard by its migration to T2S. 

Info source: SP2 and bilateral 
input. VP is planning to fully 
comply with the relevant T2S 
standard by its migration to T2S. 

Info source: T2S HSG surveys 
2013. Registration information 
is not part of the settlement 
instruction. 

Info source: T2S HSG surveys 
2013. Tax information is 
directly associated with the 
account, hence no need to 
transfer the details in 
settlement message. 

Info source: Compliance 
monitoring update May 2019. In 
line with the T2S community 
needs, the AMI-SeCo 
supported the adaptation of the 
T2S calendar as of 2019 based 
on the principle that T2S should 
be open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second T2S 
settlement currency in October 
2018 this will mean that T2S will 
be closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

Info source: Sept 2021 CEG 
survey. VP implemented a 
technical solution ensuring the 
appropriated tax statuses 28 
October 2019. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. Full 
compliance with T2S SF II 
rule. 

12th T2S Harmonisation Progress Report – Annex 

29 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input from the DK 
NUG. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral discussions. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG survey 
and bilateral discussions. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
the Danish NUG. 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

93% 

R-Q4 
2023 

Market 
practice 
change 

Testing 
readiness 
achieved 

N/A 

VP and 
Danish NUG 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 129 CAJWG 
prioritised standards. 

Info source: T2S NUG survey 
and bilateral discussions. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

30 

 
 
 
 
T2S harmonisation activities: Estonia 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

T2S 
messages 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

4. 
Interaction 
for tax info 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Priority 1 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

B 

B 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: NSG input. 
Compliance achieved with 
migration to T2S. 

Info source: NSG input. 
Compliance achieved with 
migration to T2S. 

Info source: NSG input. 
Compliance achieved with 
migration to T2S. 

Info source: NSG input. 
Compliance achieved with 
migration to T2S. 

Info source: Compliance 
monitoring update May 
2019. In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S 
calendar as of 2019 based 
on the principle that T2S 
should be open when any of 
the T2S settlement currency 
RTGS are open. As the 
Danish Kroner will join the 
euro as the second T2S 
settlement currency in 
October 2018 this will mean 
that T2S will be closed on 
Good Friday and Easter 
Monday but open on 1 May 
as of 2019. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Update to 2021 
CEG survey. 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, 
SP2 and bilateral input. The 
local settlement system 
supports the same 
cancellation principles as 
T2S. Matched instruction 
demands cancellation 
instructions from both 
counterparties. 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

12th T2S Harmonisation Progress Report – Annex 

31 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: NSG input. 
Compliance achieved with 
migration to T2S. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: NSG input. 
Compliance achieved with 
migration to T2S. 

Info source: NSG input. 
Compliance achieved with 
migration to T2S. 

Priority 2 

94% 

R-2023 

N/A 

N/A 

No date 
provided 

NUG/MIG 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 127 CAJWG 
prioritised standards. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG survey 
and bilateral input. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

23. 
Securities 
amount 
static data 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

32 

 
 
 
 
T2S harmonisation activities: Spain 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Priority 1 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: NSG input. Full 
compliance achieved with 
migration to T2S. 

Fully 
compliant 

R-? 

Market 
practice 
changes 

N/A 

N/A 

Iberclear 

See notes below for more 
information. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: ES NSG. 

Activity 

Sub- 
activity 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

T2S 
messages 

4. 
Interaction 
for tax info 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used to transfer tax 
information. 

Info source: Compliance 
monitoring update May 
2019. In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S 
calendar as of 2019 based 
on the principle that T2S 
should be open when any of 
the T2S settlement currency 
RTGS are open. As the 
Danish Kroner will join the 
euro as the second T2S 
settlement currency in 
October 2018 this will mean 
that T2S will be closed on 
Good Friday and Easter 
Monday but open on 1 May 
as of 2019. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Sept 2021 CEG 
survey. 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUGs 
surveys 2011 and 2012, SP2 
and bilateral input. No need 
for any changes for 
compliance with T2S SF II 
rule. 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

12th T2S Harmonisation Progress Report – Annex 

33 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: SP2 and bilateral 
input. No need for any 
changes for compliance with 
T2S SF III rule. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

12. 
Settlement 
cycles 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

CSD 
account 
structures 

T2S 
accounts 
numbering 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

83% 

R-? 

N/A 

N/A 

N/A 

Iberclear 

Info source: 2014 HSG survey 
on settlement cycle and 
bilateral exchanges. Spanish 
fixed income securities 
markets (public and private 
debt) migrated to T+2 on 
06/10/2014. Spanish Stock 
Exchange transactions 
(mainly equities) migrated to 
T+2 on 03/10/2016 achieving 
full compliance. 

Info source: T2S NUG survey 
and bilateral input. Full 
compliance in place. 

Info source: T2S NUG survey 
and bilateral input. Full 
compliance in place. 

Info source: NSG input. Full 
compliance achieved with 
migration to T2S. 

Info source: HSG survey on 
T2S DCA numbering, 
April-May 2013. Full 
compliance in place. 

Info source: CEG Survey 
(Sept 2021). The statistics are 
based on the 129 CAJWG 
prioritised standards. 
Iberclear is actively 
encouraging market 
participants to comply with 
remaining standards (timing of 
security payments and 
processing of mandatory with 
options reorganizations in line 
with CAJWG 
standards).Moreover, 
reversals on an automated 
basis for most used 
mandatory reorganization 
CAEV types are already in 
place in line with the 
implementation plan 
announced in the previous 
report. 

12th T2S Harmonisation Progress Report – Annex 

34 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
compliant 

Sub- 
activity 

Activity 

23. 
Securities 
amount 
static data 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: T2S NUGs 
survey and bilateral input. 

Notes: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 
Standard 2 notes: Clarification: discussion is only on Party 2. For rest of mathcing fields Iberclear is fully compliance. 
- The Spanish AMI-SeCO is of the view that the current market practice in the Spanish market goes beyond the matching standards, as 
it encourages to inform about the client of the CSD participant, although this is an optional matching field, and it does not have a negative 
impact. 
- Several discussions have taken place in different fora, especially in the Spanish AMI-SeCo where it has been assessed that the current 
Spanish practice does not affect the settlement efficiency and improves the matching quality, avoiding the x-matching. 
- General agreement in Spanish AMI-SeCo has been reached to consider that current practice is not an issue and no adaptation planning 
is required. We are at your disposal if further information is required. 
- T2S HSG decided to focus on the actual impact of non-strict (literally) compliance of the Spanish market. Regarding the "Party 2", an 
optional matching field, it was discussed in the May 2021 HSG meeting and unfortunately there was not possible to reach a consensus, 
therefore the status remains in Red plus a foot note highlighting the low impact. 

12th T2S Harmonisation Progress Report – Annex 

35 

 
 
 
T2S harmonisation activities: France (Euroclear) 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

B 

B 

T2S 
messages 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for registration 
process. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for sending 
tax-related information. 

Info source: Compliance 
monitoring update May 
2019. In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S 
calendar as of 2019 based 
on the principle that T2S 
should be open when any of 
the T2S settlement currency 
RTGS are open. As the 
Danish Kroner will join the 
euro as the second T2S 
settlement currency in 
October 2018 this will mean 
that T2S will be closed on 
Good Friday and Easter 
Monday but open on 1 May 
as of 2019. 

Info source: CEG survey 
(Sept. 2021). According to the 
ongoing AMI-SeCo CEG 
compliance monitoring, 
Euroclear France is now 
compliant with every T2S CA 
standard, as a consequence 
of asset servicing 
modernisation delivery in 
March 2021. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. EoC 
already complies with T2S 
SFII rule (bilateral 
cancellation). 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

100% 

100% 

B 

N/A 

N/A 

100% 

N/A 

N/A 

N/A 

N/A 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

12th T2S Harmonisation Progress Report – Annex 

36 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. Full 
compliance with omnibus 
account availability in France. 

Not 
compliant 

R-? 

Legal and 
Market 
practice 
change/ 
regulation 

N/A 

N/A 

National 
legislator 

See notes below for more 
information. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 
French market plans for full 
compliance prior to migration 
to T2S. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: FR NUG 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Activity 

Sub- 
activity 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

89% 

R-? 

Market 
practice 
change 

N/A 

Q1 2021 

Euroclear 

Info source: CEG survey 
(Sept. 2021). Statistics are 
based on the 129 prioritised 
standards. 

Priority 2 

23. 
Securities 
amount 
static data 

Not 
compliant 

R-? 

N/A 

N/A 

Newly 
issued 
convertible 
bonds will be 
issued in 
FAMT. 

Newly 
issued 
securisation 
mutual funds 
will be 
denominate
d in FAMT at 
a later date. 

N/A 

See notes below for more 
information 

Notes: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

37 

 
 
 
 
Standard 14 notes: Non-compliance with standard #14 is due to barriers that Euroclear France is unable to remove by its sole action. 
Compliance would require 1/ an overhaul of the French securities law, with possible impacts on several texts (all those dealing to some 
extent with securities’ ownership, which in France can take different forms for the same ISIN) and 2/ major adaptations by the whole 
French post-trade ecosystem (the issuing landscape as well as the internal processes and account structures along the holding and 
custody chain). Following discussions within the French NSG, in July 2021 the BdF has drafted a letter to the MIB President aiming at 
explaining the situation of non-compliance of the French market and arguing for a status quo. Info source as of September 2021: June 
2021 meeting of the French NSG [and agreement in written procedure thereafter], during which this case of non-compliance has been 
considered with NSG Members, who agreed on a common French market position. 
Standard 23 notes: Info source: T2S NUG. There are debt securities denominated in UNIT in the French market, securities issued by 
securisation mutual funds as well as convertible bonds. These limited cases of non-compliance relate to a technical constraint in the CSD 
system that would not allow decimalisation on these debt instruments. For newly issued securities, Euroclear has confirmed that the 
technical constraint preventing decimalisation no longer exists for convertible bonds (the vast majority of non-compliant securities), but 
remains for securities issued by securisation mutual funds. 
The volumes are low (less than 2% of the ISINs related to debt instruments), and will be decreasing as the French market has started to 
denominate all newly issued convertible bonds in FAMT (convertibles represented the vast majority of non-compliant securities). New 
issues of securisation mutual funds will be denominated in FAMT at a later date when a new asset servicing motor (TCS BaNCS) is 
implemented in Euroclear France to manage these securities. 

12th T2S Harmonisation Progress Report – Annex 

38 

 
 
T2S harmonisation activities: Greece (BOGS) 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: GR NUG. T2S 
ISO messages in operation. 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. Interaction 
for 
registration 

4. 
Interaction 
for tax info 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

B 

B 

B 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Info source: GR NUG. T2S 
matching fields in operation. 

Info source: GR NUG. No 
registration information 
relevant for BOGS ISINs. 

Info source: GR NUG. No tax 
info in T2S messages. 

Info source: Compliance 
monitoring update May 2019. In 
line with the T2S community 
needs, the AMI-SeCo supported 
the adaptation of the T2S 
calendar as of 2019 based on 
the principle that T2S should be 
open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second T2S 
settlement currency in October 
2018 this will mean that T2S will 
be closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

Info source: CEG survey 
(Sept. 2021). Full compliance 
with all relevant T2S CA 
standards (sovereign debt 
securities). 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

100% 

100% 

B 

N/A 

N/A 

100% 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

Fully 
Compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: GR NUG. BOGs 
rules in line with T2S SF II. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: GR NUG. BOGs 
rules in line with T2S SF III. 

12th T2S Harmonisation Progress Report – Annex 

39 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: GR NUG, 2014 
HSG survey on IT 
outsourcing. 

Info source: GR NUG. Fully 
compliant since 6 October 
2014. 

Info source: GR NUG. Full 
compliance with omnibus 
account availability. 

Info source: GR NUG. No 
restrictions on the use of 
omnibus accounts. 

Info source: GR NUG. HSG 
survey on T2S securities 
account numbering, April-May 
2013. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: GR NUG. 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

100% 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG Survey 
(Sept. 2020). The statistics 
are based on the 101 
applicable CAJWG prioritised 
standards. 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: GR NUG. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

40 

 
 
 
 
T2S harmonisation activities: Hungary 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Priority 1 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Activity 

Sub- 
activity 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

Fully 
compliant 

T2S 
messages 

3. 
Interaction 
for 
registration 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: SP2 and bilateral 
input. KELER will connect to 
T2S in U2A mode. 

Info source: T2S HSG Survey 
2021 and Bilateral 
communication. KELER 
implemented T2S matching 
logic, with its mandatory, 
additional, and optional 
matching fields and BIC-based 
matching for both domestic and 
T2S-settled transactions, in its 
entirety in Dec 2021. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for passing on 
registration information. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for passing on 
tax-related information. 

N/A 

December 
2021 

KELER 

See notes below for more 
information. 

Not 
compliant 

R-Dec 
2021 

7% 

92% 

R-Q4 
2023 

Major 
technical/ 
market 
practice 
change 

Regulatory/ 
legislative/ 
technical 
change 

Major technical/ 
market practice 
and legal 
change 

100% 

N/A 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

Fully 
Compliant 

Fully 
compliant 

Fully 
compliant 

Mid-2022 

November 
2022 

KELER, 
regulator, 
HU-NSG 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG survey 
(Sept. 2021) & bilateral input. 
The Hungarian market did not 
become fully compliant with 
the T2S market claim 
standards for equities by the 
time of its migration in 
February 2017. Full 
compliance expected by 
November 2023. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input and NUG 
response. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. 

12th T2S Harmonisation Progress Report – Annex 

41 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. No barriers 
identified. 

Info source: T2S NUGs 
survey and bilateral input. No 
barriers identified. 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 

At the moment, the Hungarian 
NCB does not plan to open 
DCAs in T2S. 

Activity 

Sub- 
activity 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

26% 

R-Q4 
2024 

Technical 
change and 
market 
practice 
change for 
some 
standards 

Mid-2024 

End-2024 

KELER 

See notes below for more 
information 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUGs 
survey and bilateral input. Full 
compliance with the EU 
standard. 

Notes: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 
Standard 5 notes: Info source: bilateral input August 2021. 
KELER as the CSD of Hungary is in the process of changing its operating system in a multistage approach. The program is called 
KELER System Development Program, and its first stage will go live by the end of December 2021 after comprehensive market tests with 
the local market participants. This new system is meant to tackle the development needs of T2S harmonisation. The December 2021 go 
live will enable the following: 
• KELER will reach compliance with the T2S calendar by introducing a separate calendar for all T2S transactions; 
• KELER will provide operating hours for T2S transactions on Hungarian bank holidays and national holidays which are not T2S holidays; 
• KELER will harmonise its operating hours within a business day with those of T2S, meaning that unified cut-off times will be introduced 
for settlement transactions in T2S and KELER; 
• KELER will submit eligible value-dated transactions into T2S night-time settlement, however, these transactions will be booked in 
KELER's system only when the next daytime settlement period starts at 4:45 am. 
Standard 18 notes: Info source: CEG Survey (Oct. 2020). The statistics are based on the 129 applicable CAJWG prioritised standards. 
Based on the decision made by the HU-NSG, the Hungarian market complies with CA market standards in two phases: 
o 1st phase: standards related to mandatory corporate actions are planned to be implemented by November 2023; 
o 2nd phase: standards related to elective corporate actions are planned to be implemented by end-2024; 
o therefore full compliance is planned by the end of 2024. 

12th T2S Harmonisation Progress Report – Annex 

42 

 
 
 
 
T2S harmonisation activities: Italy 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: IT NUG. T2S ISO 
messages in operation. 

B 

B 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: IT NUG. T2S 
matching fields in operation. 

Info source: T2S HSG surveys 
2013. Settlement messages 
do not contain any registration 
information. 

Info source: Compliance 
monitoring update Dec 2021. 
Full compliance achieved 
following AMI-SeCo decision 
on the adaptation of 
Standard 4 to allow for the 
exchange of tax-related 
information in T2S messages. 

Monte Titoli was open on 
1 May 2019; therefore the 
market is fully compliant with 
the new T2S calendar. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. Fully 
compliant with T2S SF II rule. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: IT NUG. Full 
compliance with T2S SFIII 
rule. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

T2S 
messages 

5. T2S 
schedule of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

Fully 
Compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12th T2S Harmonisation Progress Report – Annex 

43 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

Activity 

Sub- 
activity 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

95% 

R-Q4 
2025 

N/A 

N/A 

No date 
provided 

N/A 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. No barriers 
identified. 

Info source: T2S NUG survey 
and bilateral input. No barriers 
identified. 

Info source: IT NUG 
confirmation on compliance 
with the standard. 

Info source: HSG survey on 
T2S DCA numbering, 
April-May 2013. BdI already 
complies fully with T2S 
standard. 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 129 
applicable CAJWG prioritised 
standards. 

Info source: T2S NUG survey 
and bilateral input. IT market 
complies fully with the EU 
standard. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

44 

 
 
 
 
Info source: SP2 and bilateral 
input. 

Info source: Bilateral 
confirmation from the NUG. 
Settlement messages are not 
used to transmit registration 
information. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used to transmit 
tax-related information. 

Info source: Compliance 
monitoring update May 2019. 
In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S 
calendar as of 2019 based on 
the principle that T2S should 
be open when any of the T2S 
settlement currency RTGS 
are open. As the Danish 
Kroner will join the euro as the 
second T2S settlement 
currency in October 2018 this 
will mean that T2S will be 
closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

T2S harmonisation activities: Lithuania 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

N/A 

N/A 

N/A 

N/A 

B 

B 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG survey 
(Sept. 2021). 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input and NUG 
Chairperson's response. 

12th T2S Harmonisation Progress Report – Annex 

45 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input and NUG 
Chairperson's response. New 
draft CSD rules were 
submitted for regulatory 
approval at the beginning of 
2016. No legal/regulatory 
barriers identified. 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. No barriers 
identified. 

Info source: T2S NUG survey 
and bilateral input. No barriers 
identified. 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: HSG survey on 
T2S DCA numbering. 

Priority 2 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

91% 

R-? 

N/A 

Implemented 
in 
September 
2020 

Implemented 
in 
September 
2020 

Nasdaq 
CSD 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 129 
applicable CAJWG prioritised 
standards. 

Info source: T2S NUG survey 
and bilateral input. Fully 
compliant with the T2S 
standard. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

46 

 
 
 
 
T2S harmonisation activities: Luxembourg (LUX CSD) 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

B 

B 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Market 
claims (28 
standards) 

100% 

Straight- 
forward to 
implement 

Transform- 
ations (13 
standards) 

100% 

R-Q4 
2023 

Straight- 
forward to 
implement 

N/A 

N/A 

LUX-CSD 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Buyer 
protection 
(18 
standards) 

0% 

Straight- 
forward to 
implement 

Legal 
harmonis- 
ation 

7. 
Settlement 
finality I: 
moment of 
entry 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

Info source: T2S HSG surveys 
2013. Registration information 
is not transferred via 
settlement messages. 

Info source: T2S HSG surveys 
2013. Tax information is not 
transferred via settlement 
messages. 

Info source: T2S 
harmonisation progress 
survey and bilateral input. 

Info source: LU NSG, 
September 2020. To facilitate 
a bilateral BP process 
between counterparties, 
LuxCSD has published in 
October 2019 a final version 
of BP invocation template 
agreed by CAJWG and T2S 
CASG as well as all the 
requirements of the market 
and T2S BP standards, 
including the agreed timeline. 
Please refer to the following 
link on the LuxCSD website. 
The key BP dates are not yet 
notified as not received from 
Issuers/Agents although the 
LuxCSD is technically ready 
to transmit this information in 
the CA Notifications. Proposal 
is that LuxCSD calculates 
such dates as per Standards 
and notify the participants 
accordingly. The proposal 
should be first agreed by the 
market. However, this has not 
been achieved so far due to a 
lack of participation of 
stakeholders from the 
Luxembourgish market in the 
various forums (ALMUS, 
LSG). 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

12th T2S Harmonisation Progress Report – Annex 

47 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Further comments 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. Lux CSD 
will follow CBF instruction 
cancellation process. 

Info source: Survey on T2S 
settlement finality rule III and 
NUG response. SFIII is 
ensured via provisions in 
Luxembourg public law. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 

Info source: T2S NUG survey 
on compliance with T2S 
harmonisation standards, May 
2016 and bilateral input from 
LU NUG. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

84% 

R-Q4 
2023 

Other 

N/A 

N/A 

ABBL 

See notes below for more 
information 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG survey 
and bilateral input. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 
Standard 18 notes: Info source: CEG survey (Sept. 2021). The statistics are based on the 129 applicable CAJWG prioritised standards. 
To facilitate a bilateral BP process between counterparties, LuxCSD has published in October 2019 a final version of BP invocation 
template agreed by CAJWG and T2S CASG as well as all the requirements of the market and T2S BP standards, including the agreed 
timeline. Please refer to the following link on the LuxCSD website. 
The key BP dates are not yet notified as not received from Issuers/Agents although the LuxCSD is technically ready to transmit this 
information in the CA Notifications. Proposal is that LuxCSD calculates such dates as per Standards and notify the participants 
accordingly. The proposal should be first agreed by the market. However, this has not been achieved so far due to a lack of participation 
of stakeholders from the Luxembourgish market in the various forums (ALMUS, LSG). 

12th T2S Harmonisation Progress Report – Annex 

48 

 
 
 
 
T2S harmonisation activities: Latvia 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Priority 1 

Activity 

Sub- 
activity 

1. T2S ISO 
20022 
messages 

Fully 
compliant 

2. T2S 
matching 
fields 

Fully 
compliant 

3. 
Interaction 
for 
registration 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Source: bilateral input and 
quarterly self assessment. 
Latvian CSD plans to comply 
fully by migration date. 

Source: XMAP Survey 2015 
and further bilateral 
clarification from the NUG on 
adaptation of initial register 
transactions according to T2S 
matching specifications. 

Source: bilateral input. 
Registration information is not 
passed on through settlement 
messages. 

Source: bilateral input. 
Tax-related information is not 
passed on through settlement 
messages. 

Info source: Compliance 
monitoring update May 2019. In 
line with the T2S community 
needs, the AMI-SeCo supported 
the adaptation of the T2S 
calendar as of 2019 based on 
the principle that T2S should be 
open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second T2S 
settlement currency in October 
2018 this will mean that T2S will 
be closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG survey 
(Sept. 2021). 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Source: LV NUG. 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

12th T2S Harmonisation Progress Report – Annex 

49 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Source: LV NUG. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: LV NUG. Fully 
compliant since 6 October 
2014. 

B 

N/A 

N/A 

N/A 

N/A 

Source: LV NUG. 

B 

N/A 

N/A 

N/A 

N/A 

Source: LV NUG. There are 
no restrictions rules regarding 
omnibus accounts in the 
Latvian CSD. 

B 

N/A 

N/A 

N/A 

N/A 

Source: LV NUG. 

B 

N/A 

N/A 

N/A 

N/A 

Source: LV NUG. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

91% 

R-? 

Major 
technical 
change 

Q2 2017 

N/A 

Latvia CSD 

Info source: CEG Survey (Sep 
2019). The statistics are 
based on the 129 applicable 
CAJWG prioritised standards. 

Priority 2 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Source: LV NUG. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

50 

 
 
 
 
T2S harmonisation activities: Malta 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

T2S 
messages 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

4. 
Interaction 
for tax info 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Priority 1 

B 

B 

N/A 

N/A 

N/A 

N/A 

Info source: MT NUG. T2S 
ISO messages in operation. 

N/A 

N/A 

N/A 

N/A 

Info source: MT NUG. T2S 
matching fields in operation. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Info source: CEG survey 
(Sept. 2021). 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: MT NUG. CSD 
rules in line with T2S SF II. 

12th T2S Harmonisation Progress Report – Annex 

51 

Info source: MT NUG. No 
registration info in T2S 
messages. 

Info source: MT NUG. No tax 
info in T2S messages. 

Info source: Bilateral input Nov 
2019. In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S calendar 
as of 2019 based on the 
principle that T2S should be 
open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second 
T2S settlement currency in 
October 2018 this will mean 
that T2S will be closed on 
Good Friday and Easter 
Monday but open on 1 May as 
of 2019. Compliance by T2S 
markets with the standard on 
the T2S calendar is to be 
reassessed once the new T2S 
calendar is implemented. 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Info source: MT NUG. CSD 
rules in line with T2S SF III. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: MT NUG. CSD 
rules in line with T2S SF III. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

Info source: MT NUG. Fully 
compliant since 6 October 
2014. 

Info source: MT NUG. Full 
compliance with omnibus 
account availability. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: MT NUG. No 
restrictions on the use of 
omnibus accounts. 

Info source: MT NUG. 
Confirmation from the NUG 
received post-migration to 
T2S. 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 120 
applicable CAJWG prioritised 
standards. 

Info source: T2S NUG survey 
and bilateral input. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

23. 
Securities 
amount 
static data 

74% 

R-? 

Other 

N/A 

N/A 

MSE 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

52 

 
 
 
 
T2S harmonisation activities: The Netherlands 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Priority 1 

Activity 

Sub- 
activity 

1. T2S ISO 
20022 
messages 

Fully 
compliant 

2. T2S 
matching 
fields 

Fully 
compliant 

3. 
Interaction 
for 
registration 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

100% 

100% 

B 

N/A 

N/A 

100% 

N/A 

N/A 

N/A 

N/A 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Further comments 

Info source: SP2 and bilateral 
input. Plans and dates for full 
compliance have been 
provided. 

Info source: SP2 and bilateral 
input. Plans and dates for full 
compliance have been 
provided. 

Info source: T2S HSG surveys 
2013. There are no registered 
securities in the Netherlands. 
Registration information is not 
transmitted via settlement 
messages. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used to transmit 
tax-related information. 

Info source: Compliance 
monitoring update May 2019. In 
line with the T2S community 
needs, the AMI-SeCo supported 
the adaptation of the T2S 
calendar as of 2019 based on 
the principle that T2S should be 
open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second T2S 
settlement currency in October 
2018 this will mean that T2S will 
be closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. 

Info source: CEG survey 
(Sept. 2021). Full compliance 
achieved on 15 March 2021, 
with Euroclear Nederland (the 
IOC in NL) migrating 
mandatory events to its new 
CA platform. 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. EoC ESES 
already complies with bilateral 
cancellation after matching. 

12th T2S Harmonisation Progress Report – Annex 

53 

 
 
 
B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

B 

N/A 

N/A 

N/A 

N/A 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

Further comments 

Info source: T2S NUG 
surveys 2011 and 2012, SP2 
and bilateral input. 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. 

Info source: T2S NUG survey 
and bilateral input. 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 
T2S NUG survey and bilateral 
input. 

Info source: List of cash and 
securities side DCPs as 
published by DCPG and 
further confirmation from the 
NL NUG. 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 129 
applicable CAJWG prioritised 
standards. The market was 
assessed as fully compliant in 
2020, with the implementation 
of Mandatory Reorganisation - 
standard 12. 

Info source: T2S NUG survey 
and bilateral input. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

MSE 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

54 

 
 
 
 
T2S harmonisation activities: Portugal 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

T2S 
messages 

5. T2S 
schedule of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

Priority 1 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

B 

B 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: SP2 and bilateral 
input and quarterly status 
gathering templates. 

Info source: SP2 and bilateral 
input and quarterly status 
gathering templates. 

Info source: T2S HSG surveys 
2013. No registration details 
are sent via settlement 
instructions. 

Info source: T2S HSG surveys 
2013 and further bilateral 
clarifications. Tax-related 
information is not passed on 
when sending settlement 
instructions. 

Info source: T2S harmonisation 
progress survey and bilateral 
input. 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Fully 
compliant 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

Fully 
Compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG survey 
(Sept. 2021) and bilateral 
input. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: PT NUG. Full 
compliance with T2S SF II 
rule. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: PT NUG. Full 
compliance with T2S SF III 
rule. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

12th T2S Harmonisation Progress Report – Annex 

55 

 
 
 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

Activity 

Sub- 
activity 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

88% 

R-Q4 
2023 

N/A 

N/A 

N/A 

N/A 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. Omnibus 
accounts are available. 

Info source: HSG discussions 
(Feb 2015). There are no 
restrictions on the omnibus 
accounts that need to be 
propagated down the 
settlement chain. 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 

Info source: HSG survey on 
T2S DCA numbering, 
April-May 2013. 

Info source: CEG survey 
update (Sept. 2021). The 
statistics are based on the 129 
applicable CAJWG prioritised 
standards. 

Info source: T2S NUG. Full 
compliance following 
migration. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

56 

 
 
 
 
T2S harmonisation activities: Romania 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Priority 1 

Activity 

Sub- 
activity 

T2S 
messages 

1. T2S ISO 
20022 
messages 

Fully 
compliant 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

4. 
Interaction 
for tax info 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: NUG and bilateral 
exchanges. A2A connectivity 
mode reached on 17 January 
2017. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Bilateral input Nov 
2019. In line with the T2S 
community needs, the 
AMI-SeCo supported the 
adaptation of the T2S calendar 
as of 2019 based on the 
principle that T2S should be 
open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second T2S 
settlement currency in October 
2018 this will mean that T2S will 
be closed on Good Friday and 
Easter Monday but open on 
1 May as of 2019. Compliance 
by T2S markets with the 
standard on the T2S calendar is 
to be reassessed once the new 
T2S calendar is implemented. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG survey 
(Sept. 2021). 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

12th T2S Harmonisation Progress Report – Annex 

57 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

89% 

R-? 

Priority 2 

Market 
practice as 
well as 
regulatory 
changes 

Testing 
readiness 
achieved 

No fixed date 
provided 

CSD, 
Regulator, 
NCB 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: Confirmation from 
the NUG received 
post-migration to T2S. 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 129 
applicable CAJWG prioritised 
standards. 

Info source: T2S NUG survey 
and bilateral input. No issues 
with securities amount data in 
Romania. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

58 

 
 
 
 
T2S harmonisation activities: Slovenia 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

T2S 
messages 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

B 

B 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and bilateral 
input. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for transmission 
of registration information. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for transmission 
of tax information. 

Bilateral input August 2020: 
KDD (CSD) offered FOP 
settlement on 1 May 2020 and 
committed to operate on 
1 May also in the following 
years. 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: CEG survey 
(Sept. 2021). 

Fully 
Compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2, 
status gathering templates 
Q2 2013 and bilateral input. 

Info source: T2S NUG 
surveys 2011 and 2012, SP2, 
status gathering templates Q2 
2013 and bilateral input. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. 

12th T2S Harmonisation Progress Report – Annex 

59 

 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Activity 

Sub- 
activity 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Further comments 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Priority 2 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013, 
Q2 2013 status gathering 
template. 

Info source: HSG survey on 
T2S DCA numbering, 
April-May 2013. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

KDD/ 
national 
legislators 
and 
regulators 

Info source: CEG Survey 
(Sept. 2021). The statistics 
are based on the 129 
applicable CAJWG prioritised 
standards. 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Q2 2013 status 
gathering template. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

60 

 
 
 
 
T2S harmonisation activities: Slovakia (CDCP) 

Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

T2S 
messages 

1. T2S ISO 
20022 
messages 

2. T2S 
matching 
fields 

3. 
Interaction 
for 
registration 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

4. 
Interaction 
for tax info 

Fully 
compliant 

Priority 1 

N/A 

N/A 

N/A 

N/A 

Info source: SP2 and T2S 
NUG bilateral input. 

N/A 

N/A 

N/A 

N/A 

B 

B 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

5. T2S 
schedule 
of 
settlement 
day 

6. 
Corporate 
actions 
T2S CA 
standards 
(59) 

Legal 
harmonis- 
ation 

Market 
claims (28 
standards) 

Transform- 
ations (13 
standards) 

Buyer 
protection 
(18 
standards) 

7. 
Settlement 
finality I: 
moment of 
entry 

8. 
Settlement 
Finality II: 
irrevoc- 
ability and 
enforce- 
ability 
transfer 
order 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

100% 

100% 

B 

Major 
technical 
changes 

N/A 

September 
2018 

N/A 

Info source: CEG survey 
(Sept. 2021). 

100% 

Fully 
Compliant 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Full compliance achieved in 
March 2018 with the 
completion of the collective 
agreement. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Status gathering 
templates and T2S NUG. 

12th T2S Harmonisation Progress Report – Annex 

61 

Info source: T2S HSG surveys 
2013. 

Info source: T2S HSG surveys 
2013. Settlement messages 
are not used for transmission 
of tax information. 

In line with the T2S community 
needs, the AMI-SeCo 
supported the adaptation of the 
T2S calendar as of 2019 based 
on the principle that T2S should 
be open when any of the T2S 
settlement currency RTGS are 
open. As the Danish Kroner will 
join the euro as the second 
T2S settlement currency in 
October 2018 this will mean 
that T2S will be closed on 
Good Friday and Easter 
Monday but open on 1 May as 
of 2019. Compliance by T2S 
markets with the standard on 
the T2S calendar is to be 
reassessed once the new T2S 
calendar is implemented. 

 
 
 
 
Compliance  Status 

Type of 
implement- 
ation gap 

Implementation 
plan/date* 

Implement- 
ation 
actor(s) 

If the 
standards/ 
rules are not 
yet 
implemented, 
please 
specify what 
the type of 
gap is 

Green 
(G), 
yellow 
(Y),   
red   
(R), 
blue 
(B) 

Indicates 
level of 
compliance 
with the 
relevant 
standards/ 
rules 

Activity 

Sub- 
activity 

Fully 
operational 
according 
to the T2S 
standard 

Relevant 
national 
actors for 
implement- 
ation 

Ready for 
T2S testing 

Further comments 

9. 
Settlement 
Finality III: 
irrevoc- 
ability of 
securities 
transfers. 

10. 
Outsourcing 
IT 
(Settlement) 
services 

13. 
Availability 
of omnibus 
accounts 

14. 
Restrictions 
on omnibus 
accounts 

15. 
Securities 
account 
numbering 

16. 
Dedicated 
cash 
account 
numbering 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

Fully 
compliant 

12. 
Settlement 
cycles 

CSD 
account 
structures 

T2S 
accounts 
numbering 

B 

N/A 

N/A 

N/A 

N/A 

Info source: Status gathering 
templates and T2S NUG. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: 2014 HSG survey 
on IT outsourcing. With the 
CSDR now being law, no 
barriers to outsourcing to 
public entities remain. 

Info source: Bilateral 
confirmation from NUG. Fully 
compliant since 6 October 
2014. 

Info source: T2S NUG survey 
and bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG 
bilateral input. 

B 

N/A 

N/A 

N/A 

N/A 

B 

N/A 

N/A 

N/A 

N/A 

Info source: HSG survey on 
T2S securities account 
numbering, April-May 2013. 

Info source: HSG survey on 
T2S DCA numbering, 
April-May 2013. NCB plans 
full compliance. Dates are 
provided. 

18. 
Corporate 
actions 

CA market 
standards 
(68) 

12% 

R-? 

Priority 2 

Changes in 
the CSD 
rules, market 
practice 
changes and 
IT changes. 

The 
Implementati
on plan will 
be provided 
as soon as 
possible. 

The 
Implementati
on plan will 
be provided 
as soon as 
possible. 

SK market, 
CDCP, 
regulators 
(approval of 
amended 
CDCP rules) 

Info source: CEG Survey 
(Sept.2021). The statistics are 
based on the 129 applicable 
CAJWG prioritised standards. 

23. 
Securities 
amount 
static data 

Fully 
compliant 

B 

N/A 

N/A 

N/A 

N/A 

Info source: T2S NUG input. 
Legislative change has 
already taken place. 

Note: * If standards/rules are not fulfilled, please provide the timetable and various milestones/dates in the implementation plan. 

12th T2S Harmonisation Progress Report – Annex 

62 

 
 
 
 
Annex 3: Impact assessment of non-compliance 

See AMI-SeCo’s Impact Analysis Report on non-compliance with T2S harmonisation 
standards (December 2021) published on the ECB’s website. 

12th T2S Harmonisation Progress Report – Annex 

63 

 
 
Annex 4: Methodology 

See Methodology for progress assessment on AMI-SeCo securities settlement 
harmonisation activities published on the ECB’s website. 

12th T2S Harmonisation Progress Report – Annex 

64 

 
 
 
© European Central Bank, 2022 

Postal address 
Telephone 
Website 

60640 Frankfurt am Main, Germany 
+49 69 1344 0
www.ecb.europa.eu

All rights reserved. Reproduction for educational and non-commercial purposes is permitted provided that the source is acknowledged. 

For specific terminology please refer to the ECB glossary (available in English only). 

PDF 

ISBN 978-92-899-5103-6, ISSN 2529-3257, doi:10.2866/651482, QB-CD-22-001-EN-N