Corporate events compliance report : 2024 monitoring exercise.
Date: 2025-01-21
Institutions: European Central Bank
Subjects: activity report, business activity, business policy, standard

Corporate Events 
Compliance Report 

Advisory Group on Market Infrastructures for 
Securities and Collateral 

2024 Monitoring Exercise 

December 2024 

 
 
 
 
Contents 

Executive summary and main findings 

Box 1 Overview of disclosure requests per AMI-SeCo market 

Box 2 Overview of progress since last reporting cycle 

Box 3 Overview of overall compliance status per market 

1 

Introduction 

1.1  Procedures 

1.2  Methodology 

2 

3 

Key takeaways per market 

Compliance assessment 

3.1  Distributions 

Box 4 Cash Distributions – Compliance status per Standard 

Box 5 Security Distributions – Compliance status per Standard 

3.2  Reorganisations 

Box 6 Mandatory Reorganisations – Compliance status per Standard 

Box 7 Mandatory Reorganisations with Options – Compliance status 

per Standard 

Box 8 Voluntary Reorganisations – Compliance status per Standard 

3.3  Market Claims 

Box 9 Market Claims – Compliance status per Standard 

3.4 

Transformations 

3.5  Buyer Protection 

3.6  Shareholder Identification 

Box 10 Shareholder Identification – Compliance status per Standard 

Annex 1: Market Reporting 

Annex 2: Methodology 

Corporate Events Compliance Report – Contents 

2 

7 

9 

10 

13 

13 

14 

15 

44 

45 

45 

56 

69 

69 

78 

89 

99 

100 

107 

113 

119 

119 

139 

142 

1 

 
 
Executive summary and main findings 

Each year the Advisory Group on Market Infrastructures for Securities and 
Collateral (AMI-SeCo) organises a compliance monitoring exercise in order to 
assess current levels of compliance with corporate event standards in 
Europe.1  This report presents the outcome of the fifth monitoring exercise 
conducted by the AMI-SeCo Corporate Events Group (CEG). It contains an 
assessment of compliance with the Joint Working Group’s Market Standards for 
Corporate Actions Processing (Market CA Standards), the T2S Corporate Actions 
Standards (T2S CA Standards) and the Market Standards for Shareholder 
Identification (SI Standards). 

All AMI-SeCo markets2, with the exception of the United Kingdom (UK), 
participated in the 2024 monitoring exercise. Further engagement with the UK 
market is needed with a view to putting in place the necessary reporting structures to 
ensure active participation in future exercises. The overall high level of participation 
helps to provide an insight into the state of corporate event processing across 
Europe. Accordingly, the information contained in this report could, inter alia, help to 
inform future regulatory proposals in the field of corporate events with a view to 
addressing some of the obstacles to the implementation of common pan-European 
processes that are identified in the report. 

As from 2025, AMI-SeCo, supported by the CEG, will take over responsibility 
for the definition, maintenance and monitoring of all corporate event related 
market standards defined at European level. Such consolidation will enable AMI-
SeCo to realise its objective of creating a single rulebook for corporate events in 
Europe. The CEG will also lead industry work on T+1 in the field of corporate events 
in 2025. 

In addition to assessing compliance with corporate event standards, the CEG 
also collected additional information on the functioning of the shareholder 
identification process. This includes information on the transposition of the 
Shareholder Rights Directive (SRD II)3  requirements into national legislation, levels 
of market wide adoption of the relevant ISO 20022 messages and the way in which 
the ISO 20022 messages are being used. For further information, please refer to 
sub-section 3.6.2 of this report. Information on the volumes of SI requests per market 
was also collected (please see Box 1 for details). 

1    The SCoRE Corporate Action Standards are monitored separately by AMI-SeCo’s Collateral 

Management Group (CMG). The Market Standards for General Meetings are not subject to monitoring. 

2    AMI-SeCo markets comprise European Economic Area countries, the United Kingdom and 

Switzerland. 

3    Directive (EU) 2017/828 of the European Parliament and of the Council of 17 May 2017 amending 

Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement (OJ L 132, 
20.5.2017, p. 1). 

Corporate Events Compliance Report – Executive summary and main findings 

2 

 
 
 
Main findings 

Corporate Actions   

In the field of corporate actions that are within in the scope of this report, the 
figures from the monitoring exercise show some limited increases in 
compliance over the past twelve months (see Box 2). 

• 

• 

• 

• 

• 

The greatest increases in compliance are observed in the Cypriot and 
Bulgarian markets. Both markets are now compliant with the vast majority of 
the corporate standards and have plans in place to resolve most of the 
remaining gaps in the next twelve months. 

In several cases, the overall level of compliance is lower owing to a more 
rigorous self-assessment by each market coupled with an increase in the 
level of information made available to the CEG via an enhanced reporting 
template. Non-local markets also had the possibility to report non-compliance 
cases, which further enhanced the quality of the assessment and helped to 
identify many issues with compliance across several markets. 

Some markets do not comply with corporate actions on flow standards 
(Market Claims, Transformations and Buyer Protection) and have no plans 
in place to implement them. This is considered a matter of concern, as it acts 
as a barrier to the implementation of a common pan-European process. 

Five markets – Euroclear Bank (Belgium), SKDD (Croatia), Euroclear 
Finland (Finland), BNBGSSS and CDAD (both Bulgaria) – joined T2S in 
September 2023 and were therefore assessed against the T2S CA Standards 
for the second time. While three of these markets are expected to achieve full 
compliance with the T2S CA Standards in the next twelve months, Euroclear 
Bank and Euroclear Finland are yet to announce a concrete date for 
implementing the remaining standards.   

Specific challenges in implementing certain corporate event standards 
have been observed in direct holding markets (i.e. markets where end 
investors hold securities accounts in a CSD). In the Finnish market several 
challenges have been identified regarding the implementation of a standards-
compliant mechanism for the processing of market claims, in particular in 
relation to the tax treatment of such claims. For further details, please refer to 
the Finnish market summary in Section 2.   

•  While many markets have fully implemented standards relating to the 

reversal of corporate actions, some markets (particularly direct holding 
markets) continue to report legal barriers to the processing of reversals.   

• 

Problems with compliance in announcing the key dates of a corporate 
action (e.g. ex-date, record date, payment date etc.), and in the reporting of 
such dates in the correct sequence, continue to be observed in several 

Corporate Events Compliance Report – Executive summary and main findings 

3 

 
 
markets. The emergence of more complex structured products give rise to 
additional complexity in this area. 

• 

• 

Late payments continue to be a problem in several markets. In one market 
the issue is considered to a structural problem with late payments resulting from 
the reliance on batch processing in payment systems for the transfer of cash 
proceeds to the issuer CSD. While efforts have been undertaken to limit the 
number of late payments, a sizable number of late payments are still observed.   

Although some markets have made progress in implementing electronic 
communication from the issuer to the issuer CSD in the last twelve 
months, gaps still remain and overall progress is too slow in this area. 
Provision of complete and accurate information on corporate events by the 
issuer (or its agent) which can act as a unique and reliable data source for the 
entire custody chain is critical to the efficient and effective functioning of the 
entire corporate event process. Enshrining a requirement for an issuer (or its 
agent) to provide complete corporate event data4  to the issuer CSD in a 
standardised electronic form in a future regulatory initiative could therefore help 
to address a critical barrier to the effective and efficient processing of corporate 
events. 

Many markets have developed a concrete action plan to achieve full 
compliance with corporate actions (CA) standards. 

• 

• 

• 

• 

The Single Collateral Management Rulebook for Europe (SCoRE) 
Standards are acting as a catalyst for further implementation of existing 
CA standards, with several markets reporting plans to either significantly 
increase compliance or achieve full compliance with the Market CA Standards 
and/or the T2S CA Standards in the course of 2025. 

Several markets plan to achieve full compliance in the coming years as 
part of an overhaul of their asset servicing infrastructure. More detailed 
information on the implementation roadmap for these initiatives should be 
provided in next year’s corporate events compliance monitoring exercise.   

The CEG notes that several markets have reported delays in the planned 
date of implementation in this year’s exercise. This is considered a matter of 
concern and the CEG will closely monitor the reporting of any potential further 
delays by these markets. 

Some markets continue to lag behind, however, with no clear plan or 
commitment in place to implement the standards. This acts as a barrier to 
the implementation of a common pan-European processes as part of a Single 
Rulebook and the establishment of a Capital Markets Union. Further action is 
therefore required in these markets. 

4    The SCoRE Corporate Actions Rulebook sets out a common minimum set of data which the issuer 
CSD must provide to its participants. This minimum set of data could also form the basis of the 
minimum set of common data per event which must be provided to the issuer CSD by the issuer (or its 
agent). 

Corporate Events Compliance Report – Executive summary and main findings 

4 

 
 
 
Shareholder Identification 

Several common themes were identified by the CEG in its assessment of 
compliance with the SI Standards. 

• 

• 

• 

Despite the high levels of compliance reported in most Self-Assessment 
Reports, significant issues with the processing of SI requests are still 
observed. Greatest challenges are faced in respect of cross-border activity 
owing to differences in operational procedures across markets as several 
entities active in multiple European markets do not comply with the SI 
Standards. Such differences need to be eliminated in order to deliver a common 
pan-European process. 

The definition of shareholder is not consistent across markets. This 
creates difficulties in instances where the shareholder is considered to be the 
account owner rather than the beneficial owner. As previously flagged by AMI-
SeCo to European authorities, a harmonised European definition of shareholder 
is therefore needed. 

Rates of response by intermediaries to SI requests are still suboptimal in 
many markets. Information collected by the CEG shows that response rates to 
individual requests range between 75 and 95 percent in many markets. Outside 
of Europe, there is evidence that some large intermediaries, notably from the 
United States and Asia-Pacific (APAC), are responding with an average 
response rate between 85 and 95 percent. However, there are also cases of 
other intermediaries not responding, either because they believe there are 
conflicting data security laws in their jurisdiction or because of their lack of 
awareness of SRD II and the obligation to disclose. 

•  Many issuer agents and intermediaries are not yet able to process SI 

requests in the correct ISO 20022 reporting format. This creates significant 
problems for all parties in the chain and leads to a break in straight-through 
processing. Given the importance of the disciplined use of ISO 20022 
messaging to the efficient and effective functioning of the overall process, there 
would be a need for greater precision with respect to messaging requirements 
in any future regulatory proposals in this field. Such requirements could include 
a reference to the specific ISO 20022 messages which would need to be 
implemented by market stakeholders to support the related operational 
processes. 

• 

The procedures for the disclosure of shareholder information may differ 
in direct holding markets where end investors may (or must) have direct 
accounts in the local CSD. In some direct holding markets the issuer has a legal 
right to receive the register from the CSD. This register contains the names and 
other details of all holders of owner accounts, as well as the names and other 
details of all holders of nominees.   

• 

In one market, based on the issuer’s request, there is a requirement that 
shareholder identification responses must be sent through the custody 

Corporate Events Compliance Report – Executive summary and main findings 

5 

 
 
• 

• 

• 

• 

• 

chain or directly to the issuer. In the CEG’s view, this is not in line with the SI 
Standard 3.1. The market plans to amend this requirement as of the first quarter 
of 2026 however in order to comply with the standard. 

SRD II is applicable to shares (i) issued by companies whose registered 
office is in the European Economic Area (EEA) and (ii) admitted to trading 
and listed on an EEA regulated market. Several markets, meanwhile, have 
disclosure requirements in place which extend beyond listed shares to 
cover, for example, bonds and investment funds. These securities comprise a 
sizeable proportion of the total amount of disclosure requests received in AMI-
SeCo markets (as illustrated in Box 1). The operational processing of SRD II 
related and non-SRD II related requests is, however, not always the same (for 
example, different messages and workflows may be used to process the 
disclosure requests).   

Applying different rules and standards per instrument type increases 
complexity. From a cross-border perspective in particular, the existence of 
multiple disclosure requirements (which also may depend on the asset type), 
each with a potentially different legal basis, gives rise to significant challenges 
for foreign intermediaries to check and verify the legal validity of the request 
before disclosing the requested information.   

There are also potential issues with conflict of laws, as intermediaries in 
one country may be unable to disclose information based on a law in 
another country. Many of the legal and operational issues that arise out of 
different sources of disclosure requests could be tackled by broadening the 
scope of the common European legal foundations for disclosure requests, and 
the relevant common operational rules and processes, so that ideally they cover 
all instrument types. 

Several markets experience difficulties in verifying that requests come 
from, or are made on behalf of, the issuer, as central securities depositories 
(CSDs) and intermediaries may not have a contractual relationship with either 
the issuer or the SI agent. This results in the need for time-consuming manual 
processes to validate SI requests prior to processing. 

The CEG has also identified challenges with (i) verifying, in an automated 
manner, whether the ISIN stipulated in the disclosure request is in the 
scope of the applicable law and (ii) when a threshold is applied, checking 
whether the figure given as threshold is compatible with the national legal 
framework – such check can only be performed by either the issuer (agent) or 
the issuer CSD, as these are the only parties with complete information on the 
total number of outstanding securities information which is needed to verify if 
the request is under above the applicable threshold (if any) in the given market. 

• 

Paper-based requests are being received in a number of markets. Such 
requests are not consistent with the objectives of the SI Standards and the 

Corporate Events Compliance Report – Executive summary and main findings 

6 

 
 
SRD II Implementing Regulation5, which requires SI requests to be machine 
readable (which cannot be achieved with paper requests). Handling of paper-
based requests may also give rise to concerns over the security of the 
transmission of responses. 

• 

• 

The receipt of SI information is a prerequisite for the smooth execution of 
other corporate event processes in some AMI-SeCo markets. In those 
markets, the CEG noted that withholding payments and prohibiting investors 
from participating in general meetings are two of the tools used by issuers as 
mitigation measures to deal with cases where information on the holders of the 
securities is not disclosed upon request. 

It is noted that some intermediaries in several European markets charge 
issuers (or their agents) for responding to requests to disclose 
shareholder information. From an issuer’s point of view, this gives rise to 
uncertainty about the total costs of requesting information, since (i) the number 
of responses cannot be estimated and (ii) the level of costs varies depending on 
the market. 

Box 1 
Overview of disclosure requests per AMI-SeCo market   

In SRD II scope 

Outside SRD II scope 

Issued in the local CSD 

Issued in a foreign CSD 

Issued in the local CSD 

Issued in a foreign CSD 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY 
% change) 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY % 
change) 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY 
% change) 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY % 
change) 

AT - Oesterreichische Kontrollbank (T2S) 

34 (2) 

35 (-3%) 

445 (0) 

439 (+1%) 

0 (0) 

0 

25 (0) 

40 (-38%) 

BE - Euroclear Bank (T2S) 

4 (0) 

9 (-56%) 

2125 (0) 

1766 (+20%) 

385 (0) 

181 (+113%) 

0 (0) 

BE - Euroclear Belgium (T2S) 

132 (0) 

139 (-5%) 

58 (0) 

62 (-6%) 

0 (0) 

BE - NBB-SSS (T2S) 

BG - BNBGSSS (T2S) 

BG - CDAD (T2S) 

CH - SIX SIS (T2S) 

CY - Cyprus Stock Exchange 

CZ - CSD Prague 

CZ - SKD 

N/A 

N/A 

6 (0) 

0 (0) 

0 (0) 

1 (0) 

N/A 

N/A 

N/A 

7 (-14%) 

0 

0 

N/A 

N/A 

0 (0) 

0 (0) 

15 (0) 

N/A 

N/A 

0 

0 

0 

1 (+0%) 

18 (0) 

20 (-10%) 

N/A 

N/A 

N/A 

DE - Clearstream Banking Frankfurt (T2S) 

210 (2) 

351 (-40%) 

978 (52) 

911 (+7%) 

DK - Euronext Securities Copenhagen (T2S) 

1 (0) 

0 

870 (0) 

15 (0) 

20 (-25%) 

0 (0) 

0 

0 

N/A 

N/A 

0 (0) 

0 (0) 

0 (0) 

0 (0) 

N/A 

0 (1) 

0 (0) 

1 (0) 

EE - Nasdaq CSD (T2S) 

ES - Iberclear (T2S) 

0 

N/A 

N/A 

0 

0 

0 

0 

N/A 

0 

0 

0 

0 (0) 

N/A 

N/A 

0 (0) 

0 (0) 

0 (0) 

0 (0) 

N/A 

0 (0) 

0 (0) 

38   

42 (-10%) 

1203 (4) 

81 (+1385%) 

71 

88 (-19%) 

42 (7) 

FI - Euroclear Finland (T2S) 

3 (0) 

4 (-25%) 

0 (0) 

2 (-100%) 

FR - Euroclear France (T2S) 

1156 (0) 

1300 (-11%) 

58 (0) 

194 (-70%) 

GR - BOGS (T2S) 

GR - ATHEXCSD 

HR - SKDD (T2S) 

N/A 

N/A 

61 (0) 

76 (-20%) 

6 (0) 

15 (-60%) 

N/A 

6 (0) 

0 (0) 

N/A 

262 (-98%) 

0 

0 (0) 

0 (0) 

N/A 

5 (0) 

0 (0) 

0 

0 

N/A 

0 (0) 

0 (0) 

N/A 

4 (+25%) 

0 

2 (-100%) 

0 

0 (0) 

0 

101 (5) 

85 (+19%) 

0 

0 

N/A 

N/A 

0 

0 

0 

0 

N/A 

0 

0 

0 

0 

0 

N/A 

5    Commission Implementing Regulation (EU) 2018/1212 of 3 September 2018 laying down minimum 

requirements implementing the provisions of Directive 2007/36/EC of the European Parliament and of 
the Council as regards shareholder identification, the transmission of information and the facilitation of 
the exercise of shareholders rights (OJ L 223, 4.9.2018, p. 1). 

Corporate Events Compliance Report – Executive summary and main findings 

7 

 
 
 
 
 
 
In SRD II scope 

Outside SRD II scope 

Issued in the local CSD 

Issued in a foreign CSD 

Issued in the local CSD 

Issued in a foreign CSD 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY 
% change) 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY % 
change) 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY 
% change) 

No. of 
processed / 
(rejected) 
requests in 
2024 

No. of 
processed 
requests in 
2023 / (YoY % 
change) 

0 (0) 

0 

0 (0) 

1 (0) 

0 (0) 

0 

0 

0 

0 

0 

131 (0) 

139 (-6%) 

0 

0 (0) 

390 

0 

0 

503 (-22%) 

2592 (0) 

952 (+172%) 

N/A 

0 (0) 

0 (0) 

0 (0) 

0 (0) 

N/A 

0 

0 

0 

0 

N/A 

0 (0) 

0 (0) 

0 

N/A 

0 

0 

15 

1571 (0) 

1451 (+8%) 

HU - KELER (T2S) 

IE - Euroclear Bank (T2S) 

IS - Nasdaq CSD 

IT - Euronext Securities Milan (T2S) 

LI - SIX SIS 

LT - Nasdaq CSD (T2S) 

111 (0) 

129 (-14%) 

0 (0) 

0 

1092 (0) 

671 (+63%) 

0 (0) 

0 

LU - Clearstream Banking Luxembourg 

LU - LuxCSD (T2S) 

LV - Nasdaq CSD (T2S) 

MT - Malta Stock Exchange (T2S) 

1 (0) 

2 (-50%) 

37 (0) 

41 (-10%) 

0 (0) 

0 (0) 

0 

0 

NL - Euroclear Nederland (T2S) 

133 (0) 

142 (-6%) 

58 (0) 

62 (-6%) 

NO - Euronext Securities Oslo 

27 (5) 

0 

0 (0) 

0 

0 (0) 

5 (1) 

0   

679 (12) 

376 (+81%) 

8 (-38%) 

48 (2) 

12 (+300%) 

0 (2) 

0 (0) 

1 (-100%) 

22 (4) 

36 (-39%) 

5 (-100%) 

378 (0) 

303 (+25%) 

1 (0) 

0 (0) 

0 (2) 

7 (-86%) 

0 

0 

5 (2) 

0 (0) 

0 (0) 

0 (0) 

2 (2) 

0 (0) 

N/A 

PL - KDPW 

PL - SKARBNET4 

218 (0) 

162 (+35%) 

46 (0) 

22 (+109%) 

42 (0) 

51 (-18%) 

N/A 

N/A 

N/A 

N/A 

N/A 

0 (0) 

N/A 

0 

PT - Euronext Securities Porto (T2S) 

60 (0) 

83 (-28%) 

427 (0) 

400 (+7%) 

0 (0) 

RO - Depozitarul Central (T2S) 

721 (0) 

1467 (-51%) 

103 (0) 

114 (-10%) 

2249 (0) 

1346 (+67%) 

0 (0) 

RO - SaFIR 

SE - Euroclear Sweden 

SI - KDD (T2S) 

SK - CDCP (T2S) 

UK - Euroclear UK & International 

N/A 

7 (0) 

7 (0) 

1 (1) 

N/A 

N/A 

10 (-30%) 

5 (+40%) 

0 

N/A 

N/A 

0 (0) 

0 (0) 

N/A 

0 

0 

362 (1) 

334 (+8%) 

N/A 

N/A 

N/A 

0 (0) 

0 (0) 

1 (1) 

N/A 

N/A 

0 

0 

0 

N/A 

N/A 

0 

0 (0) 

1 (1) 

N/A 

26 (-81%) 

1 (-100%) 

0 

0 

0 

0 

N/A 

0 

0 

N/A 

0 

0 

0 

N/A 

Total 

2996 (11) 

4048 -26% 

10185 (71) 

6251 +63% 

4652 (6) 

3057 +52% 

1769 (21) 

1656 +7% 

Notes:   
- The figures reported are based on information provided by the respective markets. According to this information, 19,602 disclosure requests were processed in total during the 
period from 1 July 2023 to 30 June 2024. The figures should be treated as indicative figures and may not represent the full volume of disclosure requests in each market. 
- N/A indicates that no securities falling in the scope of the given category are held by the CSD.   
- Issued in a foreign CSD refers to disclosure requests related to securities where the recipient of the disclosure request is the investor CSD. 
- Based on its local implementing regulation, KELER CSD rejects requests related to securities outside the scope of SRD II. Therefore, there are no statistics available for disclosure 
requests concerning securities outside the scope of SRD II. 
- The figures for the Swedish market only consider ISO 20022 shareholder identification disclosure requests (seev.045) requested/sent via the CSD. Other forms of reporting, e.g., 
the Swedish nominee reporting obligation, or targeted requests sent to Swedish custodians, have not been included. 
- The important increase in volume observed for requests in SRDII scope received by the Spanish CSD in its capacity as investor CSD is attributed to a new participant, CACEIS 
Bank Spain, which reported their figures (1,126 SI requests) for the first time under the CEG monitoring exercise. 
- The decrease in volumes for ATHEXCSD can be attributed to a corresponding decrease in the number of the ISINs held by ATHEXCSD in its capacity as investor CSD. 

Summary of progress   

Box 2 provides a summary of each market’s progress towards achieving 
compliance with the Market CA Standards, T2S CA Standards and the SI 
Standards over the last twelve months. 

Corporate Events Compliance Report – Executive summary and main findings 

8 

 
 
 
 
 
Box 2 
Overview of progress since last reporting cycle 

Cash 
Distri- 
butions 

Security 
Distri- 
butions 

Distri- 
butions 
with 
Options 

Manda- 
tory 
Reorga- 
nisations 

Manda- 
tory 
Reorga- 
nisations 
with 
Options 

+1 

-3 

+1 

-5 

+1 

-3 

+2 

-2 

Voluntary 
Reorga- 
nisations 

+2 

Market 

AT - OeKB (T2S) 

BE - Euroclear Bank 
(T2S) 

BE - Euroclear Belgium 
(T2S) 

BE - NBB-SSS (T2S) 

BG - BNBGSSS (T2S) 

N/A 

BG - CD AD (T2S) 

CH - SIX SIS (T2S) 

CY - Cyprus Stock 
Exchange 

CZ - CSD Prague 

+3 

+1 

+1 

+1 

N/A 

N/A 

-1 

-2 

N/A 

N/A 

+1 

+1 

+1 

-1 

+2 

+1 

-2 

+7 

+2 

N/A 

+2 

Market 
Claims 

Transfor- 
mations 

Buyer 
Protec- 
tion 

Share- 
holder 
Identifi- 
cation 

MARKET 
CA STAN- 
DARDS 

T2S CA 
STAN- 
DARDS 

SI STAN- 
DARDS 

B 

+1 

+2 

+4 

N/A 

N/A 

+7 

N/A 

+11 

B 

N/A 

N/A 

B 

N/A 

N/A 

Already 
Compliant 

N/A 

N/A 

N/A 

CZ - SKD 

-1 

N/A 

N/A 

-3 

N/A 

N/A 

N/A 

N/A 

N/A 

DE - Clearstream 
Banking Frankfurt 
(T2S) 

DK - Euronext 
Securities Copenhagen 
(T2S) 

EE - Nasdaq CSD (T2S) 

ES - Iberclear (T2S) 

FI - Euroclear Finland 
(T2S) 

FR - Euroclear France 
(T2S) 

-3 

GR - BOGS (T2S) 

GR - ATHEXCSD 

HR - SKDD (T2S) 

HU - KELER (T2S) 

IE - Euroclear Bank 
(T2S) 

IS – Nasdaq CSD 

IT - Euronext Securities 
Milan (T2S) 

LI - SIX SIS 

LT - Nasdaq CSD (T2S) 

LU - Clearstream 
Banking Luxembourg 

LU - LuxCSD (T2S) 

LV - Nasdaq CSD (T2S) 

MT - Malta Stock 
Exchange (T2S) 

NL - Euroclear 
Nederland (T2S) 

NO - Euronext 
Securities Oslo 

PL - KDPW 

Already 
Compliant 

Already 
Compliant   

Already 
Compliant 

Already 
Compliant 

Already 
Compliant 

Already 
Compliant 

+1 

-2 

N/A 

N/A 

N/A 

Already 
Compliant 

Already 
Compliant 

N/A 

-1 

-2 

-1 

-1 

-5 

-1 

-1 

-1 

-1 

+1 

+1 

+2 

+1 

+1 

+2 

+1 

+2 

+1 

+1 

N/A 

Already 
Compliant 

N/A 

N/A 

N/A 

Already 
Compliant 

Already 
compliant 

Already 
Compliant 

Already 
Compliant 

Already 
Compliant 

N/A 

Already 
Compliant 

Already 
Compliant 

Already 
Compliant 

Already 
Compliant 

Already 
compliant 

Already 
Compliant 

N/A 

N/A 

R 

N/A 

N/A 

-5 

-1 

Corporate Events Compliance Report – Executive summary and main findings 

9 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cash 
Distri- 
butions 

Security 
Distri- 
butions 

Distri- 
butions 
with 
Options 

Manda- 
tory 
Reorga- 
nisations 

Market 

Manda- 
tory 
Reorga- 
nisations 
with 
Options 

Voluntary 
Reorga- 
nisations 

Market 
Claims 

Transfor- 
mations 

Buyer 
Protec- 
tion 

Share- 
holder 
Identifi- 
cation 

MARKET 
CA STAN- 
DARDS 

T2S CA 
STAN- 
DARDS 

SI STAN- 
DARDS 

PL - SKARBNET4 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

PT - Euronext 
Securities Porto (T2S) 

RO - Depozitarul 
Central (T2S) 

RO - SaFIR 

SE - Euroclear Sweden 

-1 

N/A 

N/A 

-1 

N/A 

-2 

N/A 

-3 

-2 

SI - KDD (T2S) 

SK - CDCP (T2S) 

UK - Euroclear 
UK&International 

-1 

N/A 

N/A 

Already 
Compliant 

R 

Already 
Compliant 

Already 
Compliant 

N/A 

N/A 

N/A 

Already 
compliant 

Already 
Compliant 

Already 
compliant 

Already 
Compliant 

Already 
Compliant 

-21 

-22 

-4 

-23 

-28 

-26 

-10 

-12 

-12 

N/A 

R 

N/A 

N/A 

Notes: 
- The table shows the absolute change in compliance since the 2023 Corporate Events Compliance Report for each standard category. The last three columns show which markets 
were already compliant or have reached overall compliance (‘B’) with the Market CA Standards, the T2S CA Standards and the SI Standards this year and which markets are no 
longer fully compliant (‘R’). 

Overall status of compliance 

In total, eight markets (out of 40) are fully compliant with the Market CA 
Standards, fifteen markets (out of 28) are fully compliant with the T2S CA 
Standards and ten markets (out of 31) are fully compliant with the SI Standards 
(as illustrated in the last three columns in the table in Box 3). 

Box 3 
Overview of overall compliance status per market 

Cash 
Distri- 
butions 

Security 
Distri- 
butions 

Distri- 
butions 
with 
Options 

Mandatory 
Reorgs 
with 
Options 

Mandatory 
Reorgs 

Market 

Voluntary 
Reorgs 

Market 
Claims 

Transfor- 
mations 

Buyer 
Protection 

Share- 
holder 
Identifi- 
cation 

MARKET 
CA STAN- 
DARDS 

T2S CA 
STAN- 
DARDS 

SI STAN- 
DARDS 

AT - OeKB (T2S) 

100% 

100% 

100% 

100% 

100% 

100% 

89% 

100% 

100% 

90% 

B 

R-? 

R-? 

BE - Euroclear Bank 
(T2S) 

83% 

73% 

83% 

BE - EBe (T2S) 

100% 

100% 

100% 

BE - NBB-SSS (T2S) 

100% 

100% 

BG - BNBGSSS (T2S) 

86% 

BG - CDAD (T2S) 

92% 

N/A 

95% 

CH - SIX SIS (T2S) 

100% 

100% 

91% 

64% 

N/A 

92% 

21% 

55% 

86% 

CY - CSE 

CZ - CSD Prague 

CZ - SKD 

DE - CBF (T2S) 

DK - Euronext 
Securities 
Copenhagen (T2S) 

78% 

96% 

100% 

89% 

96% 

100% 

91% 

48% 

61% 

79% 

79% 

85% 

N/A 

96% 

96% 

93% 

21% 

N/A 

N/A 

N/A 

67% 

83% 

0% 

0% 

N/A 

N/A 

92% 

92% 

81% 

31% 

N/A 

85% 

4% 

15% 

0% 

100% 

R-? 

R-Q1 2026 

B 

100% 

100% 

100% 

94% 

67% 

R-? 

R-? 

R-Q4 2025 

88% 

100% 

100% 

100% 

N/A 

R-Q4 2026 

B 

N/A 

27% 

96% 

0% 

N/A 

N/A 

R-Q4 2025  R-Q1 2026 

N/A 

100% 

94% 

100%  R-Q1 2025  R-Q2 2025 

B 

100% 

92% 

100% 

0% 

0% 

N/A 

0% 

0% 

0% 

0% 

0% 

N/A 

N/A 

62% 

95% 

N/A 

R-? 

R-? 

R-? 

R-? 

R-? 

R-? 

B 

R-? 

R-? 

N/A 

N/A 

R-? 

N/A 

R-Q2 2025 

N/A 

R-? 

B 

B 

B 

N/A 

R-? 

R-? 

R-? 

R-? 

R-? 

B 

B 

B 

R-Q4 2025 

N/A 

86% 

90% 

95% 

100% 

83% 

100% 

96% 

100% 

75% 

100% 

100% 

90% 

96% 

95% 

50% 

96% 

96% 

92% 

100% 

100% 

100% 

EE - Nasdaq CSD (T2S) 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

ES - Iberclear (T2S) 

96% 

FI - EFi (T2S) 

FR - EF (T2S) 

88% 

83% 

91% 

91% 

67% 

0% 

100% 

100% 

91% 

87% 

96% 

82% 

93% 

100% 

85% 

92% 

92% 

100% 

100% 

100% 

0% 

100% 

100% 

100% 

R-? 

R-Q4 2029 

B 

100% 

100% 

100% 

67% 

GR - BOGS (T2S) 

100% 

N/A 

N/A 

100% 

100% 

100% 

100% 

100% 

100% 

N/A 

Corporate Events Compliance Report – Executive summary and main findings 

10 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Cash 
Distri- 
butions 

Security 
Distri- 
butions 

Distri- 
butions 
with 
Options 

Mandatory 
Reorgs 
with 
Options 

Mandatory 
Reorgs 

Market 

Voluntary 
Reorgs 

Market 
Claims 

Transfor- 
mations 

Buyer 
Protection 

Share- 
holder 
Identifi- 
cation 

MARKET 
CA STAN- 
DARDS 

T2S CA 
STAN- 
DARDS 

SI STAN- 
DARDS 

GR - ATHEXCSD 

100% 

100% 

83% 

25% 

91% 

88% 

86% 

27% 

73% 

86% 

33% 

83% 

0% 

0% 

83% 

100% 

100% 

91% 

35% 

83% 

87% 

93% 

29% 

75% 

89% 

88% 

92% 

19% 

85% 

88% 

0% 

0% 

7% 

0% 

0% 

0% 

0% 

76% 

R-? 

N/A 

R-? 

100% 

R-? 

R-Q2 2025 

B 

92% 

100% 

86% 

R-Q4 2025  R-Q4 2025  R-Q4 2025 

4% 

15% 

0% 

100% 

100% 

100% 

0% 

N/A 

R-? 

R-Q1 2026 

R-? 

R-? 

N/A 

N/A 

HR - SKDD (T2S) 

HU - KELER (T2S) 

IE - Euroclear 
Bank(T2S) 

IS - Nasdaq CSD 

IT - Euronext Securities 
Milan (T2S) 

96% 

95% 

83% 

96% 

96% 

96% 

100% 

100% 

100% 

86% 

R-Q1 2026 

B 

R-Q1 2026 

LI - SIX SIS 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

92% 

100% 

100% 

LT - Nasdaq CSD 
(T2S) 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

90% 

B 

B 

LU - CBL 

75% 

86% 

67% 

87% 

LU - LuxCSD (T2S) 

100% 

100% 

100% 

100% 

82% 

93% 

81% 

92% 

0% 

0% 

100% 

100% 

8% 

0% 

LV - Nasdaq CSD 
(T2S) 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

MT - MSE (T2S) 

71% 

68% 

83% 

70% 

75% 

77% 

100% 

100% 

100% 

NL - ENL (T2S) 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

NO - Euronext 
Securities Oslo 

PL - KDPW 

PL - SKARBNET4 

PT - Euronext Securities 
Porto (T2S) 

50% 

88% 

N/A 

88% 

RO - Dep. Cen. (T2S) 

92% 

RO - SaFIR 

91% 

SE - Euroclear Sweden 

75% 

45% 

86% 

N/A 

86% 

95% 

N/A 

64% 

50% 

83% 

N/A 

83% 

67% 

N/A 

67% 

30% 

83% 

88% 

87% 

91% 

89% 

65% 

32% 

79% 

N/A 

89% 

96% 

N/A 

64% 

35% 

81% 

N/A 

88% 

69% 

N/A 

62% 

R-? 

B 

B 

N/A 

R-? 

R-? 

0% 

R-? 

100%  R-H2 2025  R-H2 2025 

B 

90% 

95% 

43% 

B 

R-? 

B 

B 

B 

B 

95% 

R-Q3 2026 

N/A 

95% 

N/A 

R-? 

R-? 

R-? 

R-? 

R-? 

R-? 

R-? 

N/A 

B 

B 

N/A 

R-? 

B 

B 

N/A 

N/A 

B 

B 

N/A 

B 

B 

0% 

30% 

N/A 

0% 

8% 

0% 

0% 

0% 

N/A 

100% 

100% 

100% 

95% 

R-Q4 2025 

100% 

100% 

100% 

100% 

R-? 

13% 

40% 

44% 

8% 

N/A 

92% 

81% 

N/A 

R-Q4 2025 

N/A 

R-? 

B 

SI - KDD (T2S) 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

100% 

SK - CDCP (T2S) 

UK - Euroclear UK&Int 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

100% 

100% 

100% 

100%  R-Q1 2026 

0% 

0% 

0% 

N/A 

R-? 

N/A 

N/A 

Notes: 
- For the non-T2S markets, the “Buyer Protection” standards compliance rate is obtained by choosing the higher of the “Manual Buyer Protection” and the “Automatic Buyer 
Protection” standards compliance rate.   
- In the case of the T2S CA Standards, a four-colour methodology (‘blue’, ‘green’, ‘yellow’, ‘red’) is used for the assessment of markets migrating to T2S if the target date for 
compliance has not yet been reached.   
- Liechtenstein is a non-T2S market. However, Liechtenstein securities are issued in SIX SIS (which is a T2S CSD) and thus the T2S CA Standards are applied as best market 
practice. 
- Calculation method: the percentage for each set of standards indicates the ratio between the number of standards that have been fully implemented and the total number of 
applicable standards (e.g. if a set of standards includes 11 standards and one of them is not applicable to a specific entity, and that entity reported an implementation level of 100%, 
fully implemented, for seven of the 10 applicable standards and any other value (0%, 25%, 50% or 75%) for the other three, the overview table will indicate an overall compliance 
level of (1*7 + 0*3)/10 = 70% for that specific entity and set of standards). 
- In recognition of the fact that market claims and transformations are not executed at all for cross-CSD transactions taking place between Euroclear Bank and Clearstream Banking 
Luxembourg via the so-called ‘Bridge’, the CEG agreed to limit all the “Market Claims” and “Transformations” standards compliance rates of Euroclear Bank and Clearstream Banking 
Luxembourg to a maximum of 75%. 
- Euroclear Bank will support settlement in central bank money (in T2S) and in commercial bank money (outside T2S). Euroclear Bank is therefore assessed against both the T2S CA 
Standards and the Market CA Standards for “Market Claims”, “Transformations” and “Buyer Protection”. The percentage figures and implementation deadline shown in Box 3 reflects 
Euroclear Bank’s compliance status vis-à-vis the T2S CA Standards. For more details on Euroclear Bank’s compliance with the Market CA Standards, please refer to section 3. 

Outlook for 2025 

The CEG will further analyse some of the issues identified in the course of this 
year’s compliance exercise as part of its 2025 work programme. Areas identified 
for further improvement during the current monitoring exercise will also be taken into 
account in the 2025 CEG monitoring exercise. Other planned work items for 2025 
include: 

Corporate Events Compliance Report – Executive summary and main findings 

11 

 
 
•  Onboarding other corporate event standards6  in the scope of the CEG’s 

work and initiating work on the subsequent creation of a single rulebook for 
corporate events in Europe.   

• 

• 

• 

• 

Assessing the impact of the shortening of the settlement cycle on the 
processing of corporate events in view of the proposed move to T+1 in 
Europe by October 2027.   

Tackling long-standing cases of non-compliance with a view to (i) identifying 
the nature of the barrier to achieving full compliance (e.g. legal, technical, etc.) 
and (ii) inviting the relevant market to put a concrete plan in place to address 
this gap. 

Analysing specific issues identified in the monitoring exercise including, 
but not limited to, (i) the application of key dates on structured products (ii) 
potential legal barriers to the processing of reversals and (iii) the processing of 
market claims in direct holding markets, including the tax treatment of such 
claims. 

Analysing potential recommendations by the European Commission for 
future improvements to the Shareholder Rights Directive and supporting 
AMI-SeCo in any communication with EU authorities on this topic. 

Structure of this report 

The report is structured as follows: 

• 

• 

• 

• 

• 

Section 1 provides information on the scope of the monitoring exercise and 
describes the procedures and methodology employed in the production of this 
report. 

Section 2 contains a summary of the key takeaways per market based on the 
Self-Assessment Reports provided by each AMI-SeCo National Stakeholder 
Group (NSG) and the subsequent assessment of these reports by the AMI-
SeCo CEG. 

Section 3 provides a detailed overview of the current status of compliance with 
the individual standards covered by the AMI-SeCo’s CEG. For each standard 
where full compliance has not yet been achieved, an explanation of the current 
status is provided together with details of the planned implementation date. 

Annex 1 provides details on the reporting entities for each market. 

Annex 2 provides details on the colour coding used in this report. 

6    This includes the definition and maintenance of the Market Standards for Corporate Actions Processing 

as well as the definition, maintenance and monitoring of the SCoRE Corporate Actions Standards and 
the Market Standards for General Meetings. 

Corporate Events Compliance Report – Executive summary and main findings 

12 

 
 
 
1 

Introduction 

Each year the Advisory Group on Market Infrastructures for Securities and Collateral 
(AMI-SeCo) organises a compliance monitoring exercise in order to assess current 
levels of compliance with corporate events standards in Europe. The survey is 
organised via the AMI-SeCo National Stakeholder Groups (NSGs) (or that market’s 
equivalent working group) established in each market. The results of the compliance 
monitoring exercise are then assessed by AMI-SeCo’s Corporate Events Group 
(CEG) and the results are made publicly available in AMI-SeCo’s Corporate Events 
Compliance Report (this report). 

This report contains an assessment of compliance with the: 

•  Market Standards for Corporate Actions Processing7  (Market CA Standards) – 

the Market CA Standards are relevant to all markets in the EEA, Switzerland 
and the United Kingdom. 

• 

T2S Corporate Actions Standards8  (T2S CA Standards) – the T2S CA 
Standards are relevant for (i) all markets that have migrated to TARGET2-
Securities (T2S) and (ii) markets that intend to migrate to T2S. 

•  Market Standards for Shareholder Identification9  (SI Standards) – the SI 

Standards are currently relevant to all markets in the EEA. 

The report has been prepared by the AMI-SeCo CEG based on the results of a 
compliance monitoring exercise that took place during the third quarter of 2024 and 
focuses on market developments during the period from September 2023 to 
September 2024. 

1.1 

Procedures 

In the survey, each market was invited to indicate the level of compliance with all 
applicable standards. Where compliance with the standard was not yet achieved, 
each market was asked to provide further information on the barriers to 
implementation (if any) together with details of the market’s progress towards 
achieving compliance since the previous monitoring exercise. Information on the 
market’s implementation plans and related milestones was also requested. Based on 
these responses, the CEG prepared a draft assessment of the compliance status of 
each market. This report presents the results of this assessment. 

7    Market Standards for Corporate Actions Processing. 
8    The T2S Corporate Actions Standards comprise the T2S Market Claims Standards, the T2S 

Transformations Standards and the T2S Buyer Protection Standards. 

9    Market Standards for Shareholder Identification. 

Corporate Events Compliance Report – Introduction 

13 

 
 
 
1.2 

Methodology 

This report assigns consistent colour coding to the assessment of compliance with 
the three sets of standards covered in this report. In accordance with the standard 
AMI-SeCo methodology, blue is assigned to those standards where full compliance 
has been achieved, while red is assigned if compliance has not yet been achieved. 
In the case of the T2S CA Standards, if the target date for compliance has not yet 
been reached (i.e. the market has not yet migrated to T2S) then a yellow or green 
status is also possible.10  In certain instances, a “not applicable” (N/A) status can be 
assigned if the scope of the standards is broader than the scope of activities covered 
by the monitored entity. For example, if the scope of a CSD’s activities is limited to 
debt instruments, then standards only relevant to equities will be deemed not 
applicable. Please refer to Annex 2 for further details. 

10    The T2S CA Standards are relevant to markets which have (i) joined T2S or (ii) plan to join T2S. If a 

market does not plan to join T2S, it is assessed against the Market Claims, Transformations and Buyer 
Protection Standards set out in the Market CA Standards. 

Corporate Events Compliance Report – Introduction 

14 

 
 
 
2 

Key takeaways per market 

This section provides a summary of the key takeaways per market based on the 
Self-Assessment Reports provided by each AMI-SeCo NSG and the subsequent 
assessment of these reports by the AMI-SeCo CEG. For each market, a separate 
summary is provided for: 

• 

CA Standards (this covers the Market CA Standards and, if applicable, the T2S 
CA Standards) 

• 

SI Standards (this covers the SI Standards only). 

Austria (OeKB) 

CA Standards 

One of the main gaps in compliance, relating to the notification of events by issuers 
where some issuers/paying agents do not deliver the information in the prescribed 
way for dividends and corporate actions, has been addressed in the period under 
review. In addition, the CEG assessed the Austrian market as being compliant with 
two standards relating to the usage of unique identifiers for options in corporate 
action events, resulting in the Austrian achieving full compliance with the Market CA 
Standards (in cases where the unique identifier is not provided by the issuer, the 
unique identifier will be set by the CSD; the CEG deemed this practice to be 
compliant with the standards). 

Three gaps remain in the area of market claims: 1) the ex-cum indicator is not being 
used, 2) delayed settlement of market claims and 3) the absence of a user-friendly 
facility for market claims. As yet, the market has no plans in place to address these 
gaps. The Austrian market is invited to provide a concrete adaptation plan in 2025 to 
address these gaps. 

SI Standards 

Regarding SI Standards, some issues were identified in relation to (i) issuers setting 
a response deadline which is less than ten business days after the date of the SI 
request and (ii) some clients not yet being able to process SI requests in ISO 20022 
format. Issues with the definition of the date from which the shares have been held 
were resolved during the period under review. 

A potential non-compliance case was reported by a foreign market in relation to 
Standard 3.1 in which the respondent stated that the use of closed user groups 
(CUGs) at issuer CSD level was creating connectivity issues. In response the 
Austrian NSG explained that the channel for issuers/issuer agents to submit 

Corporate Events Compliance Report – Key takeaways per market 

15 

 
 
disclosure requests to the CSD is exclusively FinPlus. The address defined in the 
disclosure request to submit the disclosure request response is never that of the 
CSD. Accordingly, the disclosure request responses are never submitted to the CSD 
and therefore any party in the custody chain has the capability to respond to the 
address defined in the disclosure request (intermediaries do not have to send 
disclosure request responses via a CUG). Based on the explanation provided, the 
CEG reconfirmed its previous assessment that there is no barrier to open 
communication in the Austrian market. Other requirements of Standard 3.1 are 
nevertheless not followed by all issuers in the Austrian market, and compliance with 
the standard was accordingly revised downwards. 

Belgium (Euroclear Bank) 

CA Standards 

In the field of corporate actions, little progress has been observed since last year. 
However, Euroclear Bank has plans in place to address the majority of the remaining 
gaps by 2029 as part of its Asset Servicing Modernisation Project. The Asset 
Servicing Modernisation Project is comprised of several phases. In 2024/2025 proxy 
voting events will migrate to ISO 20022. This will be followed by the migration of 
mandatory securities events (in Q1 2026), mandatory cash events (in 2028) and 
voluntary events (in 2029). Concrete implementation dates for the implementation of 
standards on market claims, transformations and buyer protection are not yet 
available. The CEG highlighted the need for more detailed information on the 
implementation roadmap in due course to allow market participants to plan 
implementation on their side accordingly.   

With regard to corporate actions on flow, Euroclear Bank is assessed against both 
the T2S CA Standards and the Market CA Standards for market claims, 
transformations and buyer protection in recognition of the fact that Euroclear Bank 
will continue to support settlement in commercial bank money (i.e. outside T2S) 
following its migration to T2S. In line with Euroclear Bank’s phased migration plan for 
joining T2S, the T2S CA Standards will become relevant once Euroclear Bank 
enables intra-CSD settlement in T2S. Euroclear Bank confirmed its plans to reach 
full compliance with the T2S CA Standards (on market claims, transformations and 
buyer protection) by the start of the intra-CSD settlement phase, currently planned 
for January 2026. 

SI Standards 

Regarding SI Standards, Euroclear Bank reported receiving a limited number of 
disclosure requests in the period under review (all received from a single issuer 
agent, appointed by one issuer). 

Corporate Events Compliance Report – Key takeaways per market 

16 

 
 
Belgium (Euroclear Belgium) 

CA Standards 

As in previous years, the main gap observed relates to the processing of capital 
increase events (which occur once or twice a year), which are not processed in 
accordance with the standards. Although the CSD is technically ready to support 
standard-compliant processing, a market change is required, but, for commercial 
reasons, issuer agents are not willing to change Belgian market practice. No specific 
action plan is currently being considered. Another gap is observed in relation to 
payments in securities, which are made after the opening of the settlement system 
on the payment date. This resulted in six standards being assessed as non-
compliant. 

SI Standards 

Regarding SI Standards, the market had previously experienced some issues with 
the use of email for the processing of SI requests; some of these issues were no 
longer observed in the period under review resulting in an increased level of 
compliance with the standards. The Euroclear Belgium procedure of systematically 
sending SI requests to all CSD participants without considering whether those 
parties held the position on the record date was assessed as not in line with the 
standards. The market was therefore assessed as not compliant with Standards 1.8a 
to 1.8e. Euroclear Belgium acknowledges the issue and has a plan in place to 
resolve the issue in 2025. 

Belgium (NBB-SSS) 

CA Standards 

NBB-SSS demonstrated high-levels of compliance overall. A few gaps were 
observed, which are planned to be addressed by November 2026 (twelve months 
later than previously foreseen). 

SI Standards 

SI Standards are not applicable as NBB-SSS does not handle equities. 

Corporate Events Compliance Report – Key takeaways per market 

17 

 
 
Bulgaria (BNBGSSS) 

CA Standards 

A few gaps in compliance with the Market CA Standards exist, which are now 
expected to be resolved by end 2025 (one year later than originally planned). With 
regard to corporate actions on flow, BNBGSSS was assessed against the T2S CA 
Standards for the second time following its migration to T2S in September 2023. 
Although low levels of compliance were observed, it is noted that full compliance with 
these standards is foreseen by the first quarter of 2026 (later than the previously 
communicated date of end 2024). 

SI Standards 

The SI Standards are not relevant to BNBGSSS as the scope of its activities is 
limited to debt instruments. 

Bulgaria (CDAD) 

CA Standards 

CDAD provided a detailed report on the current status of implementation in the 
Bulgarian market and a plan is in place to address the majority of gaps by the end of 
2024. It is noted that the main barriers are of a technical rather than a legal nature. 
With regard to corporate actions on flow, CDAD was assessed against the T2S CA 
Standards for the second time following its migration to T2S in September 2023. As 
in the previous year, full compliance with the transformation standards was reported. 
High levels of compliance with the market claims and buyer protection standards 
were observed with full compliance with these standards expected in the first half of 
2025. 

SI Standards 

Seven additional standards were implemented in the last twelve months, resulting in 
CDAD achieving full compliance with the SI Standards.   

Corporate Events Compliance Report – Key takeaways per market 

18 

 
 
Croatia (SKDD) 

CA Standards 

No changes in compliance with the Market CA Standards were observed in the last 
twelve months. Further IT system upgrades are planned by the end of the third 
quarter of 2025 which will address the majority of the remaining gaps.   

SKDD joined T2S in September 2023. SKDD was thus assessed against the T2S CA 
Standards for the second time with regard to the processing of corporate actions on 
flow. Although zero compliance with the applicable standards was reported, a plan is 
in place to achieve full compliance with the T2S CA Standards in the first half of 
2025. 

SI Standards 

Compliance with the SI Standards was again assessed at 100% this year following 
the closure of the previously outstanding gaps during 2023.   

Cyprus (Cyprus Stock Exchange) 

CA Standards 

The Cyprus AMI-SeCo NSG reported increases in compliance with several 
standards during the period under review which can be largely attributed to the 
implementation of new CSD software.   

SI Standards 

For the SI Standards, some important increases in compliance were observed year 
on year. However, not all shareholder identification requests are transmitted in an 
electronic form. As a result, the CEG agreed to revise downwards the status of 
compliance of all impacted SI Standards (Standard 1.4, 1.5, 1.6, 1.9, 1.10, 3.3 and 
3.4). 

Czech Republic (SKD) 

CA Standards 

Security Distributions, Distributions with Options, Mandatory Reorganisations with 
Options and Buyer Protection were reported as being not applicable, as such 

Corporate Events Compliance Report – Key takeaways per market 

19 

 
 
processes are deemed not applicable to the instruments handled by SKD. 100% 
compliance with the applicable standards was reported in the Self-Assessment 
Report. A number of gaps were identified by the CEG, however, which resulted in 
the compliance status being revised downwards. The CEG noted that the 
Transformations Standards were marked as not applicable in the Self-Assessment 
Report, while these standards would be relevant to the processing of redemptions 
(which are understood to be processed by SKD). SKD explained that only one type 
of corporate action – redemption of securities – exists in the SKD system. At the end 
of the maturity date, the SKD system deletes the securities from its records and as a 
result these securities cease to exist. There are no transformation options, and a 
change of redemption date is not allowed by the SKD system. The SKD system does 
not allow participants to send instructions for settlement on or after the redemption 
date. Based on the additional explanations provided, the CEG confirmed the 
applicability of the Transformation Standards to SKD and invited SKD to put a plan in 
place to support the processing of transformations. 

Regarding the processing of cash distributions, interest payments are not processed 
separately from redemptions when the payment date of interest payments and 
redemptions coincide. This is not compliant with the standards. The CEG agreed to 
revise downwards the status of compliance with Cash Distributions Standard 18 and 
Mandatory Reorganisations Standard 15 accordingly. 

SI Standards 

The SI Standards are not relevant to SKD as the scope of its activities is limited to 
debt instruments. 

Czech Republic (CSD Prague) 

CA Standards 

In general, low levels of compliance were observed across all categories of 
corporate actions standards. While plans to implement certain standards in the 
context of the work of Czech markets on the SCoRE initiative are welcomed, it is 
noted that no plan is in place to address many of the remaining gaps. The CEG 
considers that the lack of a plan to address these gaps is problematic and that 
further efforts are needed to engage with the Czech market on this topic. 

SI Standards 

For the SI Standards, gaps remain in respect of one standard (1.8d) where SI 
requests are transmitted only to “holding” intermediaries – pending transactions are 
thus not reflected. New holding intermediaries are informed on the record date. A 
plan is in place to address this gap by the end of the second quarter of 2025. It is 

Corporate Events Compliance Report – Key takeaways per market 

20 

 
 
also noted that in the Czech market the account holder is considered to be the 
shareholder. Accordingly, SI information is only provided by (i) the CSD or (ii) a 
custodian holding an account in the CSD. 

Denmark (Euronext Securities Copenhagen) 

CA Standards 

Regarding corporate actions standards, a small number of gaps were reported which 
the Danish market plans to address in the context of the implementation of the 
SCoRE Standards. However, one gap remains for which no implementation plan has 
been devised. The Danish CSD reports that it has been asked not to implement the 
Distributions with Options standards for investment funds (the standards are 
implemented for other instrument types) by some of its market participants, as these 
participants consider that, for the processing of a DVOP event, payment in 
accordance with the standard would delay the cash payment by two weeks 
compared to the existing solution in the Danish market. It is understood that this 
stance may change in the future, as the implementation of the SCoRE Rulebook is 
triggering a wider review of CA processing in the Danish market. The Danish NSG is 
invited to review its stance on this matter and to devise an implementation plan to 
address the remaining gap. 

SI Standards 

Regarding SI Standards, a status of 100% compliance was reported. A number of SI 
requests have been received in practice and the Danish market has reported that the 
process is working well so far. As in previous years, the status of compliance with 
Standards 3.1, 3.4 and 3.5 was revised downwards however to take into account 
missing responses to disclosure requests.   

Some foreign intermediaries reported obstacles to accessing the market as Euronext 
Securities Copenhagen has not developed functionality allowing an issuer or issuer 
agent to submit a disclosure request using an ISO 20022 message. The CEG did not 
consider this to be a case of non-compliance with the standards, however, as this 
setup does not prevent the issuer or its agent from submitting a disclosure request in 
electronic form. The CEG will continue to monitor this topic. 

Furthermore, the CEG noted that Denmark and the other Nordic markets (Finland, 
Norway and Sweden) are direct-holding markets, meaning that (domestic) end 
investors may (or must, in Finland and Norway) have direct accounts in the CSD. 
The Danish CSD requires all issuers (issuing securities in the Danish CSD) to 
appoint an issuer agent. The issuer agent must be a participant in the CSD, holding 
the role of issuer agent (among other roles such as account operator). The issuer 
agent acts as the interface between the CSD and the issuer, for example, issuance, 
corporate actions and general meeting notifications/meeting services. The issuer 

Corporate Events Compliance Report – Key takeaways per market 

21 

 
 
agent is also the only party that can, on behalf of the issuer of shares listed on a 
regulated market, request the CSD to send a shareholder identification disclosure 
request. The issuer agent does so via the CSD’s portal. As the agent is appointed by 
the issuer, it is also authorised to initiate an SI request, and the CSD does not need 
to verify with the issuer – removing the need for a separate process (such as the 
provision of letter of authorisation). In Denmark, the CSD account structure and lack 
of the distinction between owner and nominee accounts has resulted in CSD 
participants with the role of account controller (account operator in the other three 
Nordic markets) responding to a disclosure request for all CSD accounts opened 
under their participant ID. It is noted that while the CSD could do the same, there 
would be enormous overlap between the reporting making the process of 
reconciliation for the disclosure response agent very difficult (or at least requiring a 
process specific to Denmark).   

Estonia (Nasdaq CSD) 

CA Standards 

Regarding corporate actions standards, full compliance was reported for the second 
consecutive year following the resolution of a number of gaps related to the 
processing of reversals during 2023. 

SI Standards 

Regarding SI Standards, the CSD does not impose any limits on the number of days 
in the past or in the future for which SI requests may be submitted. Although the law 
does not impose any limits, the Standards were designed to be more restrictive than 
the law in order to encourage best practice among issuers. The absence of a 
safeguard at CSD level to enforce compliance with the Standards may give rise to 
cases of non-compliance. 

Finland (Euroclear Finland) 

CA Standards 

Following its migration to T2S in September 2023, Euroclear Finland was again 
assessed as 100% compliant with the T2S CA Standards for transformations and 
buyer protection. Compliance with the market claims standards was assessed at 
zero per cent however as, although a mechanism for market claims is implemented 
in the CSD system, dividends (which represent the majority of CAs in Finland) are 
paid in commercial bank money outside the CSD system and hence are excluded 
from market claims detection.   

Corporate Events Compliance Report – Key takeaways per market 

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Discussions in the Finnish market are ongoing on the implementation of a standards 
compliant processing mechanism, but several challenges have been identified. Due 
to the Finnish market structure, all end investor accounts are held in the CSD 
system. As a result, dividend payments also need to be processed via the CSD 
whereby tax should be withdrawn individually according to the tax set-up of each 
account. At the time of market claim creation, the same tax process should be 
applied. This causes an issue since the seller and buyer may not have the same tax 
status but possible differences in the tax amount would need to be processed 
according to the law. There is no withholding agent involved and the tax would be 
withheld at the time of payment. Bank of Finland has established a working group to 
elaborate a future model which enables the payment of dividend payments in central 
bank money and the processing of market claims in a compliant manner. Although 
the working group has made limited progress to date, the discussions on the 
implementation of a standards compliant processing mechanism are planned to 
continue in 2025. The CEG stresses the importance of implementing these 
standards and will continue to monitor progress on this topic and provide support to 
the Finnish market where relevant. 

The market also reports legal barriers to reversing processed payments. This 
creates significant issues in the event that a reversal is needed as the recipient of 
the payment is under no obligation to return the cash proceeds. The CEG noted that 
challenges with reversals have been identified in other Nordic markets and will 
investigate this topic further.   

SI Standards 

Regarding SI Standards, the CEG noted that Finland and the other Nordic markets 
(Denmark, Norway and Sweden) are direct-holding markets, meaning that 
(domestic) end investors may (or must, in Finland and Norway) have direct accounts 
in the CSD. In Finland (and also Norway and Sweden), the issuer has a legal right to 
receive the register from the CSD. The Finnish NSG explained that Euroclear 
Finland therefore does not respond to requests as first intermediary because issuers 
have access to shareholder data in the Euroclear Finland system and thus they 
directly monitor registered shareholders of the company whenever necessary without 
need to initiate a shareholder identification disclosure. For shares, the issuer has a 
direct contractual relationship with the Finnish/Swedish CSD and is able to order the 
creation and processing of various corporate events, including general meetings, 
and shareholding identification disclosure requests via the CSD’s portal. While an 
issuer can also appoint an issuer agent to perform these actions on its behalf, this is 
not common practice in the Finnish market (for bonds and warrants however, it 
should be noted that the Finnish CSD requires issuers to appoint an issuer agent). 
The CEG agreed that this behaviour is compliant as the issuer has access to the 
shareholder information.   

The CEG also noted that a number of paper requests are received in the Finnish 
market also. Paper requests are deemed to be inconsistent with the objectives of the 
SI Standards and the European Commission’s work on digitalisation. It was also 

Corporate Events Compliance Report – Key takeaways per market 

23 

 
 
noted that the Implementing Regulation states that requests should be machine 
readable, which cannot be achieved with paper requests. Handling of paper-based 
requests may also give rise to concerns over the security of the transmission of 
responses. 

France (Euroclear France) 

CA Standards 

In the field of corporate actions, a number of non-compliance cases identified in 
previous Corporate Events Compliance Reports continue to persist. In particular, late 
payments continue to be a problem in the French market. This issue is considered to 
be of a structural nature with late payments resulting from the reliance on batch 
processing in payment systems for the transfer of cash proceeds to the issuer CSD. 
While efforts have been undertaken to limit the number of late payments, a sizable 
number of late payments are still observed. Further work is therefore needed in this 
area in order to permanently resolve this issue. In addition, the French market 
reported lower levels of compliance with two Voluntary Reorganisations standards, 
resulting in a slight decrease in the overall level of compliance.   

SI Standards 

Regarding SI Standards, relatively high levels of compliance were observed. Some 
intermediaries are not yet able to process requests in the ISO 20022 format, 
however, which is creating issues and impeding the ability to process such requests 
on a straight-through-processing basis. The issue of the CSD sending requests to all 
participants regardless of whether they have a holding is also noted as being a 
problem. The market was therefore assessed as not compliant with Standards 1.8a 
to 1.8e. Euroclear France acknowledges the issue and plans to address it by end 
2025 (one year later than originally planned). 

Germany (Clearstream Banking Frankfurt) 

CA Standards 

Regarding corporate actions standards, no changes in compliance were observed 
this year. Work is underway to address the gaps in compliance with the key dates for 
cash distributions: 

• 

For interest payments on unit-based instruments, compliance with the key dates 
was originally expected in 2024 but further discussions between Clearstream 
Banking Frankfurt and the national data provider are now required before 
determining a new target date for implementation.   

Corporate Events Compliance Report – Key takeaways per market 

24 

 
 
• 

For investment fund payments, a legal assessment is currently ongoing, to be 
followed by discussions with investment companies and their agents; no target 
date for achieving compliance with the key dates is has been set.   

With regard to the use of interim International Security Identification Numbers (ISINs) 
for DVOP, a number of barriers have been identified as preventing implementation. 
The German market has established a dedicated task force to further analyse this 
issue. 

As with last year, a number of non-compliance cases were reported by foreign 
markets for three standards (Cash Distributions Standards 12, 15, and 16). These 
gaps are expected to be resolved following the implementation of the 
aforementioned initiative to address the gaps in compliance with the key dates for 
cash distributions.   

SI Standards 

Two cases of non-compliance were observed concerning Standards 3.1 and 3.4 (as 
not all intermediaries down the chain are able to process the shareholder 
identification messages in an STP manner).   

Greece (ATHEXCSD) 

CA Standards 

In relation to the corporate actions standards, a number of technical and regulatory 
changes are planned by ATHEXCSD in order to implement the related standards. It 
was noted that ATHEXCSD plans to implement the Market Claims, the 
Transformations and Buyer Protection Standards by end 2025 (approximately twelve 
months later than originally planned). 

SI Standards 

Regarding SI Standards, these are assessed as being fully implemented by 
ATHEXCSD as first intermediary (issuer CSD). In its role as investor CSD, 
automated implementation by ATHEXCSD as intermediary was introduced at the 
end of 2021. Despite the 100% compliance reported in the Self-Assessment Report, 
the CEG noted that payments are withheld in the event of non-disclosure and, in this 
context, agreed that, consistent with the previous year’s CEG assessment, the level 
of compliance with SI Standards relating to the receipt of disclosure information 
should be revised downwards accordingly. 

The CEG noted that the receipt of disclosure information may be used as a basis 
and as a binding source for the release of a subsequent dividend payment in the 

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25 

 
 
Greek market. As a result of this practice, (some) investors holding securities in an 
omnibus account will not receive the dividend payments on time in cases where 
disclosure of information is not provided. Further information on the case at hand is 
provided below. 

Description of the situation 

In accordance with the Bank of Greece’s (BoG’s) articles of association, dividend 
distributions may only be paid to identified beneficial owners that are deemed eligible 
by the BoG. Related dividend payment announcements state that shareholder 
identification is a prerequisite to the smooth conclusion of the corporate event.   

BoG acts as a paying agent for its own dividend distribution and assigns ATHEXCSD 
as its Issuer Agent for the receipt and reconciliation of the intermediaries’ SI 
disclosures. After the completion of the SI request’s procedures, ATHEXCSD 
provides BoG with a file of identified shareholders plus the intermediaries’ 
disclosures received but not automatically matched by ATHEXCSD’s systems. 
Where there are omnibus accounts partially identified, BoG and ATHEXCSD initiate 
additional identification requests and communications with ATHEXCSD participants 
to achieve full identification. For the part of omnibus accounts not fully identified, 
BoG withholds payments to ATHEXCSD participants (as BoG’s articles of 
association do not allow otherwise). 

It is noted that the case of BoG is unique with regards to using SI requests as a 
prerequisite to a dividend payment and unless all intermediaries comply with the 
SRD II framework by transmitting their SI disclosures on time correctly, using the 
ISO 20022 messaging standard, it is not possible for BoG to complete all the 
payments. ATHEXCSD would like to stress the need for all intermediaries to comply 
with the SRD II framework and transmit their disclosures on time, correctly and using 
the market standards (ISO 20022 format). It is noted that ATHEXCSD is not 
responsible for the SI identification outcome and the completion of all payments, and 
the CEG acknowledges that ATHEXCSD has fully implemented the SI standards 
(including the relevant ISO20022 messages) and has in place all relevant processes 
to request the information required to process the dividend payment. 

Greece (BOGS) 

CA Standards 

BOGS was already assessed as fully compliant last year. 

SI Standards 

The SI Standards are not relevant to BOGS as the scope of its activities is limited to 
debt instruments. 

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26 

 
 
Hungary (KELER) 

CA Standards 

Regarding corporate actions standards, no changes in compliance were observed 
this year. A plan is in place to comply with remaining standards by December 2025.   

SI Standards 

For SI Standards, high levels of compliance are observed. For one standard (future 
record date), KELER complies with the standard regarding intermediaries having 
holdings in the underlying security but does not forward the request for 
intermediaries with pending transactions in the underlying security. This gap is 
planned to be addressed by December 2025. 

Iceland (Nasdaq CSD) 

CA Standards 

This is the third year in which Iceland has participated in the AMI-SeCo corporate 
events compliance monitoring exercise. The Icelandic CSD is part of the Nasdaq 
Group and therefore the Icelandic market reports similar levels of compliance as the 
Estonian, Lithuanian and Latvian markets (where Nasdaq CSD also acts as the 
issuer CSD). The primary gap in compliance concerns standards relating to the 
information flow for (I)CSD participants to end investors.   

SI Standards 

SRD II is expected to be transposed into national legislation in 2025. The SI 
Standards were therefore assessed as not applicable in the current reporting cycle. 

Ireland (Euroclear Bank) 

CA Standards 

This is the fourth year in which a separate report has been provided by the Irish 
market following the migration of Irish securities from Euroclear UK and Ireland (now 
Euroclear UK and International) to Euroclear Bank on 15 March 2021. No progress 
has been achieved in the last twelve months, with some additional gaps in 
compliance identified. The main gaps in compliance observed continue to relate to (i) 

Corporate Events Compliance Report – Key takeaways per market 

27 

 
 
a large gap between the payment date and record date for dividend payments 
(around 3 to 4 weeks) as a result of a need to print physical documentation, (ii) 
Distributions with Options – the Irish market does not issue interim securities for 
dividends with options as issuers currently do not see value in utilising an interim 
security for dividends where the rights aren’t tradeable, (iii) key buyer protection 
dates not yet notified and (iv) a number of gaps in compliance with market claims, 
transformations and buyer protections standards exist. Although gaps related to 
market claims, buyer protection and transformations are expected to be addressed 
as part of Euroclear Bank’s Asset Servicing Modernisation Programme, it is noted 
that a large number of gaps require changes in market behaviour and no plans have 
been put in place to address these gaps. The CEG consider this to be a matter of 
concern and invite the Irish market to put a concrete implementation plan in place 
(with the involvement of all relevant stakeholders) in order to address the remaining 
gaps. 

SI Standards 

For SI Standards, no information on the individual standards was provided on the 
grounds that, under existing Irish corporate law and the implementation of SRD II 
into Irish law, Euroclear Bank’s Nominee, as the person recorded in the register of 
members, is the “shareholder” for the purposes of Irish corporate securities within 
the scope of SRD II held by Euroclear Bank participants. While acknowledging that 
this was a legal barrier, the CEG agreed that the Irish market should be deemed 
non-compliant with the SI Standards. Legislative reform is required in order to ensure 
that the Irish market can adhere to the SI Standards and facilitate the implementation 
of a single European process. 

Italy (Euronext Securities Milan) 

CA Standards 

In the field of corporate actions, the main gap remaining is that CSD announcements 
are currently sent for settled positions only, thereby excluding any pending receipt 
and/or delivery that might have an impact on the eligible balance. This issue is 
planned to be resolved in the first quarter of 2026 as part of a wider review of the 
CSD’s custody platform. Regarding Distributions with Options, as previously agreed 
by the CEG, full compliance will only be possible once full compliance with the 
Security Distributions Standards has been achieved. Standard 3 of the Distributions 
with Options Standards was thus assessed as not implemented (this approach also 
resulted in the revision of the status of compliance in other markets in order to 
ensure that a consistent approach is applied across all markets). 

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SI Standards 

Regarding SI Standards, two gaps were reported to the Italian NSG both of which 
are expected to be resolved in the first quarter of 2026 following the implementation 
of ISO 20022 messaging. Regarding responses to SI requests, currently, based on 
the issuer’s request, responses to SI requests are transmitted through the custody 
chain or directly to the issuer. This is not considered to be in line with the SI 
Standards. As with last year, the CEG agreed to maintain the partial level of 
compliance with Standard 3.1.   

Latvia (Nasdaq CSD) 

CA Standards 

Regarding corporate actions standards, full compliance was reported for the second 
consecutive year following the resolution of a number of gaps related to the 
processing of reversals during 2023.   

SI Standards 

Regarding SI Standards, the CSD does not impose any limits on the number of days 
in the past or in the future for which SI requests may be submitted. Although the law 
does not impose any limits, the Standards were designed to be more restrictive than 
the law in order to encourage best practice among issuers. The absence of a 
safeguard at CSD level to enforce compliance with the Standards may give rise to 
cases of non-compliance. 

In Latvia the receipt of a disclosure response is a prerequisite for participation in a 
general meeting. As this requirement is not well known, it causes issues at investor 
level with a negative impact on investors if an intermediary does not respond. The 
Latvian CSD explained that such a requirement is fully compatible with SRD II and 
emphasised that there are still many intermediaries in the EU that do not comply with 
the obligations arising from SRD II and the SRD II Implementing Regulation to 
disclose the ultimate shareholders and that, for this reason, there is a risk that a 
shareholder will not be able to exercise his or her rights (no concrete cases linked to 
this requirement were reported in the 2024 monitoring exercise). Further information 
on this scenario is provided below. 

Description of the situation 

The issuer submits a disclosure request for the upcoming annual general meeting 
(AGM). The list of shareholders is compiled. If the shareholders’ register contains 
nominee records behind which the CSD has non-disclosed beneficial owners, then 
the voting rights of those beneficial owners will be impacted as, if one of the 
intermediaries which fails to disclose beneficial owners later sends a voting 
instruction to represent the non-disclosed beneficial owner at the issuer’s AGM, upon 

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29 

 
 
receiving the ballot, the issuer will not be able to identify the specified person as a 
shareholder, as he or she was not disclosed in the list of shareholders. For this 
reason, the shareholder will not be able to exercise his or her right to vote at the 
shareholders’ meeting. It is noted that the CSD does not have the authority to 
enforce intermediaries to disclose beneficial owners, as required by SRD II and the 
Implementing Regulation. 

Liechtenstein (SIX SIS) 

CA Standards 

High levels of compliance are observed overall, as the Liechtenstein market uses 
SIX SIS as issuer CSD. Although it is not a T2S market, as it uses SIX SIS 
infrastructure, it has adopted the T2S CA Standards as best practice. 

SI Standards 

The SI standards entered into force following the incorporation of SRD II 
requirements into the EEA Agreement from 1 October 2021 (the national 
implementing act entered into force in Liechtenstein on the same date). The 
Liechtenstein market and its actors are applying the Standards and are therefore 
assessed as being fully complaint with the SI Standards. 

Lithuania (Nasdaq CSD) 

CA Standards 

Regarding corporate actions standards, full compliance was reported for the second 
consecutive year following the resolution of a number of gaps related to the 
processing of reversals during 2023.   

SI Standards 

Regarding SI Standards, the CSD does not impose any limits on the number of days 
in the past or in the future for which SI requests may be submitted. Although the law 
does not impose any limits, the Standards were designed to be more restrictive than 
the law in order to encourage best practice among issuers. The absence of a 
safeguard at CSD level to enforce compliance with the Standards may give rise to 
cases of non-compliance. 

As in the Latvian market, the receipt of a disclosure response is a prerequisite for 
participation in a general meeting in Lithuania. As this requirement was not well 

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30 

 
 
known, it caused issues at investor level with a negative impact on investors if an 
intermediary did not respond. Please refer to the Latvian market summary for further 
details. 

Luxembourg (LuxCSD) 

CA Standards 

In relation to the corporate actions standards, the main gaps observed relate to key 
dates and buyer protection. These gaps were originally due to be addressed in the 
course of 2024 but implementation has now been deferred to 2025. 

SI Standards 

LuxCSD was deemed fully compliant with the SI Standards. 

Luxembourg (Clearstream Banking Luxembourg) 

CA Standards 

In relation to the corporate actions standards, the main gaps reported relate to 
payment times, the non-reporting of buyer protection key dates and the processing 
of market claims, transformations and buyer protection instructions. While there is a 
plan to address issues related to payment times, buyer protection key dates and the 
processing of buyer protection instructions, a plan to address gaps in the processing 
of market claims and transformations has not yet been provided. With regard to 
market claims and transformations, re-instructions on bridge transactions are 
currently not possible between Clearstream and Euroclear. This issue needs to be 
discussed between Clearstream and Euroclear with a view to putting a plan in place 
to address this gap. It is noted, however, that no progress has been made on 
resolving these issues in the last twelve months and further discussions between 
Clearstream and Euroclear are not foreseen until the end of 2024. 

Three non-compliance cases were reported by foreign markets in relation to key 
dates, which resulted in a downgrade in the status of three standards (Cash 
Distributions Standards 12, 15 and 16).   

The CEG also agreed to revise downwards the status of compliance with Cash 
Distributions Standard 14, as the payable rate for floating rate instruments is not 
always confirmed at least three days before the payment date. In addition, the status 
of compliance with several standards (Security Distributions, Mandatory 
Reorganisations, Mandatory Reorganisations with Options and Voluntary 
Reorganisations) was revised downwards as payments are made in the currency of 

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31 

 
 
the new securities (while the standards state that payments should be made in the 
original currency). 

SI Standards 

Regarding SI Standards, it is noted that Clearstream Banking Luxembourg (CBL) 
receives very few SI requests as its activities are largely focused on Eurobonds. 
Over the last twelve months, CBL did not receive any SI requests in its capacity of 
issuer CSD (to date, only one valid request has been received – in 2022 - for 
securities issued in CBL). It is noted that the default approach is to set compliance to 
zero in the absence of any reporting on the status of compliance by the respective 
entity. In light of this, CBL was encouraged to provide any information that may be 
available on the shareholder identification process irrespective of the number of 
requests received to date. The CEG noted that a significant number of requests were 
received and processed by CBL in relation to securities for which it does not act as 
issuer CSD. The successful processing of these requests is considered a positive 
indicator that the process is working correctly. 

Malta (Malta Stock Exchange) 

CA Standards 

Although full compliance with the corporate actions standards was reported in the 
Self-Assessment Report provided by the Malta Stock Exchange, the CEG, as with 
last year, identified several standards where compliance has not been achieved. 
These include Cash Distributions Standard 8, where payments are paid out directly 
by the issuer rather than via the CSD. Reversals are also not supported. Some 
standards were also incorrectly reported as not applicable (for example, on key 
dates). Further attention therefore needs to be paid to improving the accuracy of the 
self-assessment completed by the Maltese market. Against this background the CEG 
agreed to maintain the status of compliance at the levels agreed in the 2023 
exercise. The CEG noted however that plans are in place to resolve many of the 
outstanding gaps by the end of 2024 and consider this to be a positive development. 

SI Standards 

Regarding SI Standards, one gap was identified by the CEG which resulted in the 
Maltese market being assessed as non-compliant with Standard 2.2. No plan has 
been devised to address this gap. The CEG Secretariat and the Maltese sponsor will 
follow this up with the Maltese market accordingly. 

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Netherlands (Euroclear Nederland) 

CA Standards 

Euroclear Nederland reported full compliance with all corporate actions standards. 
Two potential cases of non-compliance were reported by foreign markets relating to 
certain market claims and transformations standards. The issue concerned the non-
generation of market claims and transformations for a corporate event as a result of 
the incorrect configuration of ISIN level data by the issuer CSD in T2S. The issue 
was further analysed in conjunction with the Dutch market which advised that 
Euroclear Nederland is not the issuer CSD for the ISIN, but instead acts as the 
Security Maintaining Entity (SME) for the ISIN in T2S. The CEG noted that the issue, 
which resulted in an incorrect corporate action, was due to an operational error. As 
the case was deemed to be a one-off error, the CEG agreed not to downgrade the 
status of compliance with the corporate action standards at the current juncture. The 
CEG did however note that a similar (albeit not identical) issue was observed in 2023 
for the same issuance and the same corporate event type and agreed to continue to 
monitor the issue. 

SI Standards 

Regarding SI Standards, a comprehensive report was provided by the Dutch market 
with a number of general issues identified which are also considered relevant to 
other markets. The Dutch market saw an overall increase in compliance this year. 
This increase in compliance can be at least partly attributed to the guidance provided 
by the CEG that each market should focus its reporting on requests concerning 
ISINs issued by the local CSD for the purposes of the compliance assessment. This 
could then be complemented with additional information on potential cases of non-
compliance observed on ISINs issued in a non-local CSD. Overall, the SI Standards 
process is considered to be working well in the Dutch market in respect of requests 
received from domestic participants. In the 2024 monitoring exercise it was reported 
that Dutch Issuer Agents have determined that there is no practical benefit in issuing 
shareholder identification requests with future record dates as they have 
encountered difficulties when doing so. As a result, they have chosen to discontinue 
this practice. The issues reported mainly concerned requests received from non-
domestic participants. The main issues observed include the following: 

• 

• 

A sizable number of requests and responses are not transmitted using the 
required ISO 20022 messaging format. Accordingly, the information is not 
machine-readable, necessitating manual processing with a knock-on impact on 
the timely provision of the requested data. 

Some requests transmitted directly to one or more intermediaries do not include 
all the minimum information required to process the request. 

Corporate Events Compliance Report – Key takeaways per market 

33 

 
 
• 

• 

• 

• 

• 

• 

• 

Some responses are provided late or (very) close to the deadline which poses 
difficulties in case there is a need to question or correct information. As a result, 
the issuer deadline may not always be adhered to. Conversely some responses 
(by foreign intermediaries) are provided before the record date – this 
information is considered to be potentially incorrect (such responses should 
only be sent on the record date or, at the latest, on the record date +1). 

Several intermediaries are not able to send cancellation requests in formatted 
electronic form and request the issuer to remove a response manually. 

At CSD level, requests are currently sent to all participants without taking into 
account holdings on the record date (this issue is acknowledged by the CSD 
and is expected to be resolved in 2025). 

Some (foreign) intermediaries respond (very) close to the deadline which poses 
problems in terms of questioning and amending incorrect or incomplete 
information. 

Some (foreign) intermediaries are unable to manage requests with a future 
record date; they respond immediately - before record date – stating that the 
response contains holdings as of the response date. 

A significant number of (last) intermediaries has outsourced the responding to 
SI requests. The Dutch market has concerns that these responses are not (yet) 
timely, complete and correct. 

Sometimes the Requestor sets the Issuer Deadline less than ten Business 
Days after the SI request. 

• 

Regarding Standard 3.5, the Dutch market has observed cases where: 

• 

• 

• 

(foreign) intermediaries responding with the NORE reason code when 
having no position, as well as intermediaries responding with NORE 
reason code when having all BENEs below the threshold. 

several intermediaries report beneficiaries as nominees. 

holdings are reported as own account but specified as nominee holding. 

The CEG welcomed the in-depth reporting provided by the Dutch market and noted 
that the issues identified by the Dutch market (in particular those concerning foreign 
intermediaries) would also be of relevance to many other AMI-SeCo markets and 
encouraged other markets to provide information on similar cases in the next 
compliance monitoring exercise. 

Corporate Events Compliance Report – Key takeaways per market 

34 

 
 
Norway (Euronext Securities Oslo) 

CA Standards 

Euronext Securities Oslo participated in the monitoring exercise for the second time 
this year. While significant gaps in compliance were observed, a concrete 
implementation plan has been devised by Euronext Securities Oslo with full 
compliance expected with all standards by the second quarter of 2026. The 
implementation is part of a wider plan to align and upgrade corporate action 
processing across all Euronext CSDs. 

SI Standards 

SRD II entered into force in Norway on 1 July 2023. The SI Standards therefore 
became applicable to the Norwegian market as of the same date. The Norwegian 
market reported full compliance with the SI Standards in its self-assessment report. 

Norway and the other Nordic markets (Denmark, Finland and Sweden) are direct-
holding markets, meaning that (domestic) end investors may (or must, in Finland and 
Norway) have direct accounts in the CSD. Accordingly, nominee accounts in Norway 
can only be used for non-domestic investors. When applying for a Norwegian 
nominee license (intermediaries such as global custodians must hold their own 
nominee licenses from the Norwegian Financial Supervisory Authority), the 
intermediary also agrees to comply with all legal requirements, including the 
provision of information on end investors/shareholders. Prior to SRD II, shareholder 
information was requested by the issuer via email and nominees generally also 
responded to the issuer using non-automated formats. With the ISO 20022 
shareholder identification disclosure process, nominees can provide the required 
information using a more automated and secure method. 

The CEG also noted that the Norwegian CSD requires all issuers (issuing securities 
in the Norwegian CSD) to appoint an issuer agent. The issuer agent must be a 
participant in the CSD, holding the role of issuer agent (among other roles such as 
account operator). The issuer agent acts as the interface between the CSD and the 
issuer, for example, issuance, corporate actions and general meeting 
notifications/meeting services. The issuer agent is also the only party that can, on 
behalf of the issuer of shares listed on a regulated market, request the CSD to send 
a shareholder identification disclosure request. The issuer agent does so via the 
CSD’s portal. As the agent is appointed by the issuer, it is also authorised to initiate 
an SI request, and the CSD does not need to verify with the issuer – removing the 
need for a separate process (such as the provision of a letter of authorisation). The 
Norwegian CSD provides the register to the issuer in existing format as per the pre-
SRD II process. Information regarding shareholders with their shares held in owner 
account is thus available to the issuer without need for a disclosure process, hence 
the SI process only applies to nominee accounts, where it replaces a previous, quite 

Corporate Events Compliance Report – Key takeaways per market 

35 

 
 
manual process for nominees to provide information of shareholders’ names & 
details. 

Poland (KDPW) 

CA Standards 

Some increases in the levels of compliance with corporate actions standards have 
been observed this year owing primarily to the introduction of a requirement in the 
CSDs rules requiring issuers to provide narrative information on corporate events in 
a language customary in the sphere of international finance, i.e. English, as 
prescribed in the standards. Most remaining gaps in compliance are expected to be 
closed by the second quarter of 2027 (eighteen months later than the previously 
reported target date). While the Polish market has a plan in place to implement 
reversals for cash distributions, no plan is currently in place to implement reversals 
for other types of corporate actions. The reasons for this will be examined in the 
context of a broader analysis planned by the CEG regarding obstacles to achieving 
full compliance with reversals standards reported by several markets. 

For Mandatory Reorganisations, the Polish market explained that a new ISIN is not 
used. The reason for this deviation is that ISIN guidelines (issued by the Polish ISIN 
numbering agency) stipulate that ISINs should only be changed if necessary. The 
Polish market plan to examine this issue in light of changes to the Association of 
National Numbering Agencies (ANNA) technical standards. Regarding the 
Distributions with Options Standards the CEG, as in previous years, agreed that 
compliance cannot be assessed to be 100% as long as the Security Distributions 
gaps have not been addressed. 

The Polish market procedures relating to the processing of fixed price tender offers 
are also not in line with the Market Standards on Voluntary Reorganisations. The 
issue is acknowledged by the Polish market, which explained that tender offers in the 
Polish market are required by law to be treated as trading orders instead of 
corporate action events. As a result of this legal barrier, in some cases it is difficult or 
impossible for non-domestic investors to express their preferred option through the 
custody chain. The CEG will further analyse this issue. 

SI Standards 

Full compliance with the SI Standards was reported. It is noted that, in the case of SI 
requests registered with KDPW, acting as the first intermediary and an entity 
collecting SI responses, the issuer is not able or allowed to choose a record date 
from the past. The Polish Securities Trading Act does not allow shareholder 
information to be disclosed when the record date is older than the SI request date. 
This, in turn, may limit the ability of local intermediaries to respond to SI requests 
originated in a foreign jurisdiction that were received after the record date where the 

Corporate Events Compliance Report – Key takeaways per market 

36 

 
 
relationship between the SI request date and the record date is not known to the 
intermediary. It was noted that, in general, the Polish SI process does not work for 
foreign intermediaries owing to the Polish definition of shareholder. The CEG agreed 
that further follow-up on this issue may be warranted. 

In the case of SI requests on securities registered with KDPW, where KDPW acts as 
the first intermediary and an entity collecting SI responses, according to Polish 
Securities Trading Act the issuer is not able, nor allowed to choose a Record Date in 
the past. The CEG agreed to revise downwards the level of compliance with 
Standard 2.1 (which states that the issuer should be able to submit an SI request up 
to twelve months in the past) accordingly. 

Poland (SKARBNET4) 

CA Standards 

Full compliance with the CA Standards was reported by the Polish NSG. The Polish 
NSG explained that there are only two types of securities registered in SKARBNET4: 
NBP-bills (issued by National Bank of Poland (NBP) in open market operations, 
which are the main instrument of monetary policy) and T-bills (issued by the Ministry 
of Finance). Both NBP-bills and T-bills are discount short term money market 
securities. The only corporate action applicable in the case of NBP-bills and T-bills is 
the redemption event which in turn is the only corporate action event type managed 
by SKARBNET4. As SKARBNET4 processes redemptions (which are mandatory 
reorganisations), the CEG agreed that Transformations Standards (which were 
deemed not applicable in the Self-Assessment) are relevant. SKARBNET4 is 
therefore invited to put a plan in place to implement    the Transformations Standards 
and to provide further information on the implementation status in the next 
monitoring exercise. In addition, reversals were deemed not applicable by the Polish 
NSG on the basis that there are no reversals on T-bills and NBP-bills, while 
reversals should be supported if there is a need to correct a payment error. 
SKARBNET4 was therefore deemed not to be compliant with Mandatory 
Reorganisations Standards 7 and 17d. 

SI Standards 

SI Standards are not applicable as SKARBNET4 only manages a limited number of 
debt instruments. 

Corporate Events Compliance Report – Key takeaways per market 

37 

 
 
Portugal (Euronext Securities Porto) 

CA Standards 

For corporate actions, a few gaps remain related to ISO standards and reversals. A 
new CA platform was implemented in April 2024 which supports standard compliant 
processing of corporate events on debt instruments; the scope will be extended to 
other instrument types    by November 2025. 

SI Standards 

For SI Standards, all the procedures required to fully comply with the standards have 
been implemented by the CSD. However, not all intermediaries are responding to SI 
requests. The CEG agreed to revise downwards the status of compliance with 
Standard 3.1 accordingly, consistent with the approach taken for other markets. 

Some foreign intermediaries reported obstacles to accessing the market as Euronext 
Securities Porto has not developed functionality allowing an issuer or issuer agent to 
submit a disclosure request using an ISO 20022 message. However, third party 
issuer agents, duly authorised, can send the requests through the Euronext 
Securities Porto web portal and receive the consolidated information from Euronext 
Securities Porto on behalf of the issuer. As in previous years, the CEG did not 
consider this to be a case of non-compliance with the standards, however, as this 
setup does not prevent the issuer or its agent from submitting a disclosure request in 
electronic form. The CEG will continue to monitor this topic. 

The CEG noted that Euronext Securities Porto also uses seev.045 messages for 
non-SRD II disclosures as an alternative to their legacy process. Since May 2017 
(Law 15/2017) all Portuguese securities are registered. Therefore, issuers have the 
right to request information on the shareholders / investors and all the requests 
received must be forwarded. 

Romania (Depozitarul Central) 

CA Standards 

For Voluntary Reorganisation Standards, a compliance rate of 69% is observed. 
There are no plans to address these gaps as long as voluntary reorganisations are 
processed through the Bucharest Stock Exchange as usual trades and only their 
settlement is processed by the CSD. The other main gap relates to the processing of 
reversals; this gap is due to be addressed in 2025. The Romanian market is 
requested to devise a concrete adaptation plan to address the remaining gaps and 
include details of the implementation plan in next year’s monitoring exercise. 

Corporate Events Compliance Report – Key takeaways per market 

38 

 
 
SI Standards 

The CEG took note that the Self-Assessment Report showed a 100% level of 
compliance with the SI Standards. 

Romania (SaFIR) 

CA Standards 

SaFIR, the SSS operated by the National Bank of Romania, participated in the 
compliance monitoring exercise for the third time. The CEG noted that SaFIR is 
currently in the process of implementing a new corporate action platform which 
should result in full compliance with the applicable standards by the end of 2025. 
This is two years later than originally foreseen, however. The CEG highlights the 
importance of achieving full compliance by the revised implementation date. 

SI Standards 

The SI Standards are not relevant to SaFIR as the scope of its activities is limited to 
debt instruments. 

Slovakia (CDCP) 

CA Standards 

All standards not yet implemented are reported as being in the process of 
implementation with full compliance expected by the first quarter of 2026 (which is 
later than originally planned). The CEG noted that the compliance deadlines 
specified in the Slovakian Self-Assessment Report differ between the actors involved 
(for example, one deadline is provided for the CSD while another deadline is 
provided for custodians). However, in cases where the standards are applicable to 
all parties (i.e. Issuers, CSDs, Intermediaries and End Investors), there can only be 
one compliance deadline per standard relevant for all these parties (since, for 
example, if an issuer announces a CA, this announcement must be made via the 
CSD and the CSD, in turn, must announce it to all CSD account holders regardless 
of whether the account holder is another CSD, a central bank, or a custodian). The 
CEG invites the Slovakian NSG to take this into account in the preparation of next 
year’s Self-Assessment Report. 

SI Standards 

The Slovakian market reported full compliance with the SI Standards. 

Corporate Events Compliance Report – Key takeaways per market 

39 

 
 
Slovenia (KDD) 

CA Standards 

The CEG took note that the market remained fully compliant with all corporate 
actions standards.   

SI Standards 

The Slovenian market reported full compliance with the SI Standards. The CEG 
noted the Slovenian market has a specific operating model with a CSD that is 
predominantly final-client account type level; however, in line with CSDR, omnibus 
accounts are also enabled and used. This means that the first three levels of 
intermediaries are comprised and accessible to the issuer on CSD level (namely, 
CSD level, CSD member – account operator level and CSD fiduciary account holder 
level). The issuer who exercises its right to target the request to certain specific 
(“third-level”) intermediaries and directs this request to be processed through CSD 
and CSD member levels (i.e. levels 1 and 2), typically receives the response of all 
the level 3 intermediaries whose securities accounts are operated by CSD members 
(level 2) who process the initial request directed only at one or some of the level 3 
intermediaries with the same level 2 intermediary.     

Furthermore, the CEG noted that Slovenian law includes a provision allowing for the 
temporary cessation of the voting rights of an unidentified ultimate shareholder. This 
practice is one of the tools available to issuers as mitigation measures to deal with 
cases where information on the holders of the securities is not disclosed upon 
request.   

Switzerland (SIX SIS) 

CA Standards 

The Self-Assessment Report showed an increase in the level of compliance as 
issues related to the potential incorrect application of key dates for cash distributions, 
whereby some issuers in the Swiss market did not communicate the ex-date for 
structured products denominated in units to the CSD, were resolved following an 
amendment of the SIX SIS rulebook (which obliges issuers to provide the required 
information).   

Issues with the key dates for several other standards were identified by the CEG 
however which resulted in an overall downgrade in the status of the compliance:   

Corporate Events Compliance Report – Key takeaways per market 

40 

 
 
• 

• 

Distributions with Options (standard 5) and Mandatory Reorganisations with 
Options (standard 12) are not complied with as the election period is less than 
the required 10 days.     

Voluntary Reorganisations standards 13 and 14 are not complied with as the 
Guaranteed Participation Date and Market Deadline for Swiss tender offers are 
on the same day. 

SI Standards 

SI Standards were deemed not applicable as SIX SIS is located outside the EEA 
(nonetheless, it is noted that Swiss intermediaries are processing a significant 
number of disclosure requests). 

Spain (Iberclear) 

CA Standards 

Regarding corporate actions standards, no change in the overall level of compliance 
has been observed year on year. However, plans are in place to achieve increased 
levels of compliance by the fourth quarter of 2025 with current market efforts focused 
on the implementation of the SCoRE Standards. Implementation of Phase 3 of the 
Spanish market reform, scheduled for 10 March 2025, is expected to help foster full 
compliance with Mandatory Reorganisations with Options Standards 12 and 14 in 
the Spanish market in the medium term. The CEG also noted that, while Iberclear 
has implemented the possibility to announce corporate events in preliminary status, 
some issuers and issuer agents do not yet provide corporate event information to the 
issuer CSD as soon as it is publicly announced. Instead, the information is first 
published in official bulletins. As a result of the late delivery of information to the 
issuer CSD, the custody chain is only notified about the corporate event a few days 
before the payment date. The CEG considers that timely delivery of complete and 
accurate information by the issuer or its agent in an electronic form is critical to the 
efficient and effective processing of corporate events.   

SI Standards 

Regarding SI Standards, full compliance was reported by the Spanish market. One 
potential case of non-compliance was reported by a foreign market however 
concerning identification requests sent by Spanish issuer agents to an Investor CSD 
(i.e. a targeted request). Where a request is sent directly to any intermediary in the 
chain with an intention of identifying only the clients of this intermediary; the request 
should not be flagged as to be forwarded down the chain. As the agents in Spain 
sending requests directly to an Investor CSD also flag them as to be forwarded down 

Corporate Events Compliance Report – Key takeaways per market 

41 

 
 
the chain, the CEG agreed that this is a case of non-compliance and revised the 
status of compliance with standard 1.1 downwards accordingly. 

It is noted that, according to Spanish legislation, the holders of the securities 
according to the accounting records held by Iberclear and its participants are 
presumed to be the shareholders. This does not have any impact at SRD II 
identification level because the issuers have the right to request the identification of 
the shareholders and, as a new feature, if the shareholder is an intermediary entity 
that held the securities on behalf of final beneficiaries, the issuer is allowed to 
request the identification of those beneficiaries. While noting that the Spanish 
legislation recognises the possibility to request the final beneficial owner’s identity, 
the topic of definition of shareholders in the Spanish market will continue to be 
closely monitored by the CEG.   

With regard to communication channels, Iberclear supports the usage of the SWIFT 
FinPlus service since April 2022 in order to facilitate the management of the SI 
responses for the custody chain. At operational level the request of shareholders 
identification must be performed through the CSD with the CSD then centralising the 
information to be provided to the issuer. In the event of intermediary entities, the 
issuer may request the identification of the ultimate beneficiaries directly from the 
intermediary entity or request it indirectly through the CSD. 

Sweden (Euroclear Sweden) 

CA Standards 

The Swedish market reported some increases in compliance with corporate actions 
standards this year (for example, payments on equities are now processed via the 
CSD's payment mechanism). Overall, the level of compliance decreased year on 
year however as Euroclear Sweden will no longer announce reversals and, 
therefore, the relevant standards are no longer complied with. For the remaining 
standards not yet implemented, although the Swedish market is in the process of 
devising a harmonisation roadmap which should result in a significant increase in 
compliance, no timeline for implementation is yet available. The Swedish market is 
invited to provide further information on its harmonisation roadmap in 2025. 

SI Standards 

In the Self-Assessment Report, Standards 1.8a, 1.8b and 1.8e were assessed as 
non-compliant as Euroclear Sweden does not (i) allow issuers to perform a 
shareholder identification disclosure request with a record date in the past and (ii) 
support updates (while it should be possible to send an update in case of an 
extension of the issuer deadline). In addition, as requests with a record date in the 
past are not possible, the CEG agreed that Standard 2.1 should also be assessed as 
non-compliant. 

Corporate Events Compliance Report – Key takeaways per market 

42 

 
 
The CEG noted that Sweden and the other Nordic markets (Denmark, Finland and 
Norway) are direct-holding markets, meaning that (domestic) end investors may (or 
must, in Finland and Norway) have direct accounts in the CSD. In Sweden (and also 
Finland and Norway), the issuer has a legal right to receive the register from the 
CSD. This register contains the names & other details of all holders of owner 
accounts, as well as the names & other details of all holders of nominees. In 
Sweden, the issuer also has a pre-SRD II legal right to receive from the CSD a 
register that includes information of the nominees’ clients’ names & details, though 
this register takes a few days to create as it requires nominees to report the details 
to the CSD.   

United Kingdom (Euroclear UK and International) 

CA Standards 

No Self-Assessment was provided by the UK market this year. As a result, and in 
line with the standard methodology, the UK market was deemed non-compliant with 
all applicable standards. The CEG invites the UK market to put the necessary 
reporting structures in place to ensure that a comprehensive, up-to-date, Self-
Assessment report is provided in 2025. 

SI Standards 

SI Standards were deemed not applicable as the UK Department for Business, 
Energy and Industrial Strategy determined that the SRD II requirements for 
shareholder identification did not need to be transposed into UK legislation. The UK 
CSD does, however, provide a file at the end of the day to the registrars which 
contains information on the holders of the securities. Euroclear UK and International 
also holds a significant number of non-UK securities in custody for which a 
shareholder identification request process is needed. The UK market is currently 
investigating a potential solution to address this issue (potentially via the use of an 
external provider). The ISO 20022 messages used for SRD II disclosures are 
planned to be adopted, thereby aligning the operational processing with the 
operational processes followed for SRD II requests in other European markets. 

Corporate Events Compliance Report – Key takeaways per market 

43 

 
 
3 

Compliance assessment 

This section provides a detailed overview of the current status of compliance with the 
individual standards. For each standard where full compliance has not yet been 
achieved, an explanation of the current status is provided together with details of the 
planned implementation date. 

An assessment is provided for each category of corporate events covered by the 
standards in the scope of this report as follows: 

Distributions 

• 

• 

• 

Cash Distributions (e.g. cash dividend, interest payment) 

Securities Distributions (e.g. stock dividend, bonus issue) 

Distributions with Options (e.g. optional dividend) 

Reorganisations 

•  Mandatory Reorganisations with Options (e.g. conversion) 

•  Mandatory Reorganisations (e.g. stock split, redemption) 

• 

Voluntary Reorganisations (e.g. tender offer) 

Transaction Management 

•  Market Claims (Distributions) 

• 

• 

Transformations (Reorganisations) 

Buyer Protection (Elective Corporate Actions) 

Shareholder Identification 

Corporate Events Compliance Report – Compliance assessment 

44 

 
 
3.1 

Distributions 

3.1.1 

Cash Distributions 

Chart 1 
Cash Distributions – % compliance per market 

Notes: N/A. 

Box 4 
Cash Distributions – Compliance status per Standard 

Information from 
Issuer to Issuer 
(I)CSD 

Information from 
Issuer (I)CSD to its 
participants 

Information flow 
from (I)CSD 
participants to 
End Investors 

Key dates 

Processing 

AT - Oesterreichische 
Kontrollbank 

BE - Euroclear Bank 

1 

B 

B 

2 

B 

B 

3 

B 

B 

BE - Euroclear Belgium 

B  N/A  B 

BE - NBB-SSS 

BG - BNBGSSS 

BG - CD AD 

CH - SIX SIS 

CY - Cyprus Stock 
Exchange 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

4 

B 

B 

B 

B 

B 

5 

B 

B 

B 

B 

B 

75%  B 

B 

B 

B 

B 

6 

B 

B 

B 

B 

B 

B 

B 

B 

7 

B 

B 

B 

B 

B 

B 

B 

B 

8 

B 

B 

B 

B 

B 

B 

B 

50%  B 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20a  20b  20c  20d  20e 

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 

75%  B 

B 

75%  75%  B 

B 

B 

B  N/A 

B 

B 

B  N/A 

B  N/A 

B  N/A 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  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 

75%  B 

B 

B 

B 

B 

B 

B 

50%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75%  B 

CZ - CSD Prague 

50%  50%  50%  75%  75%  50%  50%  50%  50%  50%  50%  25%  25%  B 

B 

50%  75%  75%  B 

75%  B 

75%  B 

75% 

CZ - SKD 

B  N/A  B 

B 

0%  0%  0%  0% 

B 

0% 

B 

B  N/A  N/A  N/A 

B 

B 

0% 

B 

DE - Clearstream Banking 
Frankfurt 

N/A  N/A  N/A 

B 

B 

B 

B 

B 

B 

B 

B 

75%  B 

B 

75%  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

Corporate Events Compliance Report – Compliance assessment 

45 

0%10%20%30%40%50%60%70%80%90%100%AT - Oesterreichische KontrollbankBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - Nasdaq CSDES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSGR - ATHEXCSDHR - SKDDHU - KELERIE - Euroclear BankIS - NasdaqIT - Euronext Securities MilanLI - SIX SISLT - Nasdaq CSDLU - Clearstream Banking LuxembourgLU - LuxCSDLV - Nasdaq CSDMT - Malta Stock ExchangeNL - Euroclear NederlandNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4PT - Euronext Securities PortoRO - Depozitarul CentralRO - SaFIRSE - Euroclear SwedenSI - KDDSK - CDCPUK - Euroclear UK & International 
 
 
  
Information from 
Issuer to Issuer 
(I)CSD 

Information from 
Issuer (I)CSD to its 
participants 

Information flow 
from (I)CSD 
participants to 
End Investors 

Key dates 

Processing 

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 

IE - Euroclear Bank 

B  N/A  B 

B 

B 

B 

B 

B  N/A 

50%  25%  50%  50%  50%  50%  50%  25%  50%  50%  50%  B 

25%  25%  B 

25%  B 

25%  25%  25%  B 

25% 

DK - Euronext Securities 
Copenhagen 

EE - Nasdaq CSD 

1 

B 

B 

2 

B 

B 

ES - Iberclear 

75%  B 

FI - Euroclear Finland 

FR - Euroclear France 

GR - BOGS 

GR - ATHEXCSD 

HR - SKDD 

HU - KELER 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

3 

B 

B 

B 

B 

B 

B 

B 

B 

4 

B 

B 

B 

B 

B 

B 

B 

5 

B 

B 

B 

B 

B 

B 

B 

75%  B 

6 

B 

B 

B 

B 

B 

B 

B 

B 

7 

B 

B 

B 

B 

B 

B 

B 

B 

IS – Nasdaq CSD 

IT - Euronext Securities 
Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - Clearstream Banking 
Luxembourg 

LU - LuxCSD 

LV - Nasdaq CSD 

B 

B 

B 

B 

B 

B 

B 

MT - Malta Stock Exchange  B 

NL - Euroclear Nederland 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  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 

8 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50%  B 

B 

B 

50%  0%  0% 

B 

B 

B 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20a  20b  20c  20d  20e 

B 

B 

B 

25%  B 

B 

B 

B 

B 

B 

B 

25%  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 

75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75%  B 

B  N/A 

B  N/A 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50%  B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

B 

B 

25% 

B 

B 

B 

B 

B 

B 

B 

75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25% 

75%  B 

B 

75%  B 

75%  75%  75%  B 

B 

B 

B 

B 

B 

25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

50%  50%  50%  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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75%  B 

B 

B 

B 

B 

75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

NO - Euronext Securities 
Oslo 

0%  75%  75%  B 

50%  50%  75%  25%  B 

75%  B 

PL - KDPW 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

75%  B 

B 

25%  0% 

B 

B 

75%  B 

B 

B 

B 

B 

B 

0% 

B 

0% 

PL - SKARBNET4 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

PT - Euronext Securities 
Porto 

RO - Depozitarul Central 

RO - SaFIR 

SE - Euroclear Sweden 

SI - KDD 

SK - CDCP 

UK - Euroclear UK & 
International 

B 

B 

B 

B 

B 

B 

75%  B 

0% 

B 

B 

B 

B 

B 

B  N/A 

75%  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  B 

B 

B 

75%  B 

75%  B 

75%  0% 

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 

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 

75% 

B 

B 

B 

75% 

75%  B 

0% 

B 

B 

B 

75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75% 

0%  0%  0%  0% 

0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

Notes: Standards 2, 14 and 18 are not applicable to equities. Standard 15 is not applicable to fixed income securities. BNBGSSS's activities are limited to interest payment on 
government securities. Accordingly, standard 13 is not applicable. Cash Distributions are outside the scope of SKARBNET4 activities, as only Treasury-bills and NBP-bills are 
registered in SKARBNET4. Both of these instruments are short term discount papers and the only Corporate Action which is carried out on these securities is final redemption. 

Table 1 
Cash Distributions - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the Cash 
Distributions standards. Markets/CSDs not listed below have been assessed as fully 
compliant. 

Market 

Gaps 

Status 

Plan 

BE - Euroclear 
Bank   

S12, S15, 
S16, S20c 

S12, S15, S16 - In the 2024 assessment, one case of incorrect use of 
key dates has been identified with the below details: 

S12, S15, S16 – No plan 

S20c - Q4 2024 

DVCA event on ISIN LU1603790731 (listed investment fund): 

XDTE 29.04.2024 / RD 26.04.2024 / PD 07.05.2024. 

Euroclear Bank clarified that their common depositary did not share 
the record date on the above event, causing delays in following of the 
key dates sequence.   

Corporate Events Compliance Report – Compliance assessment 

46 

 
 
  
Market 

Gaps 

Status 

Plan 

S20c - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on currency, operating time-zone of 
the Agents as well as the timing that the issuers can release the 
payment (i.e. availability of cash). The concrete action taken is the 
update of MOP (Manual of Procedure) shared with Common 
Depositories and Agents in October 2024. This is a contractual 
document in which Euroclear Bank recommended the deadline to be 
compliant with those standards (and also SCoRE). Euroclear Bank 
had with CBL a joint call with some of those agents to explain the 
rules and the AMI-SeCo monitoring process. To be fully implemented 
by November 2024. 

BG - BNBGSSS    S8, S18, 

S20d 

S8 – To facilitate the activities related to implementing this standard, 
BNBGSSS plans to conduct internal testing by the end of 2024 and 
intends to synchronize external testing with the testing of SCoRE CA 
Standard 15 ISO 20022 messages for corporate actions. 

Q4 2025 

BG - CDAD   

S4, S16 

S4- Q1 2025 

S16 - Q4 2024 

S18 - Regulatory and technical changes are completed. BNBGSSS 
plans to conduct internal testing by the end of 2024 and intends to 
synchronize external testing with the testing of SCoRE CA Standard 
15 ISO 20022 messages for corporate actions. 

S20d – BNBGSSS is working on regulatory and legislative changes 
together with its single issuer (Ministry of Finance). Technical 
changes have been completed in the CSD to meet this standard as 
soon as possible. 

S4 – According to the Rules of the Bulgarian Stock Exchange (Part 
III, Article 5. (1), item 10) the companies listed on the Premium 
segment of the BSE disclose regulated information to the general 
public simultaneously in Bulgarian and in English through the media 
chosen by the company within the respective deadlines. Other 
issuers are not obliged to publish information in English. Where 
applicable, the recently developed Electronic Platform for General 
Meetings (EPOS) may also be employed to obtain narrative text, 
inserted in a dedicated section for CA data announcement in 
Bulgarian and English. There are plans to include the standard in the 
list of upcoming changes to the Bulgarian Stock Exchange (BSE) 
Trading Rules for the next amendment session. CDAD is unable to 
commit to a specific date for the next amendment session of the BSE 
Trading Rules, as this action falls exclusively under the authority of 
the BSE. Relevant discussions have taken place between the two 
institutions, and CDAD has received assurances that all necessary 
actions will be taken to incorporate the required provisions into the 
referenced document. It is also important to note that the proposed 
amendments are subject to approval by the Financial Supervision 
Commission (FSC). Nonetheless, CDAD remains confident that the 
standard will be achieved within the designated timeframe, by Q1 
2025. 

S16 – The Payment Date (PD) for dividends is not precisely defined 
in the Law. National legislation dictates that the dividend payment 
process must be initiated within 60 days, beginning on the day 
following the Record Date. Issuers communicate the PD to CDAD in 
advance by a message. For interest payment, the PD is set as per 
the Standard. The corresponding amendments in the law are 
expected. 

CY - Cyprus 
Stock Exchange 

S9-S11   

S10, S11 - Technical changes in custodians' infrastructures are 
currently assessed. 

No plan 

CZ - CSD Prague  S1-S13, 

S16-S18, 
S20a, 
S20c, 
S20e 

S1, S2, S4, S7, S8, S10-
S13, S16-S18, S20a,c,e – 
No plan 

S3, S5, S6, S9 – Q2 2025 

S1 - Only issuers of listed securities are obliged by the law to inform 
its issuer CSD about a corporate action. These issuers should inform 
their issuer CSD according to the same deadline for fulfilling the 
obligation to publicly announce the corporate action. For non-listed 
securities, there is not an obligation to announce distribution of 
proceeds publicly. More than 99% of book-entry issues are not listed. 
As these standards refer to all securities deposited and settled in 
CSD, most of the standards are not applied. Standards are mostly 
partly implemented or not implemented. It is possible to address 
shareholders of Czech companies and bondholders of Czech bonds 
directly because the issuers receive a list of shareholders from CSD 
in three days. There is no plan to change the law to increase 
administrative burden of companies with non-listed book-entry shares 
or issuers of non-listed book-entry bonds to inform CSD about a 
corporate action that does not affect (change) the underlying security. 
There is no plan to impose an obligation on issuers of book-entry 
securities to distribute proceeds only via CSD - neither contractual 
obligation imposed by CSD to issuers as its clients, nor legal from the 
legislators; not even for the listed securities. 

S2 - Payment date is given by approved Issue conditions, so that the 
Issuers announce only the new rate. 

Corporate Events Compliance Report – Compliance assessment 

47 

 
 
   
Market 

Gaps 

Status 

Plan 

S3 - The laws provide for formatted electronic form only for listed 
shares, for other securities the information is usually communicated 
in the same format as is published on the websites of the issuer (pdf). 
In case that issuer of listed shares does not inform the shareholders 
directly, the communication has to be in the format of Table 8 of 
IR 2018/1212. There is a plan that in April 2024 listed book-entry 
bonds will be communicated in ISO 20022 in compliance with 
SCoRE. There is no plan to change the law to increase administrative 
burden of other companies with book-entry shares or issuers of book-
entry bonds to use only ISO standards. 

S4 - Issuers of listed shares provide the information in English as 
well. There is an obligation from Art. 2/2 of IR 2018/1212 for listed 
shares. For non-listed securities, there is no obligation to inform in 
English. In practice, SMEs with international shareholder base would 
use bilingual text. There is no plan to change the law to increase 
administrative burden of other companies with book-entry shares or 
issuers of book-entry bonds to inform shareholders via CSD in 
English. 

S5 - The standard is implemented with respect to listed shares. There 
is a new law amendment imposing on CSD the obligation to 
communicate the information from issuer of listed book-entry shares 
to participants (in case the issuer provided the information to CSD). 
Deadlines to be complied with are set in Art. 9/2 of IR 2018/1212. 
With respect to other securities, CSD publishes received information 
immediately on its websites. CSD does not push all provided 
information downstream to its participants. The information from the 
issuer of listed securities may be supplemented by information from 
the CSD, then it is published in the CSD Bulletin and sent to all (not 
only relevant) CSD participants. CSD provides to all issuers in the 
CSD register the possibility to communicate the information by 
publication on CSD websites. There is a plan by CSD Prague to 
impose an obligation of listed bonds issuers to inform about CA in 
ISO 20022 in order to comply with SCoRE (June 2025). 

S6 - CSD informs relevant participants but only "holding" participants 
with respect to listed book-entry shares. CSD informs all its 
participants with respect to other securities. There is no obligation for 
CSD to inform only relevant participants. There is a plan to inform 
also participants obtaining securities on the day between 
announcement and record date (by July 2025). 

S7 - There is an obligation from Art. 2/2 of IR 2018/1212 for listed 
shares. The law does not provide for formatted electronic form for 
other securities than listed shares and the information is usually 
provided in the same format as is published on the websites of the 
issuer (pdf). There is a plan of CSD Prague to impose an obligation of 
listed bonds issuers to inform about CA in ISO 20022 in order to 
comply with SCoRE (by June 2025). 

There is no plan to change the law to increase administrative burden 
of all companies with book-entry shares or issuers of book-entry 
bonds to inform owners via the CSD. 

S8 - CSD informs participants prior to processing payments, credit or 
debit of their accounts. There is no plan to impose an obligation to 
distribute proceeds only via CSD. 

S9 - Implemented only for services of Investor CSD, i.e. for foreign 
securities, when CSD and its participants should inform their clients. 
With respect to Czech securities, there is no obligation at the moment 
and only participants providing custodial services would inform clients 
about a corporate action. Level of these services is not harmonised. 
With respect to listed shares, there is an obligation to transmit the 
information in two level register as owners of accounts on the second 
level are considered to be the shareholders. Records in any kind of 
sub-register about end investors are not considered as book-entry 
shares and issuers provide payments only to those stated in the list of 
shareholders on record date. There is an effort of CSD Prague to 
motivate its participants holding listed bonds to be compliant with 
SCoRE and to transmit information about CA in ISO 20022 (June 
2025). 

S10 - Implemented for listed shares and services of Investor CSD, 
i.e. for foreign securities. With respect to listed shares, there is an 
obligation to transmit the information in electronic and machine-
readable formats (2/2 of IR 2018/1212). With respect to other Czech 
securities, there is no obligation at the moment. There is a plan of 
CSD Prague to transmit information to its participants in ISO 20022. 
There is no plan with respect to non-listed companies with book-entry 
shares or issuers of book-entry bonds. 

Corporate Events Compliance Report – Compliance assessment 

48 

 
 
Market 

Gaps 

Status 

Plan 

S11 - Implemented only for listed shares and services of Investor 
CSD, i.e. for foreign securities. With respect to other Czech 
securities, there is no obligation at the moment. There is no such an 
obligation neither in the valid legislation nor in the future legislation, 
including IR 2018/1212. IR allows for URL hyperlink to websites. 

S12 - According to law, issuers of shares can distribute the proceeds 
only to shareholders that are stated on record date in the list of 
shareholders and only to the bank account stated in the list of 
shareholders. It is not possible for the issuer to distribute proceeds to 
someone who is not a shareholder (on record date). Similar applies to 
owners of bonds. At the moment, CSD Prague only extraordinarily 
distributes proceeds. Then it is made by crediting of participants' cash 
accounts in central bank. With respect to listed shares, rules of 
Prague Stock Exchange acknowledge the right of non-defaulting 
party to receive compensation of rights due to default of the other 
party on the record date and the obligation of defaulting participant to 
provide the compensation (the proceeds) to non-defaulting party via 
CSD. In case that Ex Date leads to Market Claim, there is an Ex-Date 
even for listed bonds. However, bonds are always ""units of 
securities"" in the CSD register. There are no compensations of rights 
organised by CSD in case of late settlement for non-listed securities 
or OTC trades. The definition of Ex-Date has no consequences. 
There is no plan to impose an obligation to distribute proceeds only 
via CSD - neither contractual obligation imposed by CSD to issuers 
as its clients, nor legal from the legislators. There is no plan to 
acknowledge by law the right of an issuer to distribute proceeds to 
non-defaulting party instead of shareholder registered on record date. 

S13 - Only issuers of listed securities are obliged by the law to inform 
its issuer CSD about distribution of proceeds. CSD should 
communicate the information from issuer of listed book-entry shares 
to participants (in case the issuer provided the information to CSD) to 
its participants. Deadlines to be complied with are set in Art. 9/2 of 
IR 2018/1212. In case that general meeting should decide about 
distribution of proceeds, the name of the entity (bank, investment 
firm) that will distribute the proceeds should be stated in the general 
meeting notice. These issuers should inform their (issuer's) CSD in 
the same deadline for fulfilling the obligation to announce publicly the 
corporate action. For non-listed securities, there is not an obligation 
to announce distribution of proceeds publicly. There is no plan to 
impose an obligation to distribute proceeds only via CSD and onward 
chain of intermediaries. IR does not impose that obligation as well. 

S16 - CSD does not usually distribute payments. Payments are 
distributed by banks according to a list of shareholders or 
bondholders prepared by CSD after the record date. The record date 
is usually before the coupon’s redemption (up to 30 days before) in 
order to manage tax issues and payments. The payment date is as 
close as possible after coupons redemption. Unless the GM decides 
differently, the dividend payment should be made according to law by 
3 months after the GM that decided about the dividends. The record 
date for dividend payment is often the same as the record date for the 
GM. There is no plan to impose an obligation to distribute proceeds 
only via CSD. There is an undefined deadline for companies with 
listed shares in IR (8/2/a) to set the payment date as close as 
possible to the record date, issuer deadline or the deadline set by the 
third party, so as to allow for the processing of payments to the 
shareholders as swiftly as possible. The payment date can be as 
close as possible to delivery of all necessary tax documents. 

S17 - There is an obligation for companies with shares to make 
payments by crediting bank accounts of shareholders. There is an 
obligation to make payments of more than CZK 270,000 by money 
transfer for other securities. There is no obligation of cashless 
payments with respect to bonds. If CSD distributes payments, it 
credits participants' cash accounts at Czech National Bank. 

S18 - In case that Issuer uses CSD for distribution or the distribution 
is processed via CSD as Investor CSD, payments would be 
processed separately. There is no plan to impose an obligation to 
distribute proceeds only via CSD and onward chain of intermediaries. 
There is no legal obligation even for listed shares. 

S20a - In case that Issuer uses CSD for distribution, payments are 
made in Czech National Bank accounts of participants. There is no 
plan to impose an obligation to distribute proceeds only via CSD and 
onward chain of intermediaries. There is no legal obligation even for 
listed shares. 

S20c - In case that Issuer uses CSD for distribution, payments are 
according to standard. There is usually no deadline for payments 
outside of CSD. There is no plan to impose an obligation to distribute 
proceeds only via CSD and onward chain of intermediaries. There is 
no legal obligation even for listed shares. 

Corporate Events Compliance Report – Compliance assessment 

49 

 
 
Market 

Gaps 

Status 

Plan 

S20e - In case that Issuer uses CSD for distribution, payments are 
according to standard. For payments outside of CSD reversals would 
not be possible. There is no plan to impose an obligation to distribute 
proceeds only via CSD and onward chain of intermediaries. There is 
no legal obligation even for listed shares. 

All – No plan 

No plan 

CZ - SKD 

S5-S11, 
S18 

All – Following CEG assessment. 

S8, S20e – Reversals are not allowed. 

DE - Clearstream 
Banking 
Frankfurt   

S12, S15, 
S16 

S18 - Interest payments are not processed separately from 
redemptions when the payment date of interest payments and 
redemptions coincide. This is not compliant with the standards. 

S12, S15, S16 - Parts of the Funds industry do not follow the 
sequence of dates. This is not an issue specific to the German 
market only. A Market Practice Change Initiative has been initiated. 
Discussion about target solution is still ongoing between Market 
participants, the national data vendor/provider WertpapierMitteilungen 
(WM) and Clearstream. Hence, an implementation date cannot be 
confirmed yet. Even with the support of Clearstream’s market 
participants (which they have), they cannot unilaterally introduce the 
Record Date for the unit-based instruments in question as WM play a 
crucial role alongside Clearstream. Both parties will have to make 
significant changes to existing infrastructure and processes to 
achieve market-wide implementation. Clearstream did indeed initially 
target an implementation in 2024 but could not proceed due to 
misalignment with WM. Clearstream will continue the dialogue with 
WM with the aim of defining an implementation date as soon as it’s 
feasible. 

In the 2024 assessment, three cases of incorrect use of key dates 
have been identified with the below details: 

1. an DVCA event on ISIN DE000A0H0785 (listed investment fund): 
XDTE 15.05.2024 / RD 14.05.2024 / PD 15.05.2024. 

2. an INTR event on ISIN DE000UK72HC2 (structured product): 
XDTE 18.10.2024 / RD 17.10.2024 / PD 18.10.2024. 

3. an INTR event on ISIN CH0567766123 (structured product): XDTE 
19.07.2024 / RD 18.07.2024 / PD 19.07.2024 

DK - Euronext 
Securities 
Copenhagen   

S20e 

For debt securities, a compliant solution will be implemented in line 
with the SCoRE deadline, i.e., June 2025. For equity instruments, the 
deadline is November 2025.  

Q4 2025 

ES - Iberclear   

S1 

FI - Euroclear 
Finland   

S8, S20a, 
S20e 

No plan 

S8, S20e - No plan 

S20a – Q4 2029 

Whilst Iberclear has implemented the possibility to announce 
corporate events in preliminary status, not every issuer and agent 
announces the corporate event as soon as it is publicly announced. 
Sometimes the market gets this information first instead of the issuer 
CSD. MT564 announcements are received after their publication in 
official bulletins, and MT564 swifts are notified only few days before 
of their payment date. One credit institution and one custodian point 
out that the percentage of compliance is now slightly better than in 
2023. 

S8, S20e - The Finnish regulation does not identify or allow a reversal 
of a corporate action event that has been settled on the securities 
accounts. Hence, a full reversal process as defined in SCoRE CA 
standards cannot be implemented. Manual corrections may be 
required depending on the case. 

20a - Payments are processed in Central Bank Money in the 
settlement system. However, dividends are paid in CoBM outside the 
CSD System. A taskforce discussing the future dividend payment 
model and its implementation timeline in the Finnish market was 
established in H2 2023. Payment in CeBM in the CSD System is a 
prerequisite for the future dividend payment model. In October 2024, 
the taskforce completed its work and reported its conclusion to the 
FINNUG that no consensus could be reached on the recommended 
model. Nevertheless, the taskforce intends to continue discussions 
and efforts on agreeing on a CeBM-based dividend model in Finland. 
The implementation timeline will be specified for the recommended 
model. 

FR - Euroclear 
France   

S12, S15, 
S16, S20c 

S12, S15, S16 – In the 2024 assessment, two cases of incorrect use 
of key dates have been identified with the below details:   

1. an DVCA event on ISIN LU1291091228 (listed investment fund): 
XDTE 30.08.2024 / RD 29.08.2024 / PD 10.09.2024. 

2. an INTR event on ISIN FR001400HYI7 (convertible bond): XDTE 
31.01.2024 / RD 30.01.2024 / PD 30.01.2024. 

S12, S15, S16 – No plan 

S20c - Market monitoring 
in place to continuously 
improve the payment 
timeline. 

Corporate Events Compliance Report – Compliance assessment 

50 

 
 
 
 
Market 

Gaps 

Status 

Plan 

HR - SKDD   

S4, S8, 
S19, 
S20e 

HU - KELER   

S1- S11, 
S13, S14, 
S16, 
S20a, 
S20b, 
S20c, 
S20e 

S4 - Q2 2025 
S8, S20e – No plan 
S19 - Q4 2024 

All – December 2025 

S20c – Non-compliant payments (i.e. payments after 12:00 noon) 
result from SEPA credit transfer operated through payment systems 
batches. When cash is not available in the morning of the Payment 
Date French Market prefers to operate the payment on the right date 
in the afternoon than to postpone the Pay Date the day after by 
sending an event update with a new Payment Date. No changes in 
the percentage, however actions for improvement have been taken 
and will continue. More than 84% of payments are made before 
12:00. 

S4 - Standard has been implemented regarding the general meeting, 
but not prescribed by law and it is not implemented in the Rules and 
Procedures. The CDCC will implement standard in its Rules and 
Procedures and in Corporate Action Manual in accordance with 
applicable law. 
S8, S20e - Payment reversals are not allowed currently. No 
amendments to the law governing the procedure in the event of an 
erroneous remittance of funds are needed. However, the SKDD pays 
most payments from CAs to the accounts of the Beneficiary owners 
and, currently, the SKDD does not have the authority to directly debit 
their bank account (even if it did, these accounts would have to have 
sufficient funds necessary for the reversal). SKDD can only invite the 
Beneficiary owners to remit the funds paid from the CA, noting that 
until all the funds paid from the CA have been returned, the SKDD 
must not announce and implement a reversible CA. 
S19 - The standard applies with respect to Cash Distributions. Market 
Claims will be implemented with entrance to ECMS. 

S1 - From 3 September 2020 due to SRD II, KELER introduced its 
Corporate Action notification services for listed shares. The CSD's 
corporate action database is established, which increases the 
accessibility of corporate action information. Market players are 
informed on the details of the corporate actions after the 
announcement of the issuer, from the Issuer CSD. Announcements 
for corporate actions of securities other than listed equities remain 
with the existing announcement publication places: stock exchange, 
central bank's website, issuer's website. The extension of the 
corporate action announcement services of KELER to securities other 
than listed shares is planned by December 2024. 

S2 - The implementation of this standard will be relevant during the 
implementation of standard 1. This standard will be implemented 
simultaneously with standard 1 for debt securities. 

S3 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form.     

Regarding securities other than listed equities: A corporate action 
database is available through KELER's proprietary communication 
system (KID) and on its website with limited range of information 
(only date and type of corporate action). Currently the Issuers do not 
inform the End Investors electronically. The standard is partially 
implemented at the moment, as the Issuers publish the information in 
the legally required places (on their own website, on kozzetetelek.hu 
website, and the listed Issuers on the website of the stock exchange). 

The extension of the corporate action announcement services of 
KELER to securities other than listed shares is planned by December 
2024. 

S4 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. 

In Hungary, the default language of publishing is Hungarian. The 
publication in English depends on the individual decision of the 
Issuer. The major Issuers and/or Issuers with considerable foreign 
ownership are currently publishing the information in English also. For 
securities other than listed shares, during the implementation of 
standard 1, KELER's General Business Rules shall be modified 
according to this standard. 

S5 - Due to SRD II, in case of listed shares, KELER forwards the 
notification following the data provision of the Issuer according to 
standard 1. In case of securities other than listed shares, the pre-
condition of this standard is the provision of data by the Issuer 
according to standard 1. The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

S6 - This question relates to Transaction Management. KELER does 
not have corporate action database for such purposes, the technical 
background is not yet ensured. By comparing the corporate action 
database emergent from standard 1 against the end-of-day positions 
the generation of the notification of the new position can be 
automated. 

Corporate Events Compliance Report – Compliance assessment 

51 

 
 
 
Market 

Gaps 

Status 

Plan 

S7 - KELER, as issuer CSD forwards the corporate action information 
received from the issuers of listed shares according to standard 1 to 
its participants in ISO 20022 format. In case of other securities, 
KELER does not inform on the corporate actions its Participants in 
the format and with the information content required in the standards. 
The extension of the corporate action announcement services of 
KELER to securities other than listed shares is planned by December 
2024 

S8 - The reversal of the payment is not market practice, currently the 
Issuer transfers the corrected amount after transferring back the 
incorrect first payment. KELER participates in the procedure if 
KELER is appointed as paying agent. This standard is planned to be 
implemented by December 2025. 

S9 - In case of listed shares, KELER Participants receive the issuer's 
announcement from KELER and they forward it further down the 
chain. In case of other securities KELER participants obtain CA 
information not from the Issuer through KELER, but by processing the 
information published by the Issuer. They forward the information 
obtained the before mentioned way directly or through the custody 
chain to the End Investor. The KELER Participant can forward 
immediately the Corporate Action information obtained from KELER 
to the End Investor directly or through the custody chain. 

S10 - Currently intermediaries and investors with SWIFT connectivity 
may receive such announcements. Such practice is already part of 
the service of banks and custodians. 

S11 - Due to SRD II, intermediaries are to forward corporate action 
announcements to non-Intermediaries in case of listed shares. 

In case of other securities, only intermediaries and investors with 
SWIFT connectivity may receive such announcements. Such practice 
is already part of the service of banks and custodians. In case of End 
Investors without SWIFT connectivity the announcements relevant for 
the Investor are available through the web-based application of some 
of the custodians. Providing such service is not an obligation, in most 
cases it is not part of the custody service pack. For securities other 
than listed shares, the implementation of standard 4 is necessary for 
intermediaries providing services for End Investors. 

S13 - Hungarian regulations generally prescribe stricter deadlines. 
E.g. in case of equities the decision of the GM must contain the start 
date of the payment of dividend. In case of bonds the policy 
conditions must contain the payment date, etc. There is different 
regulation for each kind of securities, there is no general rule for 
announcement deadlines. The Issuer is not obliged to inform the CSD 
according to standard 1. After the implementation of standard 1 rules 
will be in line with this standard. 

S14 - There is no market practice for the announcement of the 
payable rate at least 3 business days before Payment Date. The 
communication of the payable rate depends on the decision of the 
Issuers. The revision of the current payment procedures is in 
progress in line with the implementation of the planned 
developments. The implementation of this standard is planned by 
December 2025. 

S16 - Dividend: Payment Date-5=Record Date 

Interest: Payment Date-2=Record Date 

The General Business Rules of KELER contains the dates above and 
the market practice for listed securities follows the above mentioned 
rules. The revision of the current payment procedures is in progress 
in line with the implementation of the planned developments. The 
implementation of this standard is planned by December 2025. 

S20a - KELER is not a central paying agent, Issuers may appoint any 
third party as paying agent. This way Payments are not always made 
through KELER. The revision of the current payment procedures is in 
progress in line with the implementation of the planned 
developments. The implementation of this standard is planned by 
December 2025. 

S20b - For listed shares, the payments are not yet done by KELER. 
For other securities, the announcement of the CSD according to the 
standards does not exist, but of course the payment is made in the 
currency published in the announcement of the Issuer published in 
other places. After the implementation of standard 1 and 20a rules 
will be in line with this standard. 

Corporate Events Compliance Report – Compliance assessment 

52 

 
 
Market 

Gaps 

Status 

Plan 

S20c - It is possible to transfer the payment before 12:00, however 
there is no obligation for the issuer or the paying agent to transfer 
before midday. If KELER is appointed as paying agent, KELER meets 
the deadline mentioned in the standard. The revision of the current 
payment procedures is in progress in line with the implementation of 
the planned developments. The implementation of this standard is 
planned by December 2025. 

S20e - According to the current market practice the Issuer transfers 
the correct amount after transferring back the incorrect payment. 
KELER participates in the process only if KELER is appointed as 
paying agent. This standard is planned to be implemented by 
December 2025. 

IE - Euroclear 
Bank   

S16, S20c  S16 - There is usually 3 to 4 weeks between the RD and the PD in 
the case of dividend payments. For interest payments the market is 
expected to be compliant (no data yet given recent migration to EB as 
issuer CSD). The event timetables factor in physical printing of 
fulfilment documentation to those holders who are currently holding in 
certificated form outside of the CSD. 

S16 – No plan 
S20c - Q4 2028 

S20c - Cash is not always credited before noon as cash needs to be 
received from issuer/registrar and reconciled by EB before EB can 
process the payment. However, Euroclear Bank has started a multi 
year program which foresees the migration of the legacy custody 
processing to a new Asset Servicing Platform. Compliance with 
corporate action standards is part of the scope of this project divided 
into multiple phases with an end delivery date expected around 2029. 
Cash Mandatory event will be covered during an interim phase 
planned in 2028. 

S9-S11 - Unknown by the CSD how well the CSD participants comply 
with the standard, all participants comply to the standard when it 
comes to specific voluntary corporate actions events such as rights 
exercise and tender offers. The expected implementation date is not 
known, to be discussed with participants. 

S9-S11 – No plan   

IS - Nasdaq CSD  S9-S11 

IT - Euronext 
Securities Milan 

S5 

As of today, CSD announcements are sent taking into account settled 
positions only, thus excluding any pending receipt and/or delivery that 
might impact the eligible balance 

Q1 2026 

LU - Clearstream 
Banking 
Luxembourg 

S12, S14, 
S15, S16, 
S20c 

MT - Malta Stock 
Exchange 

NO - Euronext 
Securities Oslo 

S3, S8-
S10, S16, 
S20a, 
S20e 

S1-S3, 
S5-S8, 
S10, S16, 
S19-
S20a, 
S20e 

S12, S15, S16 - In the 2024 assessment, two cases of incorrect use 
of key dates have been identified with the below details: 

S12, S14, S15, S16, S20c 
– No plan 

1. INTR event on ISIN CH1308692636 (structured product): 

XDTE 21.03.2024 / RD 20.03.2024 / PD 21.03.2024. 

2. DVCA event on ISIN IE000JQ2IJD3 (listed investment fund): 

XDTE 08.08.2024 / RD 07.08.2024 / PD 13.08.2024. 

It was clarified by CBL that case no. 1 above was due to a human 
error as the information received from the market was transferred into 
the ICSD’s system manually. 

S14 - Following the LIBOR transition, some new benchmark rates 
have a rate fixing date later than PD-3 that impacts the timing. 

S20b - Payments are made in the currency of the new securities 
(while the standards state that payments should be made in the 
original currency). 

S20c - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on currency, operating time-zone of 
the Agents as well as the timing that the issuers can release the 
payment (i.e. availability of cash). CBL had with Euroclear Bank a 
joint call with Common Depositories and Agents to explain the rules 
and the AMI-SeCo monitoring process. Although ICSDs timing 
requirements are to be reinforced in line with the SCoRE CA 
Standards, the dependency on issuers and their agents will remain. 

Marked as non-compliant following internal plausibility check. 

S1 - Legal barrier. The Issuer has no such obligation to inform the 
CSD. Key Dates are not always announced or very late 

All – Q3 2026 

S2 - Technical barrier. The rate setting and event lifecycle is two 
different events, not working according to standards. 

S3 - Technical barrier. CoBM is not confirmed via messaging, Event 
notification is sent. 

S5 - Technical barrier. Batch solution running EOD and not possible 
to deliver on Pending Transaction in the Underlying Security with the 
Issuer as understood from the event lifecycle processing. 

Corporate Events Compliance Report – Compliance assessment 

53 

 
 
 
Market 

Gaps 

Status 

Plan 

S6 - Technical barrier. Batch solution running EOD and not possible 
to inform participant who obtains a holding or is subject to a new 
Transaction on the Underlying Security after the announcement until 
the Record Date as understood from the event lifecycle processing. If 
event has a event update, new holdings will be included in this 
updated. 

S7, S10, S20e - Technical barrier. Not all information can be 
communicated in formatted electronic form using standards defined 
and used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S8 - Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. Legal Barrier. For 
Investors, Payments is executed in commercial bank money. 
Therefore, for the vast majority of Investors payments from Issuer will 
be done in commercial bank money. 

S10 - Technical barrier. Not all information can be communicated in 
formatted electronic form using standards defined and used by the 
securities industry, such as the ISO standards, irrespective of the 
communication channel used, owing to the CSD not providing the 
needed structure. 

S16 - Technical barrier for some cash payments. All Corporate 
Actions payments are paid via national payment infrastructure. 

S19 - Technical barrier. CSD does not use Trade date do define 
entitlements. 

S20a - Technical barrier. All CA payments are paid via national 
payment infrastructure. 

S20e - Also all CA payments are paid via national payment 
infrastructure. Legal Barrier. For Investors, Payments is executed in 
commercial bank money. Therefore, for the vast majority of Investors 
payments from Issuer will be done in commercial bank money. 

S8, S20e – A reversal process compliant with the standard cannot be 
implemented currently owing to legal barriers. In the opinion of 
KDPW, the mere fact of an error of an issuer or of KDPW may at 
most constitute grounds for the issuer or KDPW to demand that the 
person/KDPW participant to whom the undue benefit has been paid 
should return it but it does not, in itself, constitute grounds for the 
issuer or KDPW to be able to compulsorily (i.e. against the will of 
such person) enforce such benefit against such person. Furthermore, 
the risk must also be considered that the issuer may not have been in 
error at all and would like to use the reversal to collect the benefit 
paid through KDPW, to which the issuer has no legal title. 
S16 - The average period between the Payment Date and the Record 
Date is: 10 business days for dividend payments, 2 business days for 
Treasury bond interest payments, 7 business days for corporate bond 
interest payments. KDPW in their current assessment believe that the 
Market Deadline and Payment Date for chosen options is shortened 
to a minimum, taking into account functions necessary for the 
operation of the business process.    This relation is due to processes 
related to withholding of tax. Changing the period between Record 
Date and Payment Date requires a change in the Commercial 
Companies Code. There are no such plans yet. 

S8 - Q4 2025 
S16, S20e - No plan 

PL - KDPW 

S8, S16, 
S20e 

PT - Euronext 
Securities Porto   

S3, S8, 
S20e 

S3 - The information is communicated electronically through Euronext 
Securities Porto portal or e-mail. The ISO standards are not 
implemented yet. No appetite from the market. 

  Q4 2025 

S8 - Very few reversals exist in the market. When requested, the 
CSD always announces its participants by email when there is a 
correction and the reason for the same. 

S20e - Very few reversals exist in the market. When requested, the 
CSD makes corrections to the payments. 

As part of the Euronext New Corporate Event Service initiative, the 
compliance deadline is June 2025 for debt instruments (linked to 
ECMS) and November 2025 for other securities. 

RO - Depozitarul 
Central 

S2, S8 

S2 - Technical changes are needed. 

S8 - Prior to the processing of a reversal the information is 
communicated by the CSD to the affected parties in a proprietary 
form (via email). In the context of AMI-SeCo SCoRE standards 
implementation, the CSD plans to implement the standard 
notifications and automated flows according to Standard no. 13 
(Reversal of a corporate action) by November 2025. 

S2 - No plan 

S8 – Q4 2025 

RO - SaFIR 

S8, S20e  All - Ongoing development and implementation 

All – Q4 2025 

Corporate Events Compliance Report – Compliance assessment 

54 

 
 
 
 
Market 

Gaps 

Status 

SE - Euroclear 
Sweden 

S3, S4, 
S7, S8,, 
S20c, 
S20e 

S3 - The CSD has functionality for formatted, electronic 
communication of most cash distribution event information from 
issuers. CA event information not covered by the solution is provided 
by issuers to the CSD via more manual means. 

Plan 

No plan 

S4 - There is no place for narrative in the CSD communication 
interface for cash distributions. An amendment of the CSD rules 
requiring ""avitext"" in both English and Swedish was implemented 
late 2011. 

S7 - Some intermediaries still use the old, non-ISO, interface. The 
CSD offers an older version of CA information interface. The old 
version contains the same information – the ISO 15022 messages 
are created from that information – but in a different format. CSD 
participants are not required to migrate to ISO 15022 messages and 
as the old version also contains information not provided in ISO 
15022 messages, not all CSD participants want to maintain access to 
both. The CSD's ISO 15022 interface does not cover all events, but 
the "non-covered" events are rare. 

S8, S20e - Reversals are not performed by the CSD due to legal 
reasons, and this has been the case since start of the CSD. In earlier 
years the SE MIG have stated that Standard 8 was complied with 
compliant since Euroclear Sweden, in case a payment would ever be 
reversed, would have sent such an announcement. However, 
following a legal analysis performed by a Government Inquiry, it was 
clarified early 2024 that a reversal of a cash distribution is in breach 
with Swedish property law, which is why the CSD would never 
perform such a reversal. 

S20c - Payments from issuers can technically be made until 15.30, 
but the CSD's rules for issuers state that payments should be made 
no later than 12 noon. Generally, events are paid by 12 noon. 

SK - CDCP   

All 
standards 

S1-S4 - Standard in process of implementation. Cash distributions 
are currently managed by issuers or issuer’s agent, the CSD does 
not provide such service yet. 

All standards – Q1 2026 

S5-S8 – Standard in process of implementation. The Slovak CSD 
only provides CA notification with regards to static data on issues 
(e.g. nominal value change) – for these one it could be assessed as 
100% completed. However, for the other types of CAs – participants 
have to look for this information themselves, there is no really 
functional centralised source of CAs. 

S9-S15 – Custodians are awaiting the implementation from the 
CDCP SR’s side. 

S16 – Custodians: For fixed income, Equities still have “payment 
period” for dividends. We are awaiting the implementation from the 
CDCP SR’s side. 

UK - Euroclear 
UK & 
International 

S17, S18 
S20a 

(Gaps identified in the 2023 monitoring exercise) 

S17, S20a – Q1 2024 

S17, S20a – No information provided. 

S18 – MMI – redemptions are currently not compliant. 

S18 – This will be 
addressed during the EUI 
Transformation 
programme that is 
occurring. 

Corporate Events Compliance Report – Compliance assessment 

55 

 
 
 
3.1.2 

Security Distributions 

Chart 2 
Security Distributions – % compliance per market 

Notes: N/A. 

Box 5 
Security Distributions – Compliance status per Standard 

Information from 
Issuer to Issuer 
(I)CSD 

Information from Issuer 
(I)CSD to its participants 

Information flow 
from (I)CSD 
participants to 
End Investors 

Key dates 

Processing 

AT – Oesterreichische 
Kontrollbank 

1 

B 

BE – Euroclear Bank 

B 

BE – Euroclear 
Belgium 

BE – NBB-SSS 

B 

B 

2 

B 

B 

B 

B 

3 

B 

B 

B 

B 

4 

B 

B 

B 

B 

5 

B 

B 

B 

B 

6 

B 

B 

B 

B 

7 

B 

B 

B 

B 

8 

B 

B 

B 

B 

9 

B 

B 

B 

B 

10 

11 

12 

13 

14 

15 

16a 

16b 

16c 

17a 

17b 

17c 

17d 

B 

B 

B 

B 

B 

B 

B 

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 

B 

B 

B 

0% 

0% 

0% 

0% 

0% 

0% 

B 

B 

B 

B 

B 

B 

B 

N/A  N/A  N/A  N/A  N/A 

BG – BNBGSSS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

BG – CD AD 

CH – SIX SIS 

CY – Cyprus Stock 
Exchange 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

CZ – CSD Prague 

B 

75%  75% 

B 

B 

75% 

B 

B 

75%  75%  25%  75% 

B 

25% 

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 

CZ – SKD 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

DE – Clearstream 
Banking Frankfurt 

DK – Euronext 
Securities 
Copenhagen 

EE – Nasdaq CSD 

ES – Iberclear 

N/A  N/A  N/A 

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 

0% 

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 

B 

75% 

B 

B 

B 

0% 

Corporate Events Compliance Report – Compliance assessment 

56 

0%10%20%30%40%50%60%70%80%90%100%AT - Oesterreichische KontrollbankBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - Nasdaq CSDES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSGR - ATHEXCSDHR - SKDDHU - KELERIE - Euroclear BankIS - NasdaqIT - Euronext Securities MilanLI - SIX SISLT - Nasdaq CSDLU - Clearstream Banking LuxembourgLU - LuxCSDLV - Nasdaq CSDMT - Malta Stock ExchangeNL - Euroclear NederlandNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4PT - Euronext Securities PortoRO - Depozitarul CentralRO - SaFIRSE - Euroclear SwedenSI - KDDSK - CDCPUK - Euroclear UK & International 
 
 
 
  
Information from 
Issuer to Issuer 
(I)CSD 

Information from Issuer 
(I)CSD to its participants 

Information flow 
from (I)CSD 
participants to 
End Investors 

Key dates 

Processing 

FI – Euroclear 
Finland 

FR – Euroclear 
France 

1 

B 

B 

2 

B 

B 

3 

B 

B 

4 

B 

B 

5 

B 

B 

6 

7 

8 

B 

25% 

B 

B 

B 

B 

9 

B 

B 

10 

11 

12 

13 

14 

15 

16a 

16b 

16c 

17a 

17b 

17c 

17d 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25% 

B 

B 

GR – BOGS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

GR – ATHEXCSD 

HR – SKDD 

B 

B 

B 

B 

B 

25% 

B 

B 

B 

B 

B 

B 

B 

25% 

B 

B 

HU – KELER 

50%  50%  50%  25%  50%  50%  25%  50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

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 

B 

IE – Euroclear Bank 

IS – Nasdaq CSD 

IT – Euronext 
Securities Milan 

LI – SIX SIS 

LT – Nasdaq CSD 

LU – Clearstream 
Banking 
Luxembourg 

LU – LuxCSD 

LV – Nasdaq CSD 

MT – Malta Stock 
Exchange 

NL – Euroclear 
Nederland 

NO – Euronext 
Securities Oslo 

B 

B 

B 

B 

B 

B 

50% 

B 

B 

50%  50%  50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

0% 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25% 

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 

25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25% 

25%  25%  25%  25%  25% 

0% 

0% 

0% 

0% 

0% 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

0% 

50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

0% 

0% 

B 

B 

B 

0% 

75% 

B 

50%  25%  75%  50% 

B 

75% 

B 

PL – KDPW 

B 

50% 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

75% 

B 

B 

50%  75% 

0% 

B 

B 

B 

B 

B 

B 

B 

PL – SKARBNET4 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

PT – Euronext 
Securities Porto 

RO – Depozitarul 
Central 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

75% 

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 

75% 

B 

B 

RO – SaFIR 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

SE – Euroclear 
Sweden 

75% 

0% 

75% 

B 

SI – KDD 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

75% 

0% 

B 

B 

B 

B 

B 

SK – CDCP 

75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75% 

UK – Euroclear UK & 
International 

0% 

0% 

0% 

0% 

0% 

0%  N/A 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Notes: Security Distributions are outside the scope of BNBGSSS, SKD, BOGS, SKARBET4 and SaFIR activities. 

Table 2 
Security Distributions – Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the Security 
Distributions standards. Markets/CSDs not listed below have been assessed as fully 
compliant. 

Market 

Gaps 

Status 

Plan 

BE – Euroclear 
Bank 

 S16b-
S17d 

S16b,c, S17a-S17d - The Euroclear Bank Nominee would receive a 
whole number of shares (no fractions) and would apply a rounding 
methodology which ensures that all shares are distributed to its 
participants. However, Euroclear Bank’s current methodology consist 
of rounding up to the largest shareholder and is therefore not 
compliant with the standard. Further feedback is needed from 
Euroclear Bank on when the ICSD will apply the top-down method 
(rounding down to the nearest whole number, in line with the 
standard) instead. 

S16b-S17d – No plan 

S17d - Q4 2024 

Corporate Events Compliance Report – Compliance assessment 

57 

 
 
 
  
Market 

Gaps 

Status 

Plan 

BG – CD AD 

S3 

Q1 2025 

S17c - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on currency, operating time-zone of 
the Agents as well as the timing that the issuer can release the 
payment (i.e., availability of cash). The concrete action taken is the 
update of MOP (Manual of Procedure) shared with Common 
Depositories and Agents in October 2024. This is a contractual 
document in which Euroclear Bank recommended the deadline to be 
compliant with those standards (and also SCoRE). Euroclear Bank 
had (with CBL) a joint call with some of those agents to explain the 
rules and the AMI-SeCo monitoring process. To be fully implemented 
by November 2024. 

According to the Rules of the Bulgarian Stock Exchange (Part III, 
Article 5. (1), item 10) the companies listed on the Premium segment 
of the BSE disclose regulated information to the general public 
simultaneously in Bulgarian and in English through the media chosen 
by the company within the respective deadlines. Other issuers are not 
obliged to publish information in English. Where applicable, the 
recently developed Electronic Platform for General Meetings (EPOS) 
may also be employed to obtain narrative text, inserted in a dedicated 
section for CA data announcement in Bulgarian and English. The 
corresponding amendments in the law are expected. There are plans 
to include the standard in the list of upcoming changes to the 
Bulgarian Stock Exchange (BSE) Trading Rules for the next 
amendment session. CDAD is unable to commit to a specific date for 
the next amendment session of the BSE Trading Rules, as this action 
falls exclusively under the authority of the BSE. Relevant discussions 
have taken place between the two institutions, and CDAD has 
received assurances that all necessary actions will be taken to 
incorporate the required provisions into the referenced document. It is 
also important to note that the proposed amendments are subject to 
approval by the Financial Supervision Commission (FSC). 
Nonetheless, CDAD remains confident that the standard will be 
achieved within the designated timeframe. 

CY – CSE 

S8-S10 

S9, S10 – Technical changes in custodians’ infrastructures are 
currently assessed. 

No plan 

CZ – CSD Prague  S2, S3, 
S5, S6, 
S8, S9-
S12, S14 

S2, S5, S8 – Q2 2025  

S3, S6, S9, S10, S11, 
S12, S14 – No plan 

S2 – The laws provide for formatted electronic form only for listed 
shares, for other securities the information is usually communicated 
in the same format as is published on the websites of the issuer (pdf). 
In case that issuer of listed shares does not inform the shareholders 
directly, the communication is in the format of Table 8 of 
IR 2018/1212. There is a plan of CSD Prague to impose an obligation 
of listed bonds issuers to inform about CA in ISO 20022 in order to 
comply with ScoRE (by June 2025). 

S3 - Issuers of listed shares provide the information in English as 
well. There is an obligation from Art. 2/2 of IR 2018/1212. For non-
listed securities, there is no obligation to inform in English. In practice, 
SMEs with international shareholder base would use bilingual text. 
There is no plan to change the law to increase administrative burden 
of all companies with book-entry shares or issuers of book-entry 
bonds to inform shareholders via CSD in English. 

S5 – The CSD informs all of its participants. There is no obligation for 
CSD to inform only relevant participants. There is a plan to inform 
also participants obtaining securities on the day between 
announcement and record date (by June 2025). 

S6 – The laws provide for formatted electronic form only for listed 
shares (Art. 2/2 of IR 2018/1212 for listed shares), for other securities 
the information is usually communicated in the same format as is 
published on the websites of the issuer (pdf). There is a plan by CSD 
Prague to impose an obligation of listed bonds issuers to inform 
about CA in ISO 20022 in order to comply with SCoRE by June 
2025). There is a plan of CSD Prague to impose an obligation of 
listed bonds issuers to inform about CA in ISO 20022 in order to 
comply with SCoRE by June 2025).   

There is no plan to change the law to increase administrative burden 
of all companies with book-entry shares or issuers of book-entry 
bonds to inform shareholders via CSD. 

S8 – Implemented only for listed shares and services of Investor 
CSD, i.e. for foreign securities, when CSD and its participants should 
inform their clients. 

With respect to listed shares, there is an obligation to transmit the 
information in two level register as owners of accounts on the second 
level of register are considered to be the shareholders. Records in 
any kind of sub-register about end investors are not considered as 
book-entry shares and issuers provide payments to those named in 
the list of shareholders on record date.     

Corporate Events Compliance Report – Compliance assessment 

58 

 
 
 
Market 

Gaps 

Status 

Plan 

With respect to other Czech securities, there is no obligation at the 
moment and only participants providing custodial services would 
inform clients about a corporate action. Level of these services is not 
harmonized. 

There is an effort of CSD Prague to motivate its participants holding 
listed bonds to be compliant with SCoRE and to transmit information 
about CA in ISO 20022 (by June 2025). 

S9 – Partly implemented only for listed shares and for services of 
Investor CSD, i.e. for foreign securities. With respect to listed shares, 
there is an obligation to transmit the information in electronic and 
machine-readable formats (2/2 of IR 2018/1212). With respect to 
Czech securities, there is no obligation at the moment. There is a 
plan of CSD Prague to transmit information to its participants in ISO 
20022.   

There is no plan with respect to non-listed companies with book-entry 
shares or issuers of book-entry bonds. 

S10 – Implemented only for listed shares and services of Investor 
CSD, i.e. for foreign securities. With respect to Czech securities, 
there is no obligation at the moment. There is no such obligation in 
the valid legislation, including IR 2018/1212. IR allows for URL 
hyperlink to websites. 

S11 – According to law, issuers of shares can distribute the proceeds 
only to shareholders that are stated on record date in the list of 
shareholders and only to the bank account stated in the list of 
shareholders. It is not possible for the issuer to distribute proceeds to 
someone who is not a shareholder (on record date). Similar applies to 
owners of bonds. At the moment, CSD Prague only extraordinarily 
distributes proceeds in securities. With respect to listed shares or 
bonds, rules of Prague Stock Exchange acknowledge the right of 
non-defaulting party to receive compensation of rights due to default 
of the other party on the record date and the obligation of defaulting 
participant to provide the compensation (the proceeds) to non-
defaulting party via CSD. There are no compensations of rights 
organised by CSD in case of late settlement for non-listed or OTC 
trades. The definition ex-date has no consequences. 

There is no plan to impose an obligation to distribute proceeds only 
via CSD – neither contractual obligation imposed by CSD to issuers 
as its clients, nor legal from the legislators. 

There is no plan to acknowledge by law the right of an issuer to 
distribute proceeds to non-defaulting party instead of shareholder 
registered on record date. 

S12 – For non-listed securities, there is no obligation to announce 
distribution of proceeds publicly. Only issuers of listed securities are 
obliged by the law to inform its issuer CSD about a distribution of 
proceeds. This information is published on the websites of CSD. 
These issuers should inform their (issuer’s) CSD in the same 
deadline for fulfilling the obligation to announce publicly the corporate 
action. For non-listed securities, there is not always an obligation to 
announce corporate action publicly. CSD should communicate the 
information from issuer of listed book-entry shares to participants (in 
case the issuer provided the information to CSD) to its participants. 
Deadlines to be complied with are set in Art. 9/2 of IR 2018/1212. 

S14 – Distribution of securities may be performed the next Business 
Day after the Record Date. When it is the Issuer that instructs the 
CSD how to perform distribution of securities, the Record Date may 
be in the past. 

DK – Euronext 
Securities 
Copenhagen 

S17d 

For debt securities, a compliant solution will be implemented in line 
with the SCoRE deadline, i.e., June 2025. For equity instruments, the 
deadline is November 2025. 

Q4 2025 

ES – Iberclear 

S7, S17d  S7, S17d – As described in the last Standards Market Progress 

All – Q4 2025 

Report (November 2023), Iberclear is already working on the 
implementation of this standard. There are some open points which 
should be covered at the CSD level and at the European Community 
level related to the difficulties to settle securities instructions if there is 
a lack of securities in any of the safekeeping accounts. One 
custodian indicates that it is waiting for ECMS implementation. The 
standard will be implemented by Q4 2025. 

FI – Euroclear 
Finland 

S7, S17d   S7, S17d – The Finnish regulation does not identify or allow a 

No plan 

reversal of a corporate action event that has been settled on the 
securities accounts. Hence, a full reversal process as defined in 
SCoRE CA standards cannot be implemented. Manual corrections 
may be required depending on the case. 

Corporate Events Compliance Report – Compliance assessment 

59 

 
 
Plan 

S3 – Q3 2025 

S7, S17d – No plan 

S1-S6, S8, S10 – 12-2024 
S7, S12, S16a, S16c- 
S17d – 12-2025 

Market 

Gaps 

Status 

HR – SKDD 

S3, S7, 
S17d 

HU – KELER 

S1-S8, 
S10, S12, 
S16a, 
S16c- 
S17d 

S3 – The standard has been implemented regarding the general 
meeting, but not prescribed by law and it is not implemented in the 
Rules and Procedures. The CDCC will implement standard in its 
Rules and Procedures and in Corporate Action Manual in accordance 
with applicable law. 

S7, S17d – Payment reversals are not allowed currently. No 
amendments to the law governing the procedure in the event of an 
erroneous remittance of funds are needed. However, the SKDD pays 
most payments from CAs to the accounts of the Beneficiary owners 
and, currently, the SKDD does not have the authority to directly debit 
their bank account (even if it did, these accounts would have to have 
sufficient funds necessary for the reversal). SKDD can only invite the 
Beneficiary owners to remit the funds paid from the CA, noting that 
until all the funds paid from the CA have been returned, the SKDD 
must not announce and implement a reversible CA. 

S1 - From 3 September 2020 due to SRD II, KELER introduced its 
Corporate Action notification services for listed shares. The CSD’s 
corporate action database is established, which increases the 
accessibility of corporate action information. Market players are 
informed on the details of the corporate actions after the 
announcement of the issuer, from the Issuer CSD. Announcements 
for corporate actions of securities other than listed equities remain 
with the existing announcement publication places: stock exchange, 
central bank’s website, issuer’s website. The extension of the 
corporate action announcement services of KELER to securities other 
than listed shares is planned by December 2024. 

S2 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form.   

Regarding securities other than listed equities: A corporate action 
database is available through KELER’s proprietary communication 
system (KID) and on its website with limited range of information 
(only date and type of corporate action). Currently the Issuers do not 
inform the End Investors electronically. The standard is partially 
implemented at the moment, as the Issuers publish the information in 
the legally required places (on their own website, on kozzetetelek.hu 
website, and the listed Issuers on the website of the stock exchange). 
The extension of the corporate action announcement services of 
KELER to securities other than listed shares is planned by November 
2023. 

S3 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer. The major 
Issuers and/or Issuers with considerable foreign ownership are 
currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER’s General Business Rules shall be modified according to this 
standard. 

S4 – The implementation of this standard will be relevant during the 
implementation of standard 1. This standard will be implemented 
simultaneously with standard 1 for debt securities. 

S5 – KELER, as issuer CSD receives the corporate action 
information from the issuers of listed shares according to standard 1 
in formatted electronic form. Regarding securities other than listed 
equities: A corporate action database is available through KELER’s 
proprietary communication system (KID) and on its website with 
limited range of information (only date and type of corporate action). 

Currently the Issuers do not inform the End Investors electronically. 
The standard is partially implemented at the moment, as the Issuers 
publish the information in the legally required places (on their own 
website, on kozzetetelek.hu website, and the listed Issuers on the 
website of the stock exchange). The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

S6 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer.   

The major Issuers and/or Issuers with considerable foreign ownership 
are currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER’s General Business Rules shall be modified according to this 
standard. 

Corporate Events Compliance Report – Compliance assessment 

60 

 
 
Market 

Gaps 

Status 

Plan 

S7 – The reversal of the payment is not market practice, currently the 
Issuer transfers the corrected amount after transferring back the 
incorrect first payment. 

KELER participates in the procedure if KELER is appointed as paying 
agent. This standard is planned to be implemented by December 
2025. 

S8 – In case of listed shares, KELER Participants receive the issuer’s 
announcement from KELER and they forward it further down the 
chain. 

In case of other securities KELER participants obtain CA information 
not from the Issuer through KELER, but by processing the information 
published by the Issuer. They forward the information obtained the 
before mentioned way directly or through the custody chain to the 
End Investor. The KELER Participant can forward immediately the 
Corporate Action information obtained from KELER to the End 
Investor directly or through the custody chain. 

S10 - Due to SRD II, intermediaries are to forward corporate action 
announcements to non-Intermediaries in case of listed shares. 

In case of other securities, only intermediaries and investors with 
SWIFT connectivity may receive such announcements. Such practice 
is already part of the service of banks and custodians. In case of End 
Investors without SWIFT connectivity the announcements relevant for 
the Investor are available through the web-based application of some 
of the custodians. Providing such service is not an obligation, in most 
cases it is not part of the custody service pack. For securities other 
than listed shares, the implementation of standard 4 is necessary for 
intermediaries providing services for End Investors. 

S12 - Hungarian regulations generally prescribe stricter deadlines. 
E.g. in case of equities the decision of the GM must contain the start 
date of the payment of dividend. In case of bonds the policy 
conditions must contain the payment date, etc. There is different 
regulation for each kind of securities, there is no general rule for 
announcement deadlines. The Issuer is not obliged to inform the CSD 
according to standard 1. After the implementation of standard 1 rules 
will be in line with this standard. 

S16a - There is no obligation for the issuer or the paying agent to 
transfer as early as possible on the Payment Date. 

The revision of the current payment procedures is in progress in line 
with the implementation of the planned developments. The 
implementation of this standard is planned by December 2025. 

S16c – Securities distribution is a very rare event type in Hungary. 
The Fractions can be handled on an exceptional basis. The revision 
of the current payment procedures is in progress in line with the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

S17a – As KELER is not a central paying agent, it is not obligatory to 
make the payments through the CSD. Such payments can be 
handled on an exceptional basis. The revision of the current payment 
procedures is in progress in line with the implementation of the 
planned developments. The implementation of this standard is 
planned by December 2025. 

S17b - For listed shares, the payments are not yet done by KELER. 
For other securities, the announcement of the CSD according to the 
standards does not exist, but of course the payment is made in the 
currency published in the announcement of the Issuer published in 
other places. After the implementation of standard 1 and 17a rules 
will be in line with this standard. 

S17c - It is possible to transfer the payment before 12:00, however 
there is no obligation for the issuer or the paying agent to transfer 
before midday. The revision of the current payment procedures is in 
progress in line with the implementation of the planned 
developments. The implementation of this standard is planned by 
December 2025. 

S17d - According to the current market practice the Issuer transfers 
the correct amount after transferring back the incorrect payment. 
KELER participates in the process only if KELER is appointed as 
paying agent. This standard is planned to be implemented by 
December 2025. 

Corporate Events Compliance Report – Compliance assessment 

61 

 
 
Market 

Gaps 

Status 

IE – Euroclear 
Bank 

S16b-
S17d 

S16b,c, S17a-S17d – The Euroclear Bank Nominee would receive a 
whole number of shares (no fractions) and would apply a rounding 
methodology which ensures that all shares are distributed to its 
participants. However, Euroclear Bank’s current methodology consist 
of rounding up to the largest shareholder and is therefore not 
compliant with the standard. Further feedback is needed from 
Euroclear Bank on when the ICSD will apply the top-down method 
(rounding down to the nearest whole number, in line with the 
standard) instead. 

Plan 

No plan 

IS – Nasdaq CSD  S8-S10 

S8-S10 – Unknown by the CSD how well the CSD participants 
comply with the standard, all participants comply to the standard 
when it comes to specific voluntary corporate actions events for 
example Rights issues and dividend payments. 

S8-S10 – No plan 

IT – Euronext 
Securities Milan 

S4 

As of today, CSD announcements are sent taking into account settled 
positions only, thus excluding any pending receipt and/or delivery that 
might impact the eligible balance. 

Q1 2026 

LU – 
Clearstream 
Banking 
Luxembourg 

S16a, 
S17b, c  

MT – Malta Stock 
Exchange 

NO – Euronext 
Securities Oslo 

S2, S8, 
S9, S16b-
S17a, 
S17d 

S1, S2, 
S4-S7, 
S9, S14, 
S16b,c, 
S17a,d 

S16a, S17b,c – No plan 

S16a – This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on when the issuer’s agent can 
deliver the securities. CBL had with Euroclear Bank a joint call with 
Common Depositories and Agents to explain the rules and the AMI-
SeCo monitoring process. Although ICSDs timing requirements are to 
be reinforced in line with the ScoRE CA Standards, the dependency 
on issuers and their agents will remain. 

S17b - Payments are made in the currency of the new securities 
(while the standards state that payments should be made in the 
original currency). 

S17c – This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of the payments of fractions in cash depends on currency 
as well as operating time-zone of the Agents. CBL had with Euroclear 
Bank a joint call with Common Depositories and Agents to explain the 
rules and the AMI-SeCo monitoring process. Although ICSDs timing 
requirements are to be reinforced in line with the ScoRE CA 
Standards, the dependency on issuers and their agents will remain. 

Marked as non-compliant following internal plausibility check. 

S1 - Legal barrier. The Issuer has no such obligation to inform the 
CSD. Key Dates are not always announced or very late. There is no 
applicable law defining the Issuer to inform specifically the CSD. 

All – Q3 2026 

S2, S9, - Technical barrier. Not all information can be communicated 
in formatted electronic form using standards defined and used by the 
securities industry, such as the ISO standards, irrespective of the 
communication channel used. 

S4 – Technical barrier. Batch solution running EOD and not possible 
to deliver on Pending Transaction in the Underlying Security with the 
Issuer as understood from the event lifecycle processing. 

S5 – Technical barrier. Batch solution running EOD and not possible 
to inform participant who obtains a holding or is subject to a new 
Transaction on the Underlying Security after the announcement until 
the Record Date as understood from the event lifecycle processing. If 
event has an event update, new holdings will be included in this 
updated. 

S6 – Technical barrier. Not all information and events can be 
communicated in formatted electronic form using standards defined 
and used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S7 – Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S14 – Technical barrier for some securities payments are impacted 
by the cash payments processing. 

S16b – Technical barrier. Existing system has a fragments processing 
of some securities payments. Legal barrier CSD register authorisation 
impacts the processing (rounding aggregation) of investors owning 
multiple safekeeping accounts. 

S16c – Legal barrier. No requirements on the issuer to compensate 
fraction is cash, when they can do rounding any way the choose as 
per 16.b). 

Corporate Events Compliance Report – Compliance assessment 

62 

 
 
 
Market 

Gaps 

Status 

Plan 

17a – Technical barrier. All Corporate Actions securities payments are 
paid via write-up of the securities ledger. 

17d – Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. Also, all Corporate 
Actions payments are paid via national payment infrastructure. Legal 
Barrier. For Investors, payments are executed in commercial bank 
money. Therefore, for the vast majority of Investors payments from 
Issuer will be done in commercial bank money. 

PL – KDPW 

S2, S7, 
S17d 

S2 – The communication from the issuer to the CSD is in electronic 
form, however the data provided is not formatted in compliance with 
ISO standards. 

S2 - Q4 2026 

S7, S17d – No plan 

S7, S17d – As per decision of AMI-SeCo NSG PL, the reversals 
processing will not be implemented for securities distributions. A 
reversal process compliant with the standard cannot be implemented 
currently owing to legal barriers. In the opinion of KDPW, the mere 
fact of an error of an issuer or of KDPW may at most constitute 
grounds for the issuer or KDPW to demand that the person/KDPW 
participant to whom the undue benefit has been paid should return it 
but it does not, in itself, constitute grounds for the issuer or KDPW to 
be able to compulsorily (i.e. against the will of such person) enforce 
such benefit against such person. Furthermore, the risk must also be 
considered that the issuer may not have been in error at all and 
would like to use the reversal to collect the benefit paid through 
KDPW, to which the issuer has no legal title. 

PT – Euronext 
Securities Porto 

S2, S7, 
S17d  

S2 – The information is communicated electronically through 
Euronext Securities Porto portal or e-mail. The ISO standards are not 
implemented yet. No appetite from the market. 

Q4 2025 

S7 – Very few reversals exist in the market. When requested, the 
CSD always announces its participants by email when there is a 
correction and the reason for the same. 

S17d – Very few reversals exist in the market. When requested, the 
CSD makes corrections to the payments. 

As part of the Euronext New Corporate Event Service initiative, the 
compliance deadline is June 2025 for debt instruments (linked to 
ECMS) and November 2025 for other securities. 

S7 – Prior to the processing of a reversal the information is 
communicated by the CSD to the affected parties in a proprietary 
form (via email). In the context of AMI-SeCo ScoRE standards 
implementation, the CSD plans to implement the standard 
notifications and automated flows according to Standard no. 13 
(Reversal of a corporate action) by November 2025. 

RO – Depozitarul 
Central 

 S7 

SE – Euroclear 
Sweden 

S1-S3, 
S7, S14, 
S17a, 
S17c, 
S17d 

S1 - For distributions of interim securities, the ISIN cannot be 
included in the official announcement since it cannot be requested 
before it. However, the ISIN is generally not provided as soon as 
possible. No compensation price for fractions is announced – but the 
method of determining the price is usually announced. Barrier: The 
CSD cannot generate ISINs for interim securities (rights etc.) until the 
CSD registers the event in its system. 

Q4 2025 

No plan 

S2 – Securities distribution event information is provided by issuers to 
the CSD via manual means. 

S3 – An amendment of the CSD rules requiring “”avitext”” in both 
English and Swedish was implemented late 2011. 

S7, S17d - Reversals are not performed by the CSD due to legal 
reasons, and this has been the case since start of the CSD. In earlier 
years the SE MIG have stated that Standard 7 was complied with 
compliant since Euroclear Sweden, in case a payment would ever be 
reversed, would have sent such an announcement. However, 
following a legal analysis performed by a Government Inquiry, it was 
clarified early 2024 that a reversal of a cash distribution is in breach 
with Swedish property law, which is why the CSD would never 
perform such a reversal. 

S14 – The CSD does not require pay date to be the day after record 
date. Pay date equal to record date + 2 is common for distribution of 
rights and stock dividends. 

S17a – Compensation of fractions are rare in securities distributions. 
Payments from issuers are made outside of the CSD. There is a 
tentative plan to move the payments into the CSD settlement system, 
but there is not yet any date for this. 

S17c – Payments from issuers can be made until 14.00. 

SK – CDCP 

All 
standards 

S1-S7, S11-S13, S15-S17d – Standard in process of implementation 
in the CSD. 

All – Q1 2026 

Corporate Events Compliance Report – Compliance assessment 

63 

 
 
 
 
Market 

Gaps 

Status 

Plan 

S8-S10 – Custodians are awaiting the implementation from the 
CDCP SR's side. 

S14 - Standard in process of implementation in CSD. Custodian: For 
fixed income, Equities still have ""payment period"" for dividends. 

3.1.3 

Distributions with Options 

Chart 3 
Distributions with Options – % compliance per market 

Notes: N/A. 

Corporate Events Compliance Report – Compliance assessment 

64 

0%10%20%30%40%50%60%70%80%90%100%AT - Oesterreichische KontrollbankBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - Nasdaq CSDES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSGR - ATHEXCSDHR - SKDDHU - KELERIE - Euroclear BankIS - NasdaqIT - Euronext Securities MilanLI - SIX SISLT - Nasdaq CSDLU - Clearstream Banking LuxembourgLU - LuxCSDLV - Nasdaq CSDMT - Malta Stock ExchangeNL - Euroclear NederlandNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4PT - Euronext Securities PortoRO - Depozitarul CentralRO - SaFIRSE - Euroclear SwedenSI - KDDSK - CDCPUK - Euroclear UK & International 
 
 
 
Table 3 
Distributions with Options – Compliance status per Standard 

AT - Oesterreichische Kontrollbank 

BE - Euroclear Bank 

BE - Euroclear Belgium 

BE - NBB-SSS 

BG - BNBGSSS 

BG - CD AD 

CH - SIX SIS 

CY - Cyprus Stock Exchange 

CZ - CSD Prague 

CZ - SKD 

DE - Clearstream Banking Frankfurt 

DK - Euronext Securities Copenhagen 

EE - Nasdaq CSD 

ES - Iberclear 

FI - Euroclear Finland 

FR - Euroclear France 

GR - BOGS 

GR - ATHEXCSD 

HR - SKDD 

HU - KELER 

IE - Euroclear Bank 

IS – Nasdaq CSD 

IT - Euronext Securities Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - Clearstream Banking Luxembourg 

LU - LuxCSD 

LV - Nasdaq CSD 

MT - Malta Stock Exchange 

NL - Euroclear Nederland 

NO - Euronext Securities Oslo 

PL - KDPW 

PL - SKARBNET4 

PT - Euronext Securities Porto 

RO - Depozitarul Central 

RO - SaFIR 

SE - Euroclear Sweden 

SI - KDD 

SK - CDCP 

UK - Euroclear UK & International 

1 

B 

B 

B 

N/A 

N/A 

B 

B 

0% 

50% 

N/A 

75% 

75% 

B 

B 

2 

B 

B 

B 

N/A 

N/A 

B 

B 

0% 

50% 

N/A 

B 

75% 

B 

B 

25% 

25% 

B 

N/A 

0% 

B 

25% 

25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

N/A 

B 

B 

B 

N/A 

0% 

B 

25% 

25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

N/A 

B 

B 

N/A 

N/A 

B 

B 

25% 

0% 

B 

B 

25% 

0% 

3 

B 

50% 

B 

N/A 

N/A 

4 

B 

B 

B 

N/A 

N/A 

75% 

75% 

B 

0% 

50% 

N/A 

B 

B 

B 

75% 

25% 

B 

N/A 

0% 

50% 

25% 

25% 

50% 

50% 

B 

B 

B 

0% 

50% 

N/A 

B 

75% 

B 

75% 

25% 

B 

N/A 

0% 

B 

25% 

25% 

B 

B 

B 

B 

50% 

50% 

B 

B 

50% 

B 

50% 

50% 

N/A 

75% 

0% 

N/A 

75% 

B 

25% 

0% 

B 

B 

B 

B 

50% 

B 

N/A 

B 

50% 

N/A 

75% 

B 

25% 

0% 

5 

B 

B 

B 

N/A 

N/A 

B 

75% 

0% 

50% 

N/A 

B 

B 

B 

B 

6 

B 

B 

B 

N/A 

N/A 

B 

B 

0% 

50% 

N/A 

B 

B 

B 

B 

25% 

25% 

B 

N/A 

B 

B 

25% 

25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

N/A 

B 

B 

25% 

25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

N/A 

N/A 

B 

B 

B 

B 

N/A 

N/A 

B 

B 

25% 

0% 

B 

B 

25% 

0% 

Notes: Distributions with Options are outside the scope of NBB-SSS, BNBGSSS, BOGS, SKD, SKARBET4 and SaFIR activities. As 
agreed by the CEG during the 2021 compliance monitoring exercise, full compliance with the Distributions with Options standards 
should only be possible once full compliance with the Security Distributions standards has been achieved. If a market does not fully 
comply with Security Distribution standards, standard 3 of the Distributions with Options standards will be systematically assessed as 
not implemented. 

Corporate Events Compliance Report – Compliance assessment 

65 

 
 
  
Table 4 
Distributions with Options - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the 
Distributions with Options standards. Markets/CSDs not listed below have been assessed as 
fully compliant. 

Market 

Gaps 

Status 

BE – Euroclear 
Bank 

S3 

BG – CD AD 

S3, S4  

S3 - Regarding Distributions with Options, as agreed by the CEG 
during last year’s compliance monitoring exercise, full compliance 
with the Distributions with Options standards should only be possible 
once full compliance with the Security Distributions standards has 
been achieved. Standard 3 of the Distributions with Options 
standards will thus be assessed as not implemented 

S3 - Regarding Distributions with Options, as agreed by the CEG 
during last year’s compliance monitoring exercise, full compliance 
with the Distributions with Options standards should only be possible 
once full compliance with the Security Distributions standards has 
been achieved. Standard 3 of the Distributions with Options 
standards will thus be assessed as not implemented. 

S4 - The evaluation reflects the overall assessments, concerning both 
Mandatory and Voluntary Reorganisations with Options. 

Plan 

No plan 

S3, S4 – Q1 2025 

CH – SIX SIS 

S5 

S5 – The election period is less than the required 10 days. 

CY - Cyprus 
Stock Exchange 

All 
standards 

S1-S4 - Technical and regulatory changes from Cyprus CSD are 
required to implement the standard. 

No plan 

No plan 

CZ – CSD Prague  All 

standards 

DE - Clearstream 
Banking 
Frankfurt 

S1 

DK – Euronext 
Securities 
Copenhagen 

S1, S2, 
S3, S4 

All standards – No plan 

No plan 

No plan 

S5-S6 - There is currently no interim ISIN to process elective events 
in the CSE. 

Implemented for services of Investor CSD, i.e. for foreign securities, 
when CSD and its participants distribute Interim Securities to their 
clients. There is no obligation of issuers to use CSD for Distribution 
with Options. With respect to Czech securities, Distribution with 
Options via CSD has never been used. The Issuer or other third party 
communicates with their shareholders directly based upon the list of 
shareholders. CSD is prepared to offer services to issuers processed 
according to Standards. There is no plan to impose an obligation on 
issuers to use CSD for Distribution with Options. 

S1 - German national implementation group decided to work on 
optional dividend events with two interim ISINs, one for stock and 
another for cash line. A task force has been created, out of the 
national Market Practice Committee, to specifically tackle this point. 
Implementation timeline to be determined. 

S1, S2, S4 - In a dividend with options (DVOP) event the payment in 
accordance with the standard will delay the cash payment two weeks 
compared to the existing solution in the Danish market, 
implementation of the standard will be a disadvantage to the 
investors and issuers. Amongst the Danish market participants, the 
existing functionality are therefore seen as sufficient. Thus, for the 
time being there are no appetite for further development of systems 
and/or amendments of market practice(s) with in this area. 

S3 - Regarding Distributions with Options, as agreed by the CEG 
during last year’s compliance monitoring exercise, full compliance 
with the Distributions with Options standards should only be possible 
once full compliance with the Security Distributions standards has 
been achieved. Standard 3 of the Distributions with Options 
standards will thus be assessed as not implemented. 

ES – Iberclear 

S3, S4 

S3, S4 - As the Spanish market is not fully compliant on securities 
distribution standards, this standard is not fulfilled. The standard will 
be implemented by Q4 2025. 

FI - Euroclear 
Finland 

All 
standards 

Currently the CSD does not support distributions with options like 
DVOP. The technique of using separate ISIN is in place in voluntary 
reorganisations. The implementation timeline of DVOP will be 
considered after the timeline for the future dividend payment model 
(mandatory cash dividends in CeBM) has been specified. Kindly refer 
to the explanation provided to Cash Distributions standard 20a. 

Q4 2025 

Q4 2029 

GR – ATHEXCSD  S1-S4 

S1-S4 - technical and regulatory changes from ATHEXCSD are 
required to implement the standard 

No plan 

Corporate Events Compliance Report – Compliance assessment 

66 

 
 
Plan 

No plan 

All - December 2025 

Market 

Gaps 

Status 

HR – SKDD   

S3 

HU – KELER 

All 
standards 

Regarding Distributions with Options, as agreed by the CEG during 
last year’s compliance monitoring exercise, full compliance with the 
Distributions with Options standards should only be possible once full 
compliance with the Security Distributions standards has been 
achieved. Standard 3 of the Distributions with Options standards will 
thus be assessed as not implemented. 

S1 - By law, Interim Security is possible to be issued. Distributions 
with Options are not market practice in the Hungarian market, there is 
no experience in the application of the Interim Security. The 
Hungarian National Stakeholder Group (HU-NSG) decided to re-plan 
the developments planned in the framework of Corporate Action 
Reform in order to successfully comply with the requirements of the 
Shareholder Rights Directive and the Corporate Actions 
Harmonisation standards of AMI-SeCo. As a result of the re-planning, 
processing of the elective corporate actions by KELER including the 
compliance with this standard is planned by December 2025. 

S2-S6 - Distributions with Options are not market practice in the 
Hungarian market, there is no experience in the application of the 
Interim Security. Processing of the elective corporate actions by 
KELER including the compliance with this standard is planned by 
December 2025. 

IE - Euroclear 
Bank 

All 
standards 

S1 - The Irish market does not issue interim securities for dividends 
with options. Issuers don’t currently see any value in utilising an 
interim security for dividends where the rights aren’t tradeable. 

No plan 

S2-S6 - EB as issuer CSD is technically ready to process such 
corporate action as per the standard but this is not the market 
practice in Ireland to issue interim securities. Topic raised at Irish 
working group and this is under discussion with issuers. Discussion is 
still ongoing on the Irish Asset Servicing Working group on steps and 
action remains to be taken. No further progress is noted since last 
year. 

Regarding Distributions with Options, as agreed by the CEG during 
last year’s compliance monitoring exercise, full compliance with the 
Distributions with Options standards should only be possible once full 
compliance with the Security Distributions standards has been 
achieved. Standard 3 of the Distributions with Options standards will 
thus be assessed as not implemented 

N/A 

Regarding Distributions with Options, as agreed by the CEG during 
last year’s compliance monitoring exercise, full compliance with the 
Distributions with Options standards should only be possible once full 
compliance with the Security Distributions standards has been 
achieved. Standard 3 of the Distributions with Options standards will 
thus be assessed as not implemented 

Q1 2026 

IS – Nasdaq CSD  S3 

IT - Euronext 
Securities Milan 

S3 

S3 

The process via Interim securities is supported by ICSDs, however 
n/a to Eurobonds. 

S3 – No plan 

LU – 
Clearstream 
Banking 
Luxembourg 

MT – Malta Stock 
Exchange 

S3 

S3 - Regarding Distributions with Options, as agreed by the CEG 
during last year’s compliance monitoring exercise, full compliance 
with the Distributions with Options standards should only be possible 
once full compliance with the Security Distributions standards has 
been achieved. Standard 3 of the Distributions with Options 
standards will thus be assessed as not implemented 

Regarding Distributions with Options, as agreed by the CEG during 
last year’s compliance monitoring exercise, full compliance with the 
Distributions with Options standards should only be possible once full 
compliance with the Security Distributions standards has been 
achieved. Standard 3 of the Distributions with Options standards will 
thus be assessed as not implemented 

NO – Euronext 
Securities Oslo 

S1, S3, 
S4 

S1 - Technical barrier. Only rights distribution is processed like this 
today. 

S1-S5 – Q3 2026 

S3 - Regarding Distributions with Options, as agreed by the CEG 
during last year’s compliance monitoring exercise, full compliance 
with the Distributions with Options standards should only be possible 
once full compliance with the Security Distributions standards has 
been achieved. Standard 3 of the Distributions with Options 
standards will thus be assessed as not implemented. 

S4 - Technical barrier. Issues on the overall payment process 
connected to the life cycle for MAND REOR 

Corporate Events Compliance Report – Compliance assessment 

67 

 
 
 
 
Market 

Gaps 

Status 

PL - KDPW 

S3 

PT - Euronext 
Securities Porto 

S3 

RO – Depozitarul 
Central 

S3, S4  

Plan 

No plan 

Regarding Distributions with Options, as agreed by the CEG during 
last year’s compliance monitoring exercise, full compliance with the 
Distributions with Options standards should only be possible once full 
compliance with the Security Distributions standards has been 
achieved. Standard 3 of the Distributions with Options standards will 
thus be assessed as not implemented. 

Regarding Distributions with Options, as agreed by the CEG during 
last year’s compliance monitoring exercise, full compliance with the 
Distributions with Options standards should only be possible once full 
compliance with the Security Distributions standards has been 
achieved. Standard 3 of the Distributions with Options standards will 
thus be assessed as not implemented. 

Q4 2025 

S3 – Q4 2025 

S4 - No plan 

S3 – Regarding Distributions with Options, as agreed by the CEG 
during last year’s compliance monitoring exercise, full compliance 
with the Distributions with Options standards should only be possible 
once full compliance with the Security Distributions standards has 
been achieved. Standard 3 of the Distributions with Options 
standards will thus be assessed as not implemented 

S4 - Although the standards for Voluntary Reorganisations apply in 
the market partially, we consider that Standard no. 4 applicable to 
"Distribution with options" as being partly implemented as long as the 
standard for Mandatory Reorganisations with options are almost fully 
implemented and, in our market, there have not been distributions 
with options with a second event being a voluntary reorganisation. 

SE – Euroclear 
Sweden 

SK – CDCP 

UK - Euroclear 
UK & 
International 

S3, S4 

S3 - Please see Securities Distributions. 

No plan 

S4 - Please see Mandatory Reorganisations with Options. 

All 
standards 

S1-S6 - Standard in process of implementation. Distributions with 
options are very rare on Slovak market. 

All – Q1 2026 

S1, S2 

(Gaps identified in the 2023 monitoring exercise) 

N/A 

Marked as non-compliant following CEG assessment. 

Corporate Events Compliance Report – Compliance assessment 

68 

 
 
 
3.2 

Reorganisations 

3.2.1 

Mandatory Reorganisations 

Chart 4 
Mandatory Reorganisations – % compliance per market 

Notes: N/A. 

Box 6 
Mandatory Reorganisations – Compliance status per Standard 

Information from 
Issuer to Issuer 
(I)CSD 

Information from Issuer 
(I)CSD to its 
participants 

Information flow 
from (I)CSD 
participants to 
End Investors 

Key dates 

Processing 

AT - Oesterreichische 
Kontrollbank 

BE - Euroclear Bank 

BE - Euroclear 
Belgium 

BE - NBB-SSS 

BG - BNBGSSS 

BG - CD AD 

CH - SIX SIS 

CY - Cyprus Stock 
Exchange 

CZ - CSD Prague 

CZ - SKD 

DE - Clearstream 
Banking Frankfurt 

1 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

2 

B 

B 

B 

B 

B 

B 

B 

B 

3 

B 

B 

B 

B 

B 

75% 

B 

B 

75%  50% 

B 

B 

4 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

N/A  N/A  N/A 

B 

5 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

10 

11 

12 

13 

14 

15 

16 

17a  17b  17c  17d  18a  18b 

18c 

8 

B 

B 

B 

B 

B 

B 

B 

9 

B 

B 

B 

B 

B 

B 

B 

6 

B 

B 

B 

B 

B 

B 

B 

B 

7 

B 

B 

B 

B 

50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  N/A 

B 

B 

B 

B 

75%  75% 

B 

75% 

B 

25%  25%  25% 

B 

0%  25%  75% 

B 

B 

B 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

50%  0% 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25%  25% 

B 

B 

0% 

B 

0% 

B 

B 

B 

B 

N/A 

N/A  N/A  N/A 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

Corporate Events Compliance Report – Compliance assessment 

69 

0%10%20%30%40%50%60%70%80%90%100%AT - Oesterreichische KontrollbankBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - Nasdaq CSDES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSGR - ATHEXCSDHR - SKDDHU - KELERIE - Euroclear BankIS - NasdaqIT - Euronext Securities MilanLI - SIX SISLT - Nasdaq CSDLU - Clearstream Banking LuxembourgLU - LuxCSDLV - Nasdaq CSDMT - Malta Stock ExchangeNL - Euroclear NederlandNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4PT - Euronext Securities PortoRO - Depozitarul CentralRO - SaFIRSE - Euroclear SwedenSI - KDDSK - CDCPUK - Euroclear UK & International 
 
 
 
  
IE - Euroclear Bank 

IS – Nasdaq CSD 

IT - Euronext 
Securities Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - Clearstream 
Banking Luxembourg 

LU - LuxCSD 

LV - Nasdaq CSD 

MT - Malta Stock 
Exchange 

NL - Euroclear 
Nederland 

NO - Euronext 
Securities Oslo 

PL - KDPW 

PL - SKARBNET4 

PT - Euronext 
Securities Porto 

RO - Depozitarul 
Central 

RO - SaFIR 

SE - Euroclear 
Sweden 

SI - KDD 

Information from 
Issuer to Issuer 
(I)CSD 

Information from Issuer 
(I)CSD to its 
participants 

Information flow 
from (I)CSD 
participants to 
End Investors 

Key dates 

Processing 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17a  17b  17c  17d  18a  18b 

18c 

DK - Euronext 
Securities 
Copenhagen 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

EE - Nasdaq CSD 

ES - Iberclear 

B 

B 

FI - Euroclear Finland  B 

FR - Euroclear 
France 

GR - BOGS 

GR - ATHEXCSD 

HR - SKDD 

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 

B 

75% 

25% 

B 

B 

B 

25% 

B 

B 

B 

B 

B 

B 

B 

HU - KELER 

50%  50%  50%  25%  50%  50%  25%  50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50%  25% 

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 

75% 

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 

50%  50%  50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50% 

B 

B 

B 

0% 

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 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

25% 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25% 

B 

B 

B 

B 

B 

B 

B 

25%  25%  25%  25%  25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75% 

B 

50% 

B 

75%  0% 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

50% 

B 

0% 

0% 

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 

0% 

0% 

B 

50%  25%  75%  0% 

B 

75% 

B 

75%  0%  75% 

B 

B 

75%  0% 

B 

B 

B 

B 

B 

B 

B 

50% 

B 

B 

N/A 

B 

75% 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

0%  N/A  N/A  N/A 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

N/A 

B 

B 

75% 

B 

B 

75% 

B 

B 

B 

0%  75% 

B 

B 

75%  0%  75% 

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 

B 

B 

B 

B 

B 

50% 

B 

B 

B 

B 

B 

B 

50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  75%  50%  75% 

0% 

B 

B 

B 

0%  N/A  N/A  N/A 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  N/A  N/A  N/A 

B 

25% 

B 

75%  0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

SK - CDCP 

75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75% 

UK - Euroclear UK & 
International 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Notes: Standard 15 is applicable to fixed income securities only. Standard 18c is not applicable for NBB-SSS, since all Bonds in NBB-SSS are in FAMT and there are no fractions. 
Standards 12, 16, 18a, 18b, 18c are not applicable for BNBGSSS, since the CSD`s activities with regard to mandatory reorganisations are related to redemption. 

Table 5 
Mandatory Reorganisations - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the 
Mandatory Reorganisations standards. Markets/CSDs not listed below have been assessed 
as fully compliant. 

Market 

Gaps 

Status 

Plan 

BE – Euroclear 
Bank 

S12, 
S17c, 
S18a  

S12 - In the 2024 assessment, one case of incorrect use of key dates 
was identified with the below details: 

S12 – No plan 

S17c, S18a – Q4 2024 

SPLF event on ISIN XS2620728860 (listed investment fund): 

EFFD 02.09.2024 / RD 30.08.2024 / PD 02.09.2024. 

Corporate Events Compliance Report – Compliance assessment 

70 

 
 
 
  
Market 

Gaps 

Status 

Plan 

BE – Euroclear 
Belgium 

S18a 

BG – BNBGSSS 

S7, S15 

BG – CD AD 

S3 

Euroclear Bank was deemed not compliant due to missing 
information on from the upper chain intermediary.   

S17c, S18a - This is in line with the timing that is currently defined in 
the International Securities Operational Market Practice Book. 
However, the timing of payments depends on currency, operating 
time-zone of the Agents as well as the timing that the issuer can 
release the payment (i.e., availability of cash). The concrete action 
taken is the update of MOP (Manual of Procedure) shared with 
Common Depositories and Agents in October 2024. This is a 
contractual document in which Euroclear Bank recommended the 
deadline to be compliant with those standards (and also SCoRE). 
Euroclear Bank had with CBL a joint call with some of those agents to 
explain the rules and the AMI-SeCo monitoring process. To be fully 
implemented by November 2024. 

The agent must authorise the payment in Euroclear Belgium to 
release the credit of securities. Technically, the agent can perform this 
step as from the market deadline date end of day for credit of the 
proceeds on the payment date. In case of creation of new shares, the 
cash for creation of new shares is not provided on PD-1 (due to 
overnight risk - identical to the pay-out of a cash dividend) but on PD 
in the morning as a result, the creation of shares is done in the 
morning on PD at notary's office (around 8:00 am). Given this timing, 
the message to create the securities (demat06 document) is sent to 
CSD before the opening of the settlement system, however, 
technically/operational set-up occurs most of the time around 10:00 
am which allows the credit of securities by the agent before noon (as 
for cash proceeds). 

S7 - To facilitate the activities related to implementing this standard, . 
BNBGSSS plans to conduct internal testing by the end of 2024 and 
intends to synchronize external testing with the testing of SCoRE CA 
Standard 15 ISO 20022 messages for corporate actions. 
S15 - Regulatory and technical changes are completed. BNBGSSS 
plans to conduct internal testing by the end of 2024 and intends to 
synchronize external testing with the testing of SCoRE CA Standard 
15 ISO 20022 messages for corporate actions. 

According to the Rules of the Bulgarian Stock Exchange (Part III, 
Article 5. (1), item 10) the companies listed on the Premium segment 
of the BSE disclose regulated information to the general public 
simultaneously in Bulgarian and in English through the media chosen 
by the company within the respective deadlines. Other issuers are not 
obliged to publish information in English. Where applicable, the 
recently developed Electronic Platform for General Meetings (EPOS) 
may also be employed to obtain narrative text, inserted in a dedicated 
section for CA data announcement in Bulgarian and English. There 
are plans to include the standard in the list of upcoming changes to 
the Bulgarian Stock Exchange (BSE) Trading Rules for the next 
amendment session. CDAD is unable to commit to a specific date for 
the next amendment session of the BSE Trading Rules, as this action 
falls exclusively under the authority of the BSE. Relevant discussions 
have taken place between the two institutions, and CDAD has 
received assurances that all necessary actions will be taken to 
incorporate the required provisions into the referenced document. It is 
also important to note that the proposed amendments are subject to 
approval by the Financial Supervision Commission (FSC). 
Nonetheless, CDAD remains confident that the standard will be 
achieved within the designated timeframe. 

No plan 

Q4 2025 

Q1 2025 

CY – CSE 

S9, S10 

S9, S10 - Technical changes in custodians' infrastructures are 
currently assessed. 

No plan 

All standards – No plan 

CZ – CSD Prague  S2, S3, 
S6, S8-
S10, S12-
S14, 
S17a, 
S17c,d 

S2 - The standard is implemented with respect to listed shares. In 
case that issuer of listed shares does not inform the shareholders 
directly, the communication has to be in the format of Table 8 of IR 
2018/1212. The law does not provide for formatted electronic form 
and the information is usually communicated in the same format as is 
published on the websites of the issuer (pdf). There is no plan to 
change the law to increase administrative burden of all companies 
with book-entry shares or issuers of book-entry bonds to inform CSD 
about a corporate action that does not influence the security itself. 

S3 - Issuers of listed shares provide the information in English as 
well. There is an obligation from Art. 2/2 of IR 2018/1212 for listed 
shares. For non-listed securities, there is no obligation to inform in 
English. In practice, SMEs with international shareholder base would 
use bilingual text. There is no plan to change the law to increase 
administrative burden of other companies with book-entry shares or 
issuers of book-entry bonds to inform shareholders via CSD in 
English. 

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71 

 
 
 
 
Market 

Gaps 

Status 

Plan 

S6 - The standard is implemented with respect to listed shares. In 
case that issuer of listed shares does not inform the shareholders 
directly, the communication has to be in the format of Table 8 of IR 
2018/1212. For other securities, the law does not provide for 
formatted electronic form. 

S8 - Implemented only for listed shares and services of Investor CSD, 
i.e. for foreign securities, when CSD and its participants should inform 
their clients, until the information reaches the end investor. With 
respect to listed shares, there is an obligation to transmit the 
information in two level register as owners of accounts on the second 
level of register are considered to be the shareholders. Records in 
any kind of sub-register about end investors are not considered as 
book-entry shares and issuers provide payments to those named in 
the list of shareholders on record date. With respect to other Czech 
securities, there is no obligation at the moment and only participants 
providing custodial services would inform clients about a corporate 
action. Level of these services is not harmonised. 

S9 - Partly implemented only for listed shares and for services of 
Investor CSD, i.e. for foreign securities. With respect to listed shares, 
there is an obligation to transmit the information in electronic and 
machine-readable formats (2/2 of IR 2018/1212). With respect to 
other Czech securities, there is no obligation at the moment. There is 
no plan with respect to non-listed companies with book-entry shares 
or issuers of book-entry bonds. 

S10 - Implemented only for listed shares and for services of Investor 
CSD, i.e. for foreign securities. With respect to other Czech 
securities, there is no obligation at the moment. There is no such an 
obligation neither in the valid legislation, including IR 2018/1212. IR 
allows for URL hyperlink to websites. 

S12, S13 - CSD does not usually distribute cash payments. Cash 
payments are distributed by banks according to a list of shareholders 
or bondholders prepared by CSD after the record date. The record 
date is usually before the bond’s redemption (up to 30 days before) in 
order to manage tax issues and payments. After the record date, 
trading with bonds is terminated. The payment date is as close as 
possible after redemption. Distribution of securities may be performed 
the next Business Day after the Record Date. When it is the Issuer 
who instructs CSD how to perform distribution of securities, the 
Record Date may be in the past. There is a undefined deadline for 
companies with listed shares in IR (8/2/a) to set the payment date as 
close as possible to the record date, issuer deadline or the deadline 
set by the third party, so as to allow for the processing of payments to 
the shareholders as swiftly as possible. The payment date can be as 
close as possible to delivery of all necessary tax documents. There is 
no plan to impose an obligation to distribute proceeds only via the 
CSD. 

S14 - Payments in book-entry securities may only be by book-entry. 
There is an obligation for companies with shares to make payments 
by crediting bank accounts of shareholders. There is no obligation of 
cashless payments with respect to bonds only a general obligation to 
make payments of more than CZK 270,000 by money transfer. If CSD 
distributes payments, it credits participants' cash accounts at Czech 
National Bank.   

S17a - In case that Issuer uses the CSD for distribution, payments 
are made in Czech National Bank accounts of participants. There is 
no plan to impose an obligation to distribute proceeds only via CSD 
and onward chain of intermediaries. There is no legal obligation even 
for listed shares. 

S17c - There is usually no deadline for the issuer. 

S17d - There is no policy with respect to corrections of payments. 

CZ - SKD 

S7-S13, 
17d 

All – Following CEG assessment. 

S7, S17d – Reversals are not allowed. 

All – No plan 

S15 – Redemptions are not processed separately from interest 
payments when the payment date of interest payments and 
redemptions coincide. This is not compliant with the standards. 

DK – Euronext 
Securities 
Copenhagen 

S17d 

For debt securities, a compliant solution will be implemented in line 
with the SCoRE deadline, i.e., June 2025. For equity instruments, the 
deadline is November 2025. 

Q4 2025 

ES – Iberclear 

S7, S17d   S7, S17d - Implemented for most frequent events (REDM, MCAL, 

Q4 2025 

PCAL, WRTH). One custodian points out that the percentage of 
compliance is similar to the previous year and that they receive the 
reversal directly sometimes. The standard will be implemented by Q4 
2025. 

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72 

 
 
Market 

Gaps 

Status 

FI – Euroclear 
Finland 

S7, S12, 
S17d  

FR – Euroclear 
France 

17c 

S7, S17d - The Finnish regulation does not identify or allow a reversal 
of a corporate action event that has been settled on the securities 
accounts. Hence, a full reversal process as defined in SCoRE CA 
standards cannot be implemented. Manual corrections may be 
required depending on the case. 

S12 - Deviating opinions on the need for implementing last trading 
date. LTRD is not supported by a local stock exchange 

Non-compliant payments (i.e. payments after 12:00 noon) result from 
SEPA credit transfer operated through payment systems batches. 
When cash is not available in the morning of the Payment Date 
French Market prefers to operate the payment on the right date in the 
afternoon that to postpone the Pay Date the day after by sending an 
event update with a new Payment Date. Actions undertaken have 
enabled to limit the number of payments made after 12:00 noon to 
10%. 

Plan 

All – No plan 

Ongoing analysis 

HR – SKDD   

S7, S17d  S7, S17d – No amendments to the law governing the procedure in 

S7, S17d – No plan 

HU – KELER 

S1-S8, 
S10, S11, 
S17a - 
S18a 

S1-S6, S11 – December 
2024 

S7, S8, S10, S17a-S18a – 
December 2025 

the event of an erroneous remittance of funds are needed. However, 
the SKDD pays most payments from CAs to the accounts of the 
Beneficiary owners and, currently, the SKDD does not have the 
authority to directly debit their bank account (even if it did, these 
accounts would have to have sufficient funds necessary for the 
reversal). SKDD can only invite the Beneficiary owners to remit the 
funds paid from the CA, noting that until all the funds paid from the 
CA have been returned, the SKDD must not announce and 
implement a reversible CA. 

S1 - From 3 September 2020 due to SRD II, KELER introduced its 
Corporate Action notification services for listed shares. The CSD's 
corporate action database is established, which increases the 
accessibility of corporate action information. Market players are 
informed on the details of the corporate actions after the 
announcement of the issuer, from the Issuer CSD. Announcements 
for corporate actions of securities other than listed equities remain 
with the existing announcement publication places: stock exchange, 
central bank's website, issuer's website. The extension of the 
corporate action announcement services of KELER to securities other 
than listed shares is planned by December 2024. 

S2 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form. Regarding securities other than listed equities: A 
corporate action database is available through KELER's proprietary 
communication system (KID) and on its website with limited range of 
information (only date and type of corporate action). Currently the 
Issuers do not inform the End Investors electronically. The standard is 
partially implemented at the moment, as the Issuers publish the 
information in the legally required places (on their own website, on 
kozzetetelek.hu website, and the listed Issuers on the website of the 
stock exchange). The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

S3 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer. The major 
Issuers and/or Issuers with considerable foreign ownership are 
currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER's General Business Rules shall be modified according to this 
standard. 

S4 - The implementation of this standard will be relevant during the 
implementation of standard 1. This standard will be implemented 
simultaneously with standard 1 for debt securities. 

S5 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form. Regarding securities other than listed equities: A 
corporate action database is available through KELER's proprietary 
communication system (KID) and on its website with limited range of 
information (only date and type of corporate action). Currently the 
Issuers do not inform the End Investors electronically. The standard is 
partially implemented at the moment, as the Issuers publish the 
information in the legally required places (on their own website, on 
kozzetetelek.hu website, and the listed Issuers on the website of the 
stock exchange). The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

Corporate Events Compliance Report – Compliance assessment 

73 

 
 
Market 

Gaps 

Status 

Plan 

S6 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer. The major 
Issuers and/or Issuers with considerable foreign ownership are 
currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER's General Business Rules shall be modified according to this 
standard. 

S7 - The reversal of the payment is not market practice, currently the 
Issuer transfers the corrected amount after transferring back the 
incorrect first payment. KELER participates in the procedure if 
KELER is appointed as paying agent. This standard is planned to be 
implemented by December 2025. 

S8 - In case of listed shares, KELER Participants receive the issuer's 
announcement from KELER and they forward it further down the 
chain. In case of other securities KELER participants obtain CA 
information not from the Issuer through KELER, but by processing the 
information published by the Issuer. They forward the information 
obtained the before mentioned way directly or through the custody 
chain to the End Investor. The KELER Participant can forward 
immediately the Corporate Action information obtained from KELER 
to the End Investor directly or through the custody chain. 

S10 - Due to SRD II, intermediaries are to forward corporate action 
announcements to non-Intermediaries in case of listed shares. In 
case of other securities, only intermediaries and investors with 
SWIFT connectivity may receive such announcements. Such practice 
is already part of the service of banks and custodians. In case of End 
Investors without SWIFT connectivity the announcements relevant for 
the Investor are available through the web-based application of some 
of the custodians. Providing such service is not an obligation, in most 
cases it is not part of the custody service pack. 

For securities other than listed shares, the implementation of 
standard 4 is necessary for intermediaries providing services for End 
Investors. 

S11 - Hungarian regulations generally prescribe stricter deadlines. 
E.g. in case of equities the decision of the GM must contain the start 
date of the payment of dividend. In case of bonds the policy 
conditions must contain the payment date, etc. There is different 
regulation for each kind of securities, there is no general rule for 
announcement deadlines. The Issuer does not inform the CSD 
according to standard 1. After the implementation of standard 1 rules 
will be in line with this standard. 

S17a - KELER is not a central paying agent, Issuers may appoint any 
third party as paying agent. This way Payments are not always made 
through KELER. The revision of the current payment procedures is in 
progress in line with the implementation of the planned 
developments. The implementation of this standard is planned by 
December 2025. 

S17b - For listed shares, the payments are not yet done by KELER. 
For other securities, the announcement of the CSD according to the 
standards does not exist, but of course the payment is made in the 
currency published in the announcement of the Issuer published in 
other places. After the implementation of standard 1 rules will be in 
line with this standard. 

S17c - It is possible to transfer the payment before 12:00, however 
there is no obligation for the Issuer or its paying agent to transfer 
before midday. KELER as paying agents complies with the standard. 
The revision of the current payment procedures is in progress in line 
with the implementation of the planned developments. The 
implementation of this standard is planned by December 2025. 

S17d - According to the current market practice the Issuer transfers 
the correct amount after transferring back the incorrect payment. 
KELER participates in the process only if KELER is appointed as 
paying agent. This standard is planned to be implemented by 
December 2025. 

S18a - There is no obligation for the issuer or the paying agent to 
transfer as early as possible on the Payment Date. The revision of 
the current payment procedures is in progress in line with the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

IE - Euroclear 
Bank 

S17c, 
S18a, 
S18b,c 

S17c – No such events in 2023. Cash not always credited before 
noon as cash needs to be received from issuer/registrar and 
reconciled by EB before EB can process the payment. 

No plan 

S18a – No such events in 2023.The timing of payments would 
depend on when the registrar can deliver the securities. 

Corporate Events Compliance Report – Compliance assessment 

74 

 
 
Market 

Gaps 

Status 

Plan 

S18b,c - The Euroclear Bank Nominee would receive a whole 
number of shares (no fractions) and would apply a rounding 
methodology which ensures that all shares are distributed to its 
participants. However, Euroclear Bank’s current methodology consist 
of rounding up to the largest shareholder and is therefore not 
compliant with the standard. Further feedback is needed from 
Euroclear Bank on when the ICSD will apply the top-down method 
(rounding down to the nearest whole number, in line with the 
standard) instead. 

IS – Nasdaq CSD  S8-S10 

S8-S10 - Unknown by the CSD how well the CSD participants comply 
with the standard. All participants comply to the standard when it 
comes to specific voluntary corporate actions events for example 
Rights issues and dividend payments. 

S8-S10 – No plan 

IT – Euronext 
Securities Milan 

S4  

As of today, CSD announcements are sent taking into account settled 
positions only, thus excluding any pending receipt and/or delivery that 
might impact the eligible balance. 

Q1 2026 

LU – 
Clearstream 
Banking 
Luxembourg 

S17b, c, 
S18a 

S17b - Payments are made in the currency of the new securities 
(while the standards state that payments should be made in the 
original currency). 

All - No plan 

MT– Malta Stock 
Exchange 

NO – Euronext 
Securities Oslo 

S2, S8, 
S9, S17a, 
S17d, 
S18b, c 

S1, S2, 
S4-S7, 
S9, S11-
S13, S16-
S17a, 
S17d, 
S18a,b,c 

S17c - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on the currency, operating time-zone 
of the Agents as well as the timing that the issuers can release the 
payment (i.e. availability of cash). CBL had with Euroclear Bank a 
joint call with Common Depositories and Agents to explain the rules 
and the AMI-SeCo monitoring process. Although ICSDs timing 
requirements are to be reinforced in line with the SCoRE CA 
Standards, the dependency on issuers and their agents will remain. 

S18a - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payment depends on when the issuers’ agent can 
deliver the securities. CBL had with Euroclear Bank a joint call with 
Common Depositories and Agents to explain the rules and the AMI-
SeCo monitoring process. Although ICSDs timing requirements are to 
be reinforced in line with the SCoRE CA Standards, the dependency 
on issuers and their agents will remain. 

Marked as non-compliant following internal plausibility check. 

S1 - Legal barrier. The Issuer has no such obligation to inform the 
CSD. Key Dates are not always announced or very late. There is no 
applicable law defining the Issuer to inform specifically the CSD. 

Q3 2026 

S2 - Technical barrier. Not all information can be communicated in 
formatted electronic form using standards defined and used by the 
securities industry, such as the ISO standards, irrespective of the 
communication channel used. 

S4 - Technical barrier. Batch solution running EOD and not possible 
to deliver on Pending Transaction in the Underlying Security with the 
Issuer as understood from the event lifecycle processing. 

S5 - Technical barrier. Batch solution running EOD and not possible 
to inform participant who obtains a holding or is subject to a new 
Transaction on the Underlying Security after the announcement until 
the Record Date as understood from the event lifecycle processing. If 
event has a event update, new holdings will be included in this 
updated. 

S6 - Technical barrier. Not all information and events can be 
communicated in formatted electronic form using standards defined 
and used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S7 - Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S9 - Technical barrier. Not all information can be communicated in 
formatted electronic form using standards defined and used by the 
securities industry, such as the ISO standards, irrespective of the 
communication channel used. 

Corporate Events Compliance Report – Compliance assessment 

75 

 
 
 
Market 

Gaps 

Status 

Plan 

S11 - Legal barrier. The Issuer has no such obligation to inform the 
CSD, especially relevant for Bonds. Key Dates are not always 
announced or very late. There is no applicable law defining the Issuer 
to inform specifically the CSD. Technical barrier. Not all information 
can be communicated in formatted electronic form using standards 
defined and used by the securities industry, such as the ISO 
standards, irrespective of the communication channel used. 

S13 - Technical barrier for some securities payments are impacted by 
the cash payments processing. 

S16 - Technical barrier. CSD does not use trade date to define 
entitlements. 

S17a - Technical barrier. All Corporate Actions payments are paid via 
national payment infrastructure. 

S17d - Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. Also, all Corporate 
Actions payments are paid via national payment infrastructure. Legal 
Barrier. For Investors, Payments is executed in commercial bank 
money. Therefore, for the vast majority of Investors payments from 
Issuer will be done in commercial bank money. 

S18a - Better understanding of the wording of standards by ES Oslo. 
The CSD confirmed that there are not compliant. 

S18b - Technical barrier. Existing system has a fragments processing 
of some securities payments. Legal barrier CSD register authorisation 
impacts the processing (rounding aggregation) of investors owning 
multiple safekeeping accounts. 

S18c - Legal barrier. No requirements on the issuer to compensate 
fraction is cash, when they can do rounding any way the choose as 
per securities account. 

PL – KDPW 

S2, S7, 
S16, 
S17d 

S2 - The communication from the issuer to the CSD is in electronic 
form, however the data provided is not formatted in compliance with 
ISO standards. 

S2, S16 - Q4 2026 
S7, S17d – No plan 

S7, S17d - A reversal process compliant with the standard cannot be 
implemented currently owing to legal barriers. In the opinion of 
KDPW, the mere fact of an error of an issuer or of KDPW may at 
most constitute grounds for the issuer or KDPW to demand that the 
person/KDPW participant to whom the undue benefit has been paid 
should return it but it does not, in itself, constitute grounds for the 
issuer or KDPW to be able to compulsorily (i.e. against the will of 
such person) enforce such benefit against such person. Furthermore, 
the risk must also be considered that the issuer may not have been in 
error at all and would like to use the reversal to collect the benefit 
paid through KDPW, to which the issuer has no legal title.S16 - By 
default the standard is implemented. As exception, in case of SPLF 
and SPLR the outturn security has the same ISIN as the underlying 
security, following ANNA technical recommendations in this regard. 
Revised due to the changes in ANNA technical standards, 
implementation is in progress. 

PL – 
SKARBNET4 

S7, S17d  S7, S17d – reversals were deemed not applicable by the Polish NSG 
on the basis that there are no reversals on T-bills and NBP-bills, while 
reversals should be supported if there is a need to correct a payment 
error. The CEG accordingly assessed SKARBNET as being 0% 
compliant with the standard. 

No plan 

PT – Euronext 
Securities Porto 

S2, S7, 
S17d  

S2 - The information is communicated electronically through Euronext 
Securities Porto portal or e-mail. The ISO standards are not 
implemented yet. No appetite from the market. 

Q4 2025 

S7 - Very few reversals exist in the market. When requested, the 
CSD always announces its participants by email when there is a 
correction and the reason for the same. 

S17d - Very few reversals exist in the market. When requested, the 
CSD makes corrections to the payments. 

As part of the Euronext New Corporate Event Service initiative, the 
compliance deadline is June 2025 for debt instruments (linked to 
ECMS) and November 2025 for other securities. 

S7 - Prior to the processing of a reversal the information is 
communicated by the CSD to the affected parties in a proprietary 
form (via email). In the context of AMI-SeCo SCoRE standards 
implementation, the CSD plans to implement the standard 
notifications and automated flows according to Standard no. 13 
(Reversal of a corporate action) by November 2025. 

S7 – Q4 2025 

S16 – No plan 

RO – Depozitarul 
Central 

S7, S16  

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76 

 
 
Market 

Gaps 

Status 

Plan 

All - Q4 2025 

No plan 

S16 - The ISIN of the outturn security is changed depending on the 
event type. Major technical changes should be made in order to 
become able to change the ISINs for all the events. We will assess 
the issue depending on the market requests at a later stage. 

RO - SaFIR 

S7, S17d  All - Ongoing development and implementation 

SE – Euroclear 
Sweden 

S2, S3, 
S6, S7, 
S8, S17a, 
S17c,d  

S2 - Mandatory reorganisation event information is provided by 
issuers to the CSD via manual means. 

S3 - Comment: There is little narrative provided for mandatory 
reorganisations not part of a larger event (such as a maturity 
redemption, as opposed to the pari passu stage of a rights issue). 
Most listed companies provide at least some information of the event 
in English on their websites. An amendment of the CSD rules 
requiring ""avitext"" in both English and Swedish was implemented 
late 2011. 

S6 - Some intermediaries still use the old, non-ISO, interface. The 
CSD offers an older version of CA information interface. The old 
version contains the same information – the ISO 15022 messages 
are created from that information – but in a different format. CSD 
participants are not required to migrate to ISO 15022 messages and 
as the old version also contains information not provided in ISO 
15022 messages, not all CSD participants want to maintain access to 
both. The CSD's ISO 15022 interface does not cover all events, but 
the “non-covered” events are rare. 

S7, S17d - Reversals are not performed by the CSD due to legal 
reasons, and this has been the case since start of the CSD. In earlier 
years the SE MIG have stated that Standard 7 was complied with 
compliant since Euroclear Sweden, in case a payment would ever be 
reversed, would have sent such an announcement. However, 
following a legal analysis performed by a Government Inquiry, it was 
clarified early 2024 that a reversal of a cash distribution is in breach 
with Swedish property law, which is why the CSD would never 
perform such a reversal. 

S8 - Not all intermediaries can send information on pending 
transactions, only on holdings. 

S17a - While payments from issuers on equities are now made using 
the CSD's payment mechanism, there is one event type, demerger 
with cash compensation, where the cash payment is made outside of 
the CSD's payment mechanism. Such events are very rare in the 
market. 

S17c - Payments from issuers can technically be made until 15.30, 
but the CSD's rules for issuers state that payments should be made 
no later than 12 noon. Generally, events are paid by 12 noon. 

SK – CDCP 

All 
Standards 

All - Standards in process of implementation 

All – Q1 2026 

Corporate Events Compliance Report – Compliance assessment 

77 

 
 
 
3.2.2 

Mandatory Reorganisations with Options 

Chart 5 
Mandatory Reorganisations with Options – % compliance per market 

Notes: N/A. 

Box 7 
Mandatory Reorganisations with Options – Compliance status per Standard 

Information 
from Issuer to 
Issuer (I)CSD 

Information from 
Issuer (I)CSD to its 
participants 

Information 
flow from 
(I)CSD 
participants to 
End Investors 

Key dates 

Processing 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10  11 

12  13  14  15  16 

17  18  19  20  21  22a  22b  22c  22d  23a  23b  23c 

AT - Oesterreichische 
Kontrollbank 

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 

BE - Euroclear Bank 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  0%  B 

B 

B 

B 

B 

B 

B 

B 

B  75%  B  50%  0%  0% 

BE - Euroclear 
Belgium 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  75%  75%  B 

B 

B 

B  75%  75%  B 

B 

B 

B 

B 

0%  B 

B 

BE - NBB-SSS 

B 

B 

B 

B 

B 

B  25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  25%  25%  B 

B 

B  25%  B  N/A  N/A 

BG - BNBGSSS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

BG - CD AD 

CH - SIX SIS 

B 

B 

B  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  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 

CY - Cyprus Stock 
Exchange 

B 

B 

B 

B 

B 

B 

B 

B  75%  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

CZ - CSD Prague 

50%  50%  50%  75%  75%  75%  B  75%  25%  25%  B 

0%  0%  0%  0%  75%  B 

0%  0%  0%  0%  50%  B  50%  50%  B 

B  25% 

CZ - SKD 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

DE - Clearstream 
Banking Frankfurt 

DK - Euronext 
Securities 
Copenhagen 

N/A  N/A  N/A  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  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  75%  B 

B 

B 

EE - Nasdaq CSD 

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 

Corporate Events Compliance Report – Compliance assessment 

78 

0%10%20%30%40%50%60%70%80%90%100%AT - Oesterreichische KontrollbankBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - Nasdaq CSDES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSGR - ATHEXCSDHR - SKDDHU - KELERIE - Euroclear BankIS - NasdaqIT - Euronext Securities MilanLI - SIX SISLT - Nasdaq CSDLU - Clearstream Banking LuxembourgLU - LuxCSDLV - Nasdaq CSDMT - Malta Stock ExchangeNL - Euroclear NederlandNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4PT - Euronext Securities PortoRO - Depozitarul CentralRO - SaFIRSE - Euroclear SwedenSI - KDDSK - CDCPUK - Euroclear UK & International 
 
 
 
  
Information 
from Issuer to 
Issuer (I)CSD 

Information from 
Issuer (I)CSD to its 
participants 

Information 
flow from 
(I)CSD 
participants to 
End Investors 

Key dates 

Processing 

10  11 

12  13  14  15  16 

17  18  19  20  21  22a  22b  22c  22d  23a  23b  23c 

ES - Iberclear 

1 

B 

FI - Euroclear Finland  B 

FR - Euroclear France  B 

GR - BOGS 

GR - ATHEXCSD 

HR - SKDD 

B 

B 

B 

2 

B 

B 

B 

B 

B 

B 

3 

B 

B 

B 

B 

B 

B 

4 

B 

B 

B 

B 

B 

B 

5 

B 

B 

B 

B 

B 

B 

6 

7 

8 

B 

0%  B 

B  25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  25%  B 

9 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  B  75%  75%  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 

HU - KELER 

50%  50%  50%  25%  50%  50%  25%  50%  B  50%  50%  B  25%  25%  25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  50%  50%  50%  B 

B 

B 

0%  0%  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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  B 

B  25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  25%  B 

B 

B 

B 

B 

B 

B 

B  25%  25%  B  25%  25%  25%  25%  25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  50%  B  75%  0%  0% 

B 

B 

B 

B 

B 

B 

IE - Euroclear Bank 

IS – Nasdaq CSD 

IT - Euronext 
Securities Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - Clearstream Banking 
Luxembourg 

LU - LuxCSD 

LV - Nasdaq CSD 

MT - Malta Stock 
Exchange 

NL - Euroclear 
Nederland 

NO - Euronext 
Securities Oslo 

B 

B 

B  75%  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 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  25%  25%  B 

B 

B 

B 

B 

B 

B 

B  75%  75%  B  50%  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  25%  25%  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  50%  B 

B 

B 

B 

B 

0%  0%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  50%  B 

B 

0%  B 

0%  0% 

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 

0%  75%  B  50%  25%  75%  0%  B  75%  B  75%  B 

0%  0%  75%  B  75%  B  25%  25%  B  25%  B 

B  25%  75%  50%  75% 

PL - KDPW 

B  50%  B 

B 

B 

B 

0%  B 

B 

B 

B 

B  50%  50%  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  B 

B 

B 

PL - SKARBNET4 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

PT - Euronext 
Securities Porto 

RO - Depozitarul 
Central 

B  75%  B 

B 

B 

B  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  B 

B 

B 

B 

B 

B 

B 

B 

B  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

RO - SaFIR 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

SE - Euroclear 
Sweden 

50%  0%  75%  B 

B 

B 

0%  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  50%  B 

B 

0%  B  50%  0%  B 

B 

B 

SI - KDD 

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 

SK - CDCP 

25%  25%  25%  50%  50%  50%  50%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75% 

UK - Euroclear UK & 
International 

0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

Notes: Mandatory Reorganisations with Options are outside the scope of BNBGSSS, SKD, SKARBNET4 and SaFIR activities. 

Corporate Events Compliance Report – Compliance assessment 

79 

 
 
 
  
Table 6 
Mandatory Reorganisations with Options - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the 
Mandatory Reorganisations with Options standards. Markets/CSDs not listed below have 
been assessed as fully compliant. 

Market 

Gaps 

Status 

Plan 

BE – Euroclear 
Bank 

S13, S14, 
S22c, 
S23a 

BE – Euroclear 
Belgium 

S12-S14, 
S19, S20, 
S23a 

S13, S14 – Q4 2025 

S22c, S23a – Q4 2024 

All – No plan 

S13, S14 - The key BP dates are not yet notified although Euroclear 
Bank is technically ready to transmit this information via non 
structured field. Both ICSDs agreed on the common rules for 
generating the BP key dates for the international market. This 
process will be fully handled by ICSDs; therefore, the question of the 
implementation is only on the ICSDs side and will depend on 
available technical release. Preferably, a common implementation 
date should be agreed between both ICSDs (not expected before end 
2024) to be followed by an update of the ISMAG standards 
accordingly. The implementation in PROD is not precisely defined yet 
but Q4 2025 is the new possible window. 

S22c - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on currency, operating time-zone of 
the Agents as well as the timing that the issuer can release the 
payment (i.e., availability of cash). The concrete action taken is the 
update of MOP (Manual of Procedure) shared with Common 
Depositories and Agents in October 2024. This is a contractual 
document in which Euroclear Bank recommended the deadline to be 
compliant with those standards (and also SCoRE). Euroclear Bank 
had (with CBL) a joint call with some of those agents to explain the 
rules and the AMI-SeCo monitoring process. To be fully implemented 
by November 2024. 

S23a - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on when the issuer's agent can 
deliver the securities. The concrete action taken is the update of MOP 
(Manual of Procedure) shared with Common Depositories and Agents 
in October 2024. This is a contractual document in which Euroclear 
Bank recommended the deadline to be compliant with those 
standards (and also SCoRE). Euroclear Bank had with CBL a joint 
call with some of those agents to explain the rules and the AMI-SeCo 
monitoring process. To be fully implemented by November 2024. 

S12-S14, S19, S20 - The Belgian market already reported non-
compliance on a few standards in case of capital increase events 
(note: Euroclear Belgium is technically compliant, but a market 
change is required to ensure full compliance). The issue was brought 
to the attention of the Belgian market, explaining the consequences 
for corporate action departments. Issuer agents were not willing to 
change the Belgian market practice for commercial reasons (if trading 
is stopped earlier, more risk that the price of underlying can change to 
a negative scenario for the investor in the capital increase). After 
failing attempts to change the way of working, no specific action plan 
is currently on the table, the Belgian market ‘knows’ it is not compliant 
for a few events/years, as shown in the monitoring exercise. The item 
can be raised again at the level of the Febelfin Financial Markets & 
Infrastructure Committee. 

S23a - The agent must authorise the payment in Euroclear Belgium 
to release the credit of securities. Technically, the agent can perform 
this step as from the market deadline date end of day for credit of the 
proceeds on the payment date. In case of creation of new shares, the 
cash for creation of new shares is not provided on PD1 (due to 
overnight risk - identical to the pay-out of a cash dividend) but on PD 
in the morning as a result, the creation of shares is done in the 
morning on PD at notary's office (around 8:00 am). Given this timing, 
the message to create the securities (demat06 document) is sent to 
CSD before the opening of the settlement system, However 
technically/operational set-up occurs most of the time around 10:00 
am which allows the credit of securities by the agent before noon (as 
for cash proceeds) 

BE – NBB-SSS 

S7, S20, 
S21, 
S22d 

S7, S22d – Reversal of elective events not yet implemented – 
implementation planned for November 2026. 

All – November 2026 

S20, S21 – To be implemented. 

Corporate Events Compliance Report – Compliance assessment 

80 

 
 
 
Plan 

S3 - Q1 2025 

Market 

Gaps 

Status 

BG – CD AD 

S3 

S3 - According to the Rules of the Bulgarian Stock Exchange (Part III, 
Article 5. (1), item 10) the companies listed on the Premium segment 
of the BSE disclose regulated information to the general public 
simultaneously in Bulgarian and in English through the media chosen 
by the company within the respective deadlines. Other issuers are not 
obliged to publish information in English. Where applicable, the 
recently developed Electronic Platform for General Meetings (EPOS) 
may also be employed to obtain narrative text, inserted in a dedicated 
section for CA data announcement in Bulgarian and English. There 
are plans to include the standard in the list of upcoming changes to 
the Bulgarian Stock Exchange (BSE) Trading Rules for the next 
amendment session. CDAD is unable to commit to a specific date for 
the next amendment session of the BSE Trading Rules, as this action 
falls exclusively under the authority of the BSE. Relevant discussions 
have taken place between the two institutions, and CDAD has 
received assurances that all necessary actions will be taken to 
incorporate the required provisions into the referenced document. It is 
also important to note that the proposed amendments are subject to 
approval by the Financial Supervision Commission (FSC). 
Nonetheless, CDAD remains confident that the standard will be 
achieved within the designated timeframe. 

CH – SIX SIS 

S12 

S12 - The election period is less than the required 10 days. 

No plan 

CY – CSE 

S9, S10 

S9, S10 - Technical changes in custodians' infrastructures are 
currently assessed. 

All - No plan 

CZ – CSD Prague  S1-S6, 

S8-S10, 
S12-S16, 
S18-
S22a, 
S22c, 
S22d, 
S23c  

All standards – No plan 

S1 - Implemented only for listed shares and services of Investor CSD, 
i.e. for foreign securities, when CSD and its participants provide 
custodial services. Even though there is an obligation of issuers of 
listed securities to inform its issuer CSD about a corporate action, 
there is no obligation to use CSD for Mandatory Reorganisation with 
Options. With respect to Czech securities, Mandatory Reorganisation 
with Options via CSD has never been used. The Issuer or other third 
party communicates with their shareholders directly based upon the 
list of shareholders. Only issuers of listed securities are obliged by 
the law to inform its issuer CSD about a corporate action. These 
issuers should inform their issuer CSD in the same deadline for 
fulfilling the obligation to announce publicly the corporate action. 
There is no plan to change the law to increase administrative burden 
of all companies with book-entry shares or issuers of book-entry 
bonds to inform CSD about a corporate action preceding the change 
of the security itself. 

S2 - The standard is implemented with respect to listed shares. With 
respect to other securities, the law does not provide for formatted 
electronic form and the information is usually communicated in the 
same format as is published on the websites of the issuer (pdf). 
In case that issuer of listed shares does not inform the shareholders 
directly, the communication has to be in the format of Table 8 of IR 
2018/1212. 

S3 - Issuers of listed shares provide the information in English as 
well. There is an obligation from Art. 2/2 of IR 2018/1212 for listed 
shares. 
For non-listed securities, there is no obligation to inform in English. In 
practice, SMEs with international shareholder base would use 
bilingual text. There is no plan to change the law to increase 
administrative burden of all companies with book-entry shares or 
issuers of book-entry bonds to inform shareholders via CSD in 
English.   

S4 - The standard is implemented with respect to listed shares. With 
respect to other securities, CSD publishes received information 
immediately on its websites. CSD would supplement the information 
from the issuer with the information from the CSD, publish them in the 
CSD Bulletin that is sent to all CSD participants. CSD provides to all 
issuers in the CSD register the possibility to communicate the 
information by publication on CSD websites. 

S5 - CSD informs all its participants. There is no obligation for CSD to 
inform only relevant participants. All listed companies publish the 
information on their websites; therefore the information is public. 
There is no plan at the moment to distribute the information only to 
relevant participants. Neither SRD II nor IR provides for the obligation 
distribute only to relevant participants. 

Corporate Events Compliance Report – Compliance assessment 

81 

 
 
Market 

Gaps 

Status 

Plan 

S6 - There is an obligation from Art. 2/2 of IR 2018/1212 for listed 
shares. The law does not provide for formatted electronic form and 
the information is usually provided in the same format as is published 
on the websites of the issuer (pdf). S8 - Implemented only for listed 
shares and services of Investor CSD, i.e. for foreign securities, when 
CSD and its participants should inform their clients. With respect to 
listed shares, there is an obligation to transmit the information in two 
level register as owners of accounts on the second level of register 
are considered to be the shareholders. Records in any kind of sub-
register about end investors are not considered as book-entry shares 
and issuers provide payments to those named in the list of 
shareholders on record date. With respect to other Czech securities, 
there is no obligation at the moment and only participants providing 
custodial services would inform clients about a corporate action. 
Level of these services is not harmonised. There is no plan to change 
the law to increase administrative burden of all companies with book-
entry shares or issuers of book-entry bonds to inform shareholders 
via the CSD. 

S8 - Implemented only for listed shares and services of Investor CSD, 
i.e. for foreign securities, when CSD and its participants should inform 
their clients. With respect to listed shares, there is an obligation to 
transmit the information in two level register as owners of accounts 
on the second level of register are considered to be the shareholders. 
Records in any kind of sub-register about end investors are not 
considered as book-entry shares and issuers provide payments to 
those named in the list of shareholders on record date. With respect 
to other Czech securities, there is no obligation at the moment and 
only participants providing custodial services would inform clients 
about a corporate action. Level of these services is not harmonized. 

S9 - Partly implemented only listed shares and for services of 
Investor CSD, i.e. for foreign securities. With respect to other Czech 
securities, there is no obligation at the moment. With respect to listed 
shares, there is an obligation to transmit the information in electronic 
and machine-readable formats (2/2 of IR 2018/1212). There is no 
plan with respect to non-listed companies with book-entry shares or 
issuers of book-entry bonds. 

S10 - Implemented only for listed shares and services of Investor 
CSD, i.e. for foreign securities. With respect to other Czech 
securities, there is no obligation at the moment. There is no such an 
obligation neither in the valid legislation nor in the future legislation, 
including IR 2018/1212. IR allows for URL hyperlink to websites. 

S12-S15 - There is no experience with Mandatory Reorganisation 
with Options. 

S16 - Payments in book-entry securities may only be by book-entry. 
There is an obligation for companies with shares to make payments 
by crediting bank accounts of shareholders. There is no obligation of 
cashless payments with respect to bonds only a general obligation to 
make payments of more than CZK 270,000 by money transfer. If CSD 
distributes payments, it credits participants' cash accounts at Czech 
National Bank. There is no plan to impose an obligation to distribute 
proceeds only via CSD and onward chain of intermediaries. There is 
no legal obligation even for listed shares. 

S18, S19 - There is no experience with Mandatory Reorganisation 
with Options via CSD. 

S20 - There is no experience with Mandatory Reorganisation with 
Options via CSD.S21 - There is no experience with Mandatory 
Reorganisation with Options via CSD. 

S22a - In case that Issuer uses CSD for distribution, payments are 
made in Czech National Bank accounts of participants. There is no 
plan to impose an obligation to distribute proceeds only via CSD and 
onward chain of intermediaries. There is no legal obligation even for 
listed shares. 

S22c - There is usually no deadline for the issuer. 

S22d - There is no policy with respect to corrections of payments. 

S23c – No comments provided 

DE – 
Clearstream 
Banking 
Frankfurt 

DK – Euronext 
Securities 
Copenhagen 

S19 

S22d 

S19 - Election communication through the chain is in ISO format. 
Issuers do not support ISO as of yet. External development that is 
triggered by SRD II requirements. 

No Plan 

For debt securities, a compliant solution will be implemented in line 
with the SCoRE deadline, i.e., June 2025. For equity instruments, the 
deadline is November 2025. 

Q4 2025 

Corporate Events Compliance Report – Compliance assessment 

82 

 
 
Market 

Gaps 

Status 

Plan 

ES – Iberclear 

S7, S12, 
S14, S15, 
S22d 

S7, S22d - Implemented for most frequent events (REDM, MCAL, 
PCAL, WRTH). One custodian points out that the percentage of 
compliance is similar to the previous year and that they receive the 
reversal directly sometimes. One custodian indicated that the 
standard will be fulfilled as soon as Iberclear complies with it. The 
standard will be implemented in Q4 2025. 

S7, S12, S14, S22d - Q4 
2025. 
S15 – No plan 

S12, S14 - The standard is fully implemented for all mandatory 
reorganizations with options except for the Spanish "Dividendo 
Flexible", since the election period of the cash option does not last 10 
business days. Iberclear continues strongly recommending the usage 
of DVOP event type with a common election period for all announced 
options, it's difficult to change this non-standard approach because 
issuers prefer the current process as it has been used for several 
years. A credit institution and a custodian indicate that not all the 
events and issuers comply with this standard (dividendos opción). - 
Iberclear is optimistic regarding the fulfilment of this standard after 
SCoRE implementation and Spanish Reform in 2025. 

S15 - As described in our previous report, the payment date 
announced in the CA notification is as close as possible to the Market 
Deadline. However, payment date is not always the next Business 
Day, as a public deed is required to deliver new securities CSD points 
out that the recent amendment of the Corporate Enterprises Act 
allows for a more streamlined process in the delivery of the securities 
and before the Commercial Registry. We have observed this has 
contributed to enhance slightly the compliance of this standard. 
Please, for more information see article 508 of Legislative Royal 
Decreee 1/2010 approving the consolidated text of the Corporate 
Enterprises Act. 

FI – Euroclear 
Finland 

S7, S22d   S7, S22d - The Finnish regulation does not identify or allow a reversal 

No plan 

of a corporate action event that has been settled on the securities 
accounts. Hence, a full reversal process as defined in SCoRE CA 
standards cannot be implemented. Manual corrections may be 
required depending on the case. 

HR - SKDD 

S7, S22d  S7, S22d - Reversals are currently not allowed. No amendments to 

S7, S22d – No plan 

the law governing the procedure in the event of an erroneous 
remittance of funds are needed. However, the SKDD pays most 
payments from CAs to the accounts of the Beneficiary owners and, 
currently, the SKDD does not have the authority to directly debit their 
bank account (even if it did, these accounts would have to have 
sufficient funds necessary for the reversal). SKDD can only invite the 
Beneficiary owners to remit the funds paid from the CA, noting that 
until all the funds paid from the CA have been returned, the SKDD 
must not announce and implement a reversible CA. 

Corporate Events Compliance Report – Compliance assessment 

83 

 
 
 
 
HU – KELER 

S1-S8, 
S10, S11, 
S13-S15, 
S19, S20, 
S22a- 
S23a  

S1-S6, S10, S11 – 
December 2024 

S7, S8, S10, S11, S13-
S15, S19, S20, S22a-
S23a – December 2025 

S1 - From 3 September 2020 due to SRD II, KELER introduced its 
Corporate Action notification services for listed shares. The CSD's 
corporate action database is established, which increases the 
accessibility of corporate action information. Market players are 
informed on the details of the corporate actions after the 
announcement of the issuer, from the Issuer CSD. Announcements 
for corporate actions of securities other than listed equities remain 
with the existing announcement publication places: stock exchange, 
central bank's website, issuer's website. The extension of the 
corporate action announcement services of KELER to securities other 
than listed shares is planned by December 2024. 

S2 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form. Regarding securities other than listed equities: A 
corporate action database is available through KELER's proprietary 
communication system (KID) and on its website with limited range of 
information (only date and type of corporate action). Currently the 
Issuers do not inform the End Investors electronically. The standard is 
partially implemented at the moment, as the Issuers publish the 
information in the legally required places (on their own website, on 
kozzetetelek.hu website, and the listed Issuers on the website of the 
stock exchange). The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

S3 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer. The major 
Issuers and/or Issuers with considerable foreign ownership are 
currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER's General Business Rules shall be modified according to this 
standard. 

S4 - The implementation of this standard will be relevant during the 
implementation of standard 1. This standard will be implemented 
simultaneously with standard 1 for debt securities. 

S5 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form. Regarding securities other than listed equities: A 
corporate action database is available through KELER's proprietary 
communication system (KID) and on its website with limited range of 
information (only date and type of corporate action). Currently the 
Issuers do not inform the End Investors electronically. The standard is 
partially implemented at the moment, as the Issuers publish the 
information in the legally required places (on their own website, on 
kozzetetelek.hu website, and the listed Issuers on the website of the 
stock exchange). The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

S6 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer. The major 
Issuers and/or Issuers with considerable foreign ownership are 
currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER's General Business Rules shall be modified according to this 
standard. 

S7 - The reversal of the payment is not market practice, currently the 
Issuer transfers the corrected amount after transferring back the 
incorrect first payment. KELER participates in the procedure if 
KELER is appointed as paying agent. This standard is planned to be 
implemented by December 2025. 

S8 - In case of listed shares, KELER Participants receive the issuer's 
announcement from KELER and they forward it further down the 
chain. In case of other securities KELER participants obtain CA 
information not from the Issuer through KELER, but by processing the 
information published by the Issuer. They forward the information 
obtained the before mentioned way directly or through the custody 
chain to the End Investor. The KELER Participant can forward 
immediately the Corporate Action information obtained from KELER 
to the End Investor directly or through the custody chain. 

S10 - Due to SRD II, intermediaries are to forward corporate action 
announcements to non-Intermediaries in case of listed shares. In 
case of other securities, only intermediaries and investors with 
SWIFT connectivity may receive such announcements. Such practice 
is already part of the service of banks and custodians. In case of End 
Investors without SWIFT connectivity the announcements relevant for 
the Investor are available through the web-based application of some 
of the custodians. Providing such service is not an obligation, in most 

Corporate Events Compliance Report – Compliance assessment 

84 

 
 
Market 

Gaps 

Status 

Plan 

cases it is not part of the custody service pack. For securities other 
than listed shares, the implementation of standard 4 is necessary for 
intermediaries providing services for End Investors. 

S11 - Hungarian regulations generally prescribe stricter deadlines. 
E.g. in case of equities the decision of the GM must contain the start 
date of the payment of dividend. In case of bonds the policy 
conditions must contain the payment date, etc. There are different 
regulations for each kind of securities, there is no general rule for 
announcement deadlines. The Issuer inform the CSD according to 
standard 1 only in case of equities due SRD II regulations, in case of 
other securities issuers do not inform the CSD accrrding to standard 
1. After the implementation of standard 1 rules will be in line with this 
standard. 

S13 - There is no central Buyer Protection procedure on the market. 
Implementation of Buyer Protection mechanism by the time of the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

S14 - There is no central Buyer Protection procedure on the market. 
Implementation of Buyer Protection mechanism by the time of the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

S15 - The market practice does not comply with this standard. 
Implementation of Buyer Protection mechanism by the time of the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

S19 - Currently the pre-conditions of information flow are not built out. 
The standard is applied for End Investors with SWIFT connectivity. As 
a result of the planned development, KELER will handle the 
Mandatory Reorgs. with Options in line with the standard. The 
implementation of this standard is expected by December 2025. 

S20 - The CSD can clearly separate each kind of securities, but 
Interim Security is not part of the market practice. As a result of the 
planned development, KELER will handle the Mandatory Reorgs. with 
Options in line with the standard. The implementation of this standard 
is expected by December 2025. 

S22a - KELER is not a central paying agent, Issuers may appoint any 
third party as paying agent. This way Payments are not always made 
through KELER. The revision of the current payment procedures is in 
progress in line with the implementation of the planned 
developments. The implementation of this standard is planned by 
December 2025. 

S22b - For listed shares, the payments are not yet done by KELER. 
For other securities, the announcement of the CSD according to the 
standards does not exist, but of course the payment is made in the 
currency published in the announcement of the Issuer published in 
other places. After the implementation of standard 1 and 22a rules 
will be in line with this standard. 

S22c - It is possible to transfer the payment before 12:00, however 
there is no obligation for the Issuer or its paying agent to transfer 
before midday. KELER as paying agent complies with the standard. 
The revision of the current payment procedures is in progress in line 
with the implementation of the planned developments. The 
implementation of this standard is planned by December 2025. 

S22d - According to the current market practice the Issuer transfers 
the correct amount after transferring back the incorrect payment. 
KELER participates in the process only if KELER is appointed as 
paying agent. This standard is planned to be implemented by 
December 2025. 

S23a - There is no obligation for the issuer or the paying agent to 
transfer as early as possible on the Payment Date. The revision of 
the current payment procedures is in progress in line with the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

IE – Euroclear 
Bank 

S13, S14, 
S22c, 
S23a, 
S23b, 
S23c 

S13 - The Guaranteed Participation date is not yet notified by EB as 
not received by the issuer. 

S14 - The Buyer Protection Deadline is not yet notified by EB as not 
received by the issuer. 

S13, S14 - Q2 2024 
S22c - 2029 
S23a, b, c – No plan 

S22c - Cash not always credited before noon as cash needs to be 
received from issuer/registrar and reconciled by EB before EB can 
process the payment. However, Euroclear Bank has started a multi 
year program which foresees the progressive migration of the legacy 
custody processing to a new Asset Servicing Platform. Compliance 
with corporate action standards is part of the scope of this project 
divided into multiple phases with an end delivery date expected 
around 2029. 

Corporate Events Compliance Report – Compliance assessment 

85 

 
 
Market 

Gaps 

Status 

Plan 

S23a - No such events in 2023. The timing of payments would 
depend on when the registrar can deliver the securities. 

S23b,c - The Euroclear Bank Nominee would receive a whole 
number of shares (no fractions) and would apply a rounding 
methodology which ensures that all shares are distributed to its 
participants. However, Euroclear Bank’s current methodology consist 
of rounding up to the largest shareholder and is therefore not 
compliant with the standard. Further feedback is needed from 
Euroclear Bank on when the ICSD will apply the top-down method 
(rounding down to the nearest whole number, in line with the 
standard) instead. 

IS – Nasdaq CSD  S8-S10 

S8-S10 - Unknown by the CSD how well the CSD participants comply 
with the standard, all participants comply to the standard when it 
comes to specific voluntary corporate actions events for example 
Rights issues and dividend payments 

S8-S10 - Not known, to be 
discussed with 
participants.   

IT – Euronext 
Securities Milan 

S4 

S4 - As of today, CSD announcements are sent taking into account 
settled positions only, thus excluding any pending receipt and/or 
delivery that might impact the eligible balance. 

Q1 2026 

LU – 
Clearstream 
Banking 
Luxembourg 

S13, S14, 
S17b, 
S22c, 
S23a 

S13, S14 - No plan 

S22c, S23a - No plan 

S13, S14 - The key buyer protection dates are not yet notified 
although the CBL is technically ready to transmit this information. 
Both ICSDs agreed on common rules for generating the BP key dates 
for the International market. This process will be fully handled by 
ICSDs, therefore, the question of the implementation is only on the 
ICSDs side and will depend on available technical release. 
Preferably, a common implementation date should be agreed 
between both ICSDs (not expected before end 2024) to be followed 
by an update of the ISMAG standards accordingly. 

S17b - Payments are made in the currency of the new securities 
(while the standards state that payments should be made in the 
original currency). 

S22c - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on the currency, operating time-zone 
of the Agents as well as the timing that the issuers can release the 
payment (i.e. availability of cash). CBL had with Euroclear Bank a 
joint call with Common Depositories and Agents to explain the rules 
and the AMI-SeCo monitoring process. Although ICSDs timing 
requirements are to be reinforced in line with the SCoRE CA 
Standards, the dependency on issuers and their agents will remain. 

S23a - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payment depends on when the issuers’ agent can 
deliver the securities. CBL had with Euroclear Bank a joint call with 
Common Depositories and Agents to explain the rules and the AMI-
SeCo monitoring process. Although ICSDs timing requirements are to 
be reinforced in line with the SCoRE CA Standards, the dependency 
on issuers and their agents will remain. 

LU – LuxCSD 

S13, S14  S13, S14 - The key buyer protection dates are not yet notified 

S13, S14 - 2025 

although the CSD is technically ready to transmit this information. 
The current proposal is that the CSD calculates such dates as per the 
standards and notify the participants accordingly. The proposal was 
submitted to the market for validation and approved. Developments 
are planned to achieve full compliance with the standard after the 
ECMS go-live, in the course of 2025. 

Marked as non-compliant following internal plausibility check. 

S1 - Legal barrier. The Issuer has no such obligation to inform the 
CSD. Key Dates are not always announced or very late. There is no 
applicable law defining the Issuer to inform specifically the CSD. 

All – Q3 2026 

S2, S18 - Technical barrier. Not all information can be communicated 
in formatted electronic form using standards defined and used by the 
securities industry, such as the ISO standards, irrespective of the 
communication channel used. 

S4 - Technical barrier. Batch solution running EOD and not possible 
to deliver on Pending Transaction in the Underlying Security with the 
Issuer as understood from the event lifecycle processing. 

MT – Malta Stock 
Exchange 

NO – Euronext 
Securities Oslo 

S2, S8, 
S9, S22a, 
S22d, 
S23b,c 

S1, S2, 
S4-S7, 
S9, S11, 
S13-S15, 
S17, S19, 
S20, 
S22a, 
S22d-
S23c 

Corporate Events Compliance Report – Compliance assessment 

86 

 
 
 
 
Market 

Gaps 

Status 

Plan 

S5 - Technical barrier. Batch solution running EOD and not possible 
to inform participant who obtains a holding or is subject to a new 
Transaction on the Underlying Security after the announcement until 
the Record Date as understood from the event lifecycle processing. If 
event has an event update, new holdings will be included in this 
updated. 

S6, S9 - Technical barrier. Not all information and events can be 
communicated in formatted electronic form using standards defined 
and used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S7 - Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S11 - Legal barrier. The Issuer has no such obligation to inform the 
CSD, especially relevant for Bonds. Key Dates are not always 
announced or very late. There is no applicable law defining the Issuer 
to inform specifically the CSD. Technical barrier. Not all information 
can be communicated in formatted electronic form using standards 
defined and used by the securities industry, such as the ISO 
standards, irrespective of the communication channel used. 

S13, S14 - No such function exists in the Norwegian Market. 

S15 - Technical barrier for some cash payment. All Corporate Actions 
payments are paid via national payment infrastructure. 

S17 - Technical barrier. Only rights distribution is processed like this 
today. 

S19, S20 - Technical barrier. 

S22d - Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. Also, all Corporate 
Actions payments are paid via national payment infrastructure. Legal 
Barrier. For Investors, Payments is executed in commercial bank 
money. Therefore, for the vast majority of Investors payments from 
Issuer will be done in commercial bank money. 

S23a - Technical barrier. Existing system has a fragments processing 
cash and securities. In addition, an ISIN that is different from the ISIN 
of the Underlying Security is not allocated to each outturn security. 

S23b - Technical barrier. Existing system has a fragments processing 
of some securities payments. Legal barrier CSD register authorisation 
impacts the processing (rounding aggregation) of investors owning 
multiple safekeeping accounts. 

S23c - Legal barrier. No requirements on the issuer to compensate 
fraction is cash when they can do rounding any way the choose as 
per 16.b). 

S2, S3, S13, S14 - Q4 
2026 
S7, S22d – No plan 
S15 - No plan 

PL -– KDPW 

S2, S7, 
S13-S15, 
S22d 

S2 - The communication from the issuer to the CSD is in electronic 
form, however the data provided is not formatted in compliance with 
ISO standards. 

S7, S22d – As per decision of AMI-SeCo NSG PL, the reversals 
processing will not be implemented for mandatory reorganisations 
with options. A reversal process compliant with the standard cannot 
be implemented currently owing to legal barriers. In the opinion of 
KDPW, the mere fact of an error of an issuer or of KDPW may at 
most constitute grounds for the issuer or KDPW to demand that the 
person/KDPW participant to whom the undue benefit has been paid 
should return it but it does not, in itself, constitute grounds for the 
issuer or KDPW to be able to compulsorily (i.e. against the will of 
such person) enforce such benefit against such person. Furthermore, 
the risk must also be considered that the issuer may not have been in 
error at all and would like to use the reversal to collect the benefit 
paid through KDPW, to which the issuer has no legal title. 

S13 - Manual Buyer Protection Market Practice as well as BP 
Instruction template are in place. Nonetheless, having very limited 
number of real-life scenarios at CSD level, market participants see no 
practical reason to endorse it. Thus, in spite of being able to, the CSD 
does not provide those dates. 

S14 - Manual Buyer Protection Market Practice as well as BP 
Instruction template are in place. Nonetheless, having very limited 
number of real-life scenarios at CSD level, market participants see no 
practical reason to endorse it. Thus, in spite of being able to, the CSD 
does not provide those dates. 

Corporate Events Compliance Report – Compliance assessment 

87 

 
 
Market 

Gaps 

Status 

Plan 

S15 - The average period between MD and PD of the elected option 
is 5 business days. KDPW in their current assessment believe that 
the Market Deadline and Payment Date for chosen options is 
shortened to a minimum, taking into account functions necessary for 
the operation of the business process. Changing the period between 
Record Date and Payment Date requires a change in the Commercial 
Companies Code. There are no such plans yet. 

PT – Euronext 
Securities Porto 

S2, S7, 
S22d 

S2 - The information is communicated electronically through Euronext 
Securities Porto portal or e-mail. The ISO standards are not 
implemented yet. No appetite from the market. 

Q4 2025 

S7 - Very few reversals exist in the market. When requested, the 
CSD always announces its participants by email when there is a 
correction and the reason for the same. 

S22d - Very few reversals exist in the market. When requested, the 
CSD makes corrections to the payments. 

As part of the Euronext New Corporate Event Service initiative, the 
compliance deadline is June 2025 for debt instruments (linked to 
ECMS) and November 2025 for other securities. 

S7 - Prior to the processing of a reversal the information is 
communicated by the CSD to the affected parties in a proprietary 
form (via email). In the context of AMI-SeCo SCoRE standards 
implementation, the CSD plans to implement the standard 
notifications and automated flows according to Standard no. 13 
(Reversal of a corporate action) by November 2025. 

S7 – Q4 2025 

RO – Depozitarul 
Central 

S7 

SE – Euroclear 
Sweden 

S1-S3, 
S8, S18, 
S19, 22d 

S1 - Most mandatory reorganisations with options have an interim 
ISIN as underlying security, and as a result the notification cannot be 
sent by the CSD until the ISIN has been assigned and announced. 
No compensation price for fractions is announced - but the method of 
determining the price is usually announced. 

No plan 

S2 - Mandatory reorganisation with options event information is 
provided by issuers to the CSD via manual means. 

S3 - Almost all listed companies provide at least a summary of the 
event narrative in English on their websites. An amendment of the 
CSD rules requiring “”avitext”” in both English and Swedish was 
implemented late 2011. 

S6: - The standard is reported as 100% implemented. Please note 
that some intermediaries still use the old, non-ISO, interface. The 
CSD offers an older version of CA information interface. The old 
version contains the same information – the ISO    15022 messages 
are created from that information – but in a different format. CSD 
participants are not required to migrate to ISO 15022 messages and 
as the old version also contains information not provided in ISO 
15022 messages, not all CSD participants want to maintain access to 
both. 

S7, S22d - Reversals are not performed by the CSD due to legal 
reasons, and this has been the case since start of the CSD. In earlier 
years the SE MIG have stated that Standard 7 was complied with 
compliant since Euroclear Sweden, in case a payment would ever be 
reversed, would have sent such an announcement. However, 
following a legal analysis performed by a Government Inquiry, it was 
clarified early 2024 that a reversal of a cash distribution is in breach 
with Swedish property law, which is why the CSD would never 
perform such a reversal. 

S8 – Not all intermediaries can send information on pending 
transactions, only on holdings. 

S18 – Issuers do not use option identifiers. 

S19 – Elections are not sent to the issuer/issuer agent via the CSD. 
CSD participants send aggregated instructions for holdings on CSD 
nominee accounts to the issuer agent, generally as scanned forms 
sent via email. Instructions to such CSD participants are generally in 
formatted electronic form. For holdings on CSD owner accounts, 
investors send their election forms directly to the issuer agent. 

S22a, b, c – The standards are not applicable. Payments from 
issuers do not occur in Swedish reorganisations with options 
("secondary" interim securities are used instead). Payments to 
issuers are common (eg. subscription payment) but are not made via 
the CSD. The response has changed, but the actual status has not. 

SK – CDCP 

All 
standards 

All - Standards in process of implementation 

All – Q1 2026 

Corporate Events Compliance Report – Compliance assessment 

88 

 
 
 
3.2.3 

Voluntary Reorganisations 

Chart 6 
Voluntary Reorganisations – % compliance per market 

Notes: N/A. 

Box 8 
Voluntary Reorganisations – Compliance status per Standard 

Information 
from Issuer to 
Issuer (I)CSD 

Information from 
Issuer (I)CSD to its 
participants 

Information flow 
from (I)CSD 
participants to 
End Investor 

Key dates 

Processing 

AT - Oesterreichische 
Kontrollbank 

BE - Euroclear Bank 

BE - Euroclear 
Belgium 

BE - NBB-SSS 

1 

B 

B 

B 

B 

2 

B 

B 

B 

B 

3 

B 

B 

B 

B 

4 

B 

B 

B 

B 

5 

B 

B 

B 

B 

6 

B 

B 

B 

7 

B 

B 

B 

8 

B 

B 

B 

B  25%  B 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21  22a  22b  22c  22d  23 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  0% 

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  25%  B 

B 

B 

B 

B 

B  75%  B  50% 

B 

B 

B 

B 

B 

B  25%  B 

BG - BNBGSSS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

BG - CD AD 

CH - SIX SIS 

CY - Cyprus Stock 
Exchange 

B 

B 

B 

B  75%  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  75%  B 

B  75%  75%  B 

B 

B  75%  75%  B 

B 

0%  0%  0% 

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 

CZ - CSD Prague 

B  25%  25%  B 

B  75%  B  75%  25%  25%  B 

0%  0%  0%  0%  0%  75%  B 

0%  0%  0%  50%  B  50%  0% 

B 

CZ - SKD 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

DE - Clearstream 
Banking Frankfurt 

DK - Euronext 
Securities 
Copenhagen 

N/A  N/A  N/A  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 

B 

B 

B 

B  75%  B 

B 

B  75%  B 

EE - Nasdaq CSD 

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 

Corporate Events Compliance Report – Compliance assessment 

89 

0%10%20%30%40%50%60%70%80%90%100%AT - Oesterreichische KontrollbankBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - Nasdaq CSDES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSGR - ATHEXCSDHR - SKDDHU - KELERIE - Euroclear BankIS - NasdaqIT - Euronext Securities MilanLI - SIX SISLT - Nasdaq CSDLU - Clearstream Banking LuxembourgLU - LuxCSDLV - Nasdaq CSDMT - Malta Stock ExchangeNL - Euroclear NederlandNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4PT - Euronext Securities PortoRO - Depozitarul CentralRO - SaFIRSE - Euroclear SwedenSI - KDDSK - CDCPUK - Euroclear UK & International 
 
 
 
  
Information 
from Issuer to 
Issuer (I)CSD 

Information from 
Issuer (I)CSD to its 
participants 

Information flow 
from (I)CSD 
participants to 
End Investor 

Key dates 

Processing 

ES - Iberclear 

1 

B 

FI - Euroclear Finland  B 

FR - Euroclear France  B 

GR - BOGS 

GR - ATHEXCSD 

HR - SKDD 

B 

B 

B 

2 

B 

B 

B 

B 

B 

B 

3 

B 

B 

B 

B 

B 

B 

4 

B 

B 

B 

B 

B 

B 

5 

B 

B 

B 

B 

B 

B 

6 

B 

7 

0% 

8 

B 

B  25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  25%  B 

9 

B 

B 

B 

B 

B 

B 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21  22a  22b  22c  22d  23 

B  75%  50%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  0%  0% 

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 

B 

0% 

B 

B  25%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  25%  B 

HU - KELER 

50%  50%  50%  25%  50%  50%  25%  50%  B  50%  25%  B  25%  25%  25%  25%  B 

B  25%  25%  B  25%  25%  25%  25%  25% 

IE - Euroclear Bank 

IS – Nasdaq CSD 

IT - Euronext 
Securities Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - Clearstream Banking 
Luxembourg 

LU - LuxCSD 

LV - Nasdaq CSD 

MT - Malta Stock 
Exchange 

NL - Euroclear 
Nederland 

NO - Euronext 
Securities Oslo 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  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  50%  50%  50%  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 

0%  0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  25%  25%  B 

B  25%  25%  B 

B 

B 

B 

B 

B 

B 

B 

B  50%  B 

B 

0% 

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 

B 

B 

B  75%  B  75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  75%  B  50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  50%  B 

B  50%  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 

0%  75%  B  50%  25%  75%  0% 

B  75%  B  75%  B 

0%  0%  75%  B 

B  75%  B 

0%  0%  0% 

B 

B 

0%  75% 

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 

PL - KDPW 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B  50%  50%  50%  B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

PL - SKARBNET4 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

PT - Euronext 
Securities Porto 

RO - Depozitarul 
Central 

B  75%  B 

B 

B 

B  75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  75%  B 

B 

B 

B 

B 

B 

B  75%  B 

B 

B 

B 

B 

B 

B 

B 

0%  0%  0%  0%  0%  0%  B 

B 

B 

B 

0% 

RO - SaFIR 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

SE - Euroclear 
Sweden 

B 

0%  75%  B 

B  75%  0%  75%  B 

SI - KDD 

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 

0%  50%  B 

0% 

B  50%  0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

SK - CDCP 

75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  75%  25%  75%  75%  75%  75%  75%  75% 

UK - Euroclear UK & 
International 

0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

Notes: Voluntary Reorganisations are outside the scope of BNBGSSS, SKARBNET4, SKD, and SaFIR activities. 

Table 7 
Voluntary Reorganisations - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the Voluntary 
Reorganisations standards. Markets/CSDs not listed below have been assessed as fully 
compliant. 

Market 

Gaps 

Status 

Plan 

BE – Euroclear 
Bank 

S13, S14, 
S22c, 
S23  

S13, S14 – Q4 2025 
S22c, S23 – Q4 2024 

S13, S14 - The key BP dates are not yet notified although Euroclear 
Bank is technically ready to transmit this information via non 
structured field. Both ICSDs agreed on the common rules for 
generating the BP key dates for the International market. This 
process will be fully handled by ICSDs, therefore, the question of the 
implementation is only on the ICSDs side and will depend on 
available technical release. Preferably, a common implementation 
date should be agreed between both ICSDs (not expected before end 
2024) to be followed by an update of the ISMAG standards 
accordingly. The implementation in PROD is not precisely defined yet 
but Q4 2025 is the new possible window. 

Corporate Events Compliance Report – Compliance assessment 

90 

 
 
 
  
Market 

Gaps 

Status 

Plan 

BE – NBB-SSS 

S7, S21, 
S22d 

BG – CD AD 

S3, S16 

S22c, S23 - This is in line with the timing that is currently defined in 
the International Securities Operational Market Practice Book. 
However, the timing of payments depends on currency, operating 
time-zone of the Agents as well as the timing that the issuer can 
release the payment (i.e., availability of cash). The concrete action 
taken is the update of MOP (Manual of Procedure) shared with 
Common Depositories and Agents in October 2024. This is a 
contractual document in which Euroclear Bank recommended the 
deadline to be compliant with those standards (and also SCoRE). 
Euroclear Bank had with CBL a joint call with some of those agents to 
explain the rules and the AMI-SeCo monitoring process. To be fully 
implemented by November 2024. 

S7, S22d - Reversal of elective events are not yet implemented. 

All - November 2026 

  Q1 2025 

S21 – To be implemented 

S3 - According to the Rules of the Bulgarian Stock Exchange (Part III, 
Article 5. (1), item 10) the companies listed on the Premium segment 
of the BSE disclose regulated information to the general public 
simultaneously in Bulgarian and in English through the media chosen 
by the company within the respective deadlines. Other issuers are not 
obliged to publish information in English. Where applicable, the 
recently developed Electronic Platform for General Meetings (EPOS) 
may also be employed to obtain narrative text, inserted in a dedicated 
section for CA data announcement in Bulgarian and English. There 
are plans to include the standard in the list of upcoming changes to 
the Bulgarian Stock Exchange (BSE) Trading Rules for the next 
amendment session. CDAD is unable to commit to a specific date for 
the next amendment session of the BSE Trading Rules, as this action 
falls exclusively under the authority of the BSE. Relevant discussions 
have taken place between the two institutions, and CDAD has 
received assurances that all necessary actions will be taken to 
incorporate the required provisions into the referenced document. It is 
also important to note that the proposed amendments are subject to 
approval by the Financial Supervision Commission (FSC). 
Nonetheless, CDAD remains confident that the standard will be 
achieved within the designated timeframe. 

S16 - An announcement is made by the Issuer/Offeror (e.g. in the 
Official Bulletin of the Bulgarian Stock Exchange or in the media 
provider of the public company) independently from the Market 
Deadline and Payment Date. Therefore, the Payment Date is not 
linked to the announcement of results, regardless of whether the 
voluntary reorganisation is conditional or not. The corresponding 
amendments in the regulatory documents are expected. 

CH – SIX SIS 

S13, S14  S13, S14 – The Guaranteed Participation Date and Market Deadline 

No plan 

for Swiss tender offers are on the same day, which is not compliant 
with the standard. 

CY – CSE 

S9, S10, 
S13-S15 

S9, S10 - Technical and regulatory changes from Cyprus CSD are 
required to implement the standard 

S9, S10, S15 – No plan 

S13, S14 – H2 2025 

CZ – CSD Prague  S2, S3, 
S5, S6, 
S8-S10, 
S12-S17, 
S19-
S22a, 
S22c, 
S22d 

All standards - No plan 

S13, S14 - Guidance, market templates, SWIFT messaging etc are 
expected to be applied by ATHEXCSD, and hence the CSE, in 2025 
H2, after market consultations. 

S15 – Technical and regulatory changes from Cyprus CSD are 
required to implement the standard, as consultation with local 
regulator on behalf of ATHEXCSD, and also regulatory changes and 
adaptation of issuers' procedures are required. 

S2 - The standard is implemented with respect to listed shares. In 
case that issuer of listed shares does not inform the shareholders 
directly, the communication has to be in the format of Table 8 of IR 
2018/1212. With respect to other securities, the law does not provide 
for formatted electronic form and the information is usually 
communicated in the same format as is published on the websites of 
the issuer (pdf). There is no plan to change the law to increase 
administrative burden of all companies with book-entry shares or 
issuers of book-entry bonds to inform CSD about a corporate action 
that does not influence the security itself. 

S3 - Issuers of listed shares provide the information in English as 
well. There is an obligation from Art. 2/2 of IR 2018/1212 for listed 
shares. For non-listed securities, there is no obligation to inform in 
English. In practice, SMEs with international shareholder base would 
use bilingual text. There is no plan to change the law to increase 
administrative burden of other companies with book-entry shares or 
issuers of book-entry bonds to inform shareholders via CSD in 
English. There is no plan to change the law to increase administrative 
burden of all companies with book-entry shares or issuers of book-
entry bonds to inform shareholders via CSD. 

Corporate Events Compliance Report – Compliance assessment 

91 

 
 
 
Market 

Gaps 

Status 

Plan 

S5 - There is no plan at the moment to distribute the information only 
to relevant participants. Neither SRD II nor IR provides for the 
obligation distribute only to relevant participants. There is no plan at 
the moment to distribute the information only to relevant participants. 
Neither SRD II nor IR provides for the obligation distribute only to 
relevant participants. There is no plan at the moment to distribute the 
information only to relevant participants. Neither SRD II nor IR 
provides for the obligation distribute only to relevant participants. 

S6 - The standard is implemented with respect to listed shares. There 
is an obligation from Art. 2/2 of IR 2018/1212 for listed shares. The 
law does not provide for formatted electronic form and the information 
is usually provided in the same format as is published on the 
websites of the issuer (pdf). There is no plan to change the law to 
increase administrative burden of all companies with book-entry 
shares or issuers of book-entry bonds to inform shareholders via 
CSD. 

S8 - Implemented only for listed shares and services of Investor CSD, 
i.e. for foreign securities, when CSD and its participants should inform 
their clients, until the information reaches the end investor. With 
respect to listed shares, there is an obligation to transmit the 
information in two level register as owners of accounts on the second 
level of register are considered to be the shareholders. Records in 
any kind of sub-register about end investors are not considered as 
book-entry shares and issuers provide payments to those named in 
the list of shareholders on record date. With respect to other Czech 
securities, there is no obligation at the moment and only participants 
providing custodial services would inform clients about a corporate 
action. Level of these services is not harmonised. 

S9 - Partly implemented for listed shares and for services of Investor 
CSD, i.e. for foreign securities. With respect to listed shares, there is 
an obligation to transmit the information in electronic and machine-
readable formats (2/2 of IR 2018/1212). With respect to other Czech 
securities, there is no obligation at the moment. There is no plan with 
respect to non-listed companies with book-entry shares or issuers of 
book-entry bonds. 

S10 - Implemented only for listed shares and for services of Investor 
CSD, i.e. for foreign securities. With respect to Czech securities, 
there is no obligation at the moment. There is no such an obligation 
neither in the valid legislation , including IR 2018/1212. IR allows for 
URL hyperlink to websites. 

S11 - Implemented only for services of Investor CSD, i.e. for foreign 
securities, when CSD and its participants distribute Interim Securities 
to their clients. There is no obligation of issuers to use CSD for 
Distribution with Options. With respect to Czech securities, 
Distribution with Options via CSD has been used only extraordinarily. 
The Issuer or other third party communicates with their shareholders 
directly based upon the list of shareholders. There is no plan to 
impose an obligation on issuers to use CSD for Distribution with 
Options. 

S12 – S16, S19-S21 - There is no experience with Voluntary 
Reorganisation via the CSD. 

S17 - Payments in book-entry securities may only be by book-entry. 
There is an obligation for companies with shares to make payments 
by crediting bank accounts of shareholders. There is no obligation of 
cashless payments with respect to bonds only a general obligation to 
make payments of more than CZK 270,000 by money transfer.   
If CSD distributes payments, it credits participants' cash accounts at 
Czech National Bank. 

S22a - In case that Issuer uses CSD for distribution, payments are 
made in Czech National Bank accounts of participants. S22c - There 
is usually no deadline for the issuer. S22d - There is no policy with 
respect to corrections of payments. There is no plan to impose an 
obligation to distribute proceeds only via CSD and onward chain of 
intermediaries. There is no legal obligation even for listed shares. 

S22c - There is usually no deadline for the issuer. 

S22d - There is no policy with respect to corrections of payments 

CZ – SKD 

S8-S23 

All – Marked as non-compliant following CEG assessment 

DK – Euronext 
Securities 
Copenhagen 

S21, 
S22d 

S21 – Events are very seldom in Danish market and if it is needed 
the process is manual. 

S21 – No plan 

S22d – Q4 2025 

S22d - For debt securities, a compliant solution will be implemented 
in line with the SCoRE deadline, i.e., June 2025. For equity 
instruments, the deadline is November 2025. 

Corporate Events Compliance Report – Compliance assessment 

92 

 
 
 
Plan 

S7, S22d – Q4 2025 

S15 – No plan 

S16 – Q4 2024 

Market 

Gaps 

Status 

ES – Iberclear 

S7, S15, 
S16, 
S22d 

S7, S22d - As described in the last Standards Market Progress 
Report (November 2023), Iberclear is already working on the 
implementation of this standard. There are some open points which 
should be covered at the CSD level and at the European Community 
level related to the difficulties to settle securities instructions if there is 
a lack of securities in any of the safekeeping accounts. One 
custodian indicates that it is waiting for ECMS implementation. 
Implemented for most frequent events (REDM, MCAL, PCAL, 
WRTH). One custodian points out that the percentage of compliance 
is similar to the previous year and that they receive the reversal 
directly sometimes. 

S15 - The payment date announced in the CA notification is as close 
as possible to the Market Deadline. However, payment date is not 
always the next Business Day, as a public deed is required to deliver 
new securities. For information, the CSD declared implementation 
status 50%, while three participants indicated 100%, 100% and 50% 
respectively. The is currently no plan to comply with the standard. The 
recent amendment of the Corporate Enterprises Act allows for a more 
streamlined process in the delivery of the securities and before the 
Commercial Registry. We have observed this has contributed to 
enhance slightly the compliance of this standard. Please, for more 
information see article 508 of Legislative Royal Decree 1/2010 
approving the consolidated text of the Corporate Enterprises Act. 

S16 - Results Publication date was not informed for voluntary 
reorganisations through ISO standards. For information, the CSD 
declared implementation status 50%, while three participants 
indicated 100%, 100% and 50% respectively. In line with other 
corporate actions adaptations due to the SCoRE standards 
implementation, the standard will be implemented by November 
2024. 

FI – Euroclear 
Finland 

S7, S22d  S7, S22d - The Finnish regulation does not identify or allow a reversal 

S7, S22d – No plan 

of a corporate action event that has been settled on the securities 
accounts. Hence, a full reversal process as defined in SCoRE CA 
standards cannot be implemented. Manual corrections may be 
required depending on the case. 

S11 - Some exceptional cases have been identified, and since there 
are few events of this type, the percentage of compliance is lower 
than expected this year. However, there are cases of dependency on 
the approval to be given by the Authorities for the operation to take 
place. Market monitoring in place. 

S12 - Some cases have been identified. However, French law allows 
a shorter election period (linked to market exposure risks). Market 
monitoring in place. 

S11, S12 – No plan 

FR – Euroclear 
France 

S11, S12 

GR – ATHEXCSD  S13-S15 

S13, S14 - Corporate actions are only affected on settled positions as 
of record date. Guaranteed participation has not yet been 
implemented. Guidance, market templates, swift messaging, etc., are 
expected in 2025H2, after market consultation. 

H2 2025 

S15 - Requires notification and adjustments to Issuer procedures, 
consultation with local Regulator, changes in the ATHEXCSD 
Rulebook. Guidance, market templates, swift messaging, etc., are 
expected in 2025H2, after market consultation. 

HR – SKDD 

S7, S22d  S7, S22d – No amendments to the law governing the procedure in 

S7, S22d – No plan 

the event of an erroneous remittance of funds are needed. However, 
the SKDD pays most payments from CAs to the accounts of the 
Beneficiary owners and, currently, the SKDD does not have the 
authority to directly debit their bank account (even if it did, these 
accounts would have to have sufficient funds necessary for the 
reversal). SKDD can only invite the Beneficiary owners to remit the 
funds paid from the CA, noting that until all the funds paid from the 
CA have been returned, the SKDD must not announce and 
implement a reversible CA. 

S1 - From 3 September 2020 due to SRD II, KELER introduced its 
Corporate Action notification services for listed shares. The CSD's 
corporate action database is established, which increases the 
accessibility of corporate action information. Market players are 
informed on the details of the corporate actions after the 
announcement of the issuer, from the Issuer CSD. Announcements 
for corporate actions of securities other than listed equities remain 
with the existing announcement publication places: stock exchange, 
central bank's website, issuer's website. The extension of the 
corporate action announcement services of KELER to securities other 
than listed shares is planned by December 2024. 

S1-S6, S11, S19 – 
December 2024 

S7, S8, S10, S13-S16, 
S20, S22a-S23 – 
December 2025 

HU – KELER 

S1-S8, 
S10, S11, 
S13-S16, 
S19, S20, 
S22a-S23 

Corporate Events Compliance Report – Compliance assessment 

93 

 
 
 
 
 
Market 

Gaps 

Status 

Plan 

S2 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form. Regarding securities other than listed equities: A 
corporate action database is available through KELER's proprietary 
communication system (KID) and on its website with limited range of 
information (only date and type of corporate action). Currently the 
Issuers do not inform the End Investors electronically. The standard is 
partially implemented at the moment, as the Issuers publish the 
information in the legally required places (on their own website, on 
kozzetetelek.hu website, and the listed Issuers on the website of the 
stock exchange). The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

S3 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer. The major 
Issuers and/or Issuers with considerable foreign ownership are 
currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER's General Business Rules shall be modified according to this 
standard. 

S4 - The implementation of this standard will be relevant during the 
implementation of standard 1. This standard will be implemented 
simultaneously with standard 1 for debt securities. 

S5 - KELER, as issuer CSD receives the corporate action information 
from the issuers of listed shares according to standard 1 in formatted 
electronic form. Regarding securities other than listed equities: A 
corporate action database is available through KELER's proprietary 
communication system (KID) and on its website with limited range of 
information (only date and type of corporate action). Currently the 
Issuers do not inform the End Investors electronically. The standard is 
partially implemented at the moment, as the Issuers publish the 
information in the legally required places (on their own website, on 
kozzetetelek.hu website, and the listed Issuers on the website of the 
stock exchange). The extension of the corporate action 
announcement services of KELER to securities other than listed 
shares is planned by December 2024. 

S6 - For liquid listed shares, SRD II requires the usage of English 
language for announcements according to standard 1. In Hungary, 
the default language of publishing is Hungarian. The publication in 
English depends on the individual decision of the Issuer. The major 
Issuers and/or Issuers with considerable foreign ownership are 
currently publishing the information in English also. For securities 
other than listed shares, during the implementation of standard 1, 
KELER's General Business Rules shall be modified according to this 
standard. 

S7 - The reversal of the payment is not market practice, currently the 
Issuer transfers the corrected amount after transferring back the 
incorrect first payment. KELER participates in the procedure if 
KELER is appointed as paying agent. This standard is planned to be 
implemented by December 2025. 

S8 - In case of listed shares, KELER Participants receive the issuer's 
announcement from KELER and they forward it further down the 
chain. In case of other securities KELER participants obtain CA 
information not from the Issuer through KELER, but by processing the 
information published by the Issuer. They forward the information 
obtained the before mentioned way directly or through the custody 
chain to the End Investor. The KELER Participant can forward 
immediately the Corporate Action information obtained from KELER 
to the End Investor directly or through the custody chain. 

S10 - Due to SRD II, intermediaries are to forward corporate action 
announcements to non-Intermediaries in case of listed shares. In 
case of other securities, only intermediaries and investors with 
SWIFT connectivity may receive such announcements. Such practice 
is already part of the service of banks and custodians. In case of End 
Investors without SWIFT connectivity the announcements relevant for 
the Investor are available through the web-based application of some 
of the custodians. Providing such service is not an obligation, in most 
cases it is not part of the custody service pack. For securities other 
than listed shares, the implementation of standard 4 is necessary for 
intermediaries providing services for End Investors. 

Corporate Events Compliance Report – Compliance assessment 

94 

 
 
Market 

Gaps 

Status 

Plan 

S11 - Hungarian regulations generally prescribe stricter deadlines. 
E.g. in case of equities the decision of the GM must contain the start 
date of the payment of dividend. In case of bonds the policy 
conditions must contain the payment date, etc. There is different 
regulation for each kind of securities, there is no general rule for 
announcement deadlines. The Issuer does not inform the CSD 
according to standard 1. After the implementation of standard 1 rules 
will be in line with this standard. 

S13 - There is no central Buyer Protection procedure on the market. 
Implementation of Buyer Protection mechanism by the time of the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

S14 - There is no central Buyer Protection procedure on the market. 
Implementation of Buyer Protection mechanism by the time of the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

S15 - The market practice does not comply with the standard. 
Implementation of Buyer Protection mechanism by the time of the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

S16 - Dividend: Payment Date-5=Record Date 

Interest: Payment Date-2=Record Date 

The General Business Rules of KELER contains the dates above and 
the market practice for listed securities follows the above-mentioned 
rules. The revision of the current payment procedures is in progress 
in line with the implementation of the planned developments. The 
implementation of this standard is planned by December 2025. 

S19 - KELER does not apply such identifier and the issuer provide 
with the identifier. 

S20 - Currently the pre-conditions of information flow are not built out. 
The standard is applied for End Investors with SWIFT connectivity. 

S22a - KELER is not a central paying agent, Issuers may appoint any 
third party as paying agent. This way Payments are not always made 
through KELER. The revision of the current payment procedures is in 
progress in line with the implementation of the planned 
developments. The implementation of this standard is planned by 
December 2025. 

S22b - For listed shares, the payments are not yet done by KELER. 
For other securities, the announcement of the CSD according to the 
standards does not exist, but of course the payment is made in the 
currency published in the announcement of the Issuer published in 
other places. After the implementation of standard 1 and 22a rules 
will be in line with this standard. 

S22c - It is possible to transfer the payment before 12:00, however 
there is no obligation for the Issuer or its paying agent to transfer 
before midday. KELER as paying agents complies with the standard. 
The revision of the current payment procedures is in progress in line 
with the implementation of the planned developments. The 
implementation of this standard is planned by December 2025. 

S22d - According to the current market practice the Issuer transfers 
the correct amount after transferring back the incorrect payment. 
KELER participates in the process only if KELER is appointed as 
paying agent. This standard is planned to be implemented by 
December 2025. 

S23 - There is no obligation for the issuer or the paying agent to 
transfer as early as possible on the Payment Date. The revision of 
the current payment procedures is in progress in line with the 
implementation of the planned developments. The implementation of 
this standard is planned by December 2025. 

IE – Euroclear 
Bank 

S13, S14, 
S22c, S23 

S13, S14 - Only one such event in 2023 The Guaranteed 
Participation date is not yet notified by EB as not received by the 
issuer. A development project is planned to create the required fields 
and automatic derivation when non provided. 

S13, S14 - Q2 2024 
S22c - 2029 
S23 – No plan 

S22c - Cash not always credited before noon as cash needs to be 
received from issuer/registrar and reconciled by EB before EB can 
process the payment. However, Euroclear Bank has started a 
multiyear program which foresees the progressive migration of the 
legacy custody processing to a new Asset Servicing Platform. 
Compliance with corporate action standards is part of the scope of 
this project divided into multiple phases with an end delivery date 
expected around 2029. 

S23 - No event with credit of securities in 2023. The timing of 
payments would depend on when the registrar can deliver securities. 
The payment needs to be automated from the Registrar, to the CSD, 
to next intermediary. 

Corporate Events Compliance Report – Compliance assessment 

95 

 
 
Market 

Gaps 

Status 

Plan 

IS – Nasdaq CSD  S8-S10 

S8-S10 - Unknown by the CSD how well the CSD participants comply 
with the standard. All participants comply to the standard when it 
comes to specific voluntary corporate actions events for example 
Rights issues and dividend payments 

S8-S10 - Not known, to be 
discussed with 
participants. 

IT – Euronext 
Securities Milan 

S4 

S4 - As of today, CSD announcements are sent taking into account 
settled positions only, thus excluding any pending receipt and/or 
delivery that might impact the eligible balance. 

Q1 2026 

LU – 
Clearstream 
Banking 
Luxembourg 

S13, S14, 
S22b, c, 
S23 

All – No plan 

S13, S14 - The key buyer protection dates are not yet notified 
although the CBL is technically ready to transmit this information. 
Both ICSDs agreed on common rules for generating the BP key dates 
for the International market. This process will be fully handled by 
ICSDs, therefore, the question of the implementation is only on the 
ICSDs side and will depend on available technical release. 
Preferably, a common implementation date should be agreed 
between both ICSDs (not expected before end 2024) to be followed 
by an update of the ISMAG standards accordingly. 

S22b - Payments are made in the currency of the new securities 
(while the standards state that payments should be made in the 
original currency). 

S22c - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on the currency, operating time-zone 
of the Agents as well as the timing that the issuers can release the 
payment (i.e. availability of cash). CBL had (with Euroclear Bank) a 
joint call with Common Depositories and Agents to explain the rules 
and the AMI-SeCo monitoring process. Although ICSDs timing 
requirements are to be reinforced in line with the SCoRE CA 
Standards, the dependency on issuers and their agents will remain. 

S23 - This is in line with the timing that is currently defined in the 
International Securities Operational Market Practice Book. However, 
the timing of payments depends on when the issuer's agent can 
deliver the securities. CBL had (with Euroclear Bank) a joint call with 
Common Depositories and Agents to explain the rules and the AMI-
SeCo monitoring process. Although ICSDs timing requirements are to 
be reinforced in line with the SCoRE CA Standards, the dependency 
on issuers and their agents will remain. 

LU - LuxCSD 

S13, S14  S13, S14 - The key buyer protection dates are not yet notified 

S13, S14 - 2025 

MT – Malta Stock 
Exchange 

NO – Euronext 
Securities Oslo 

S2, S8, 
S9, S16, 
S22a, 
S22d 

S1, S2, 
S4-S7, 
S9, S13-
S15, S18, 
S20,-
S22a, 
S22d, 
S23     

although the CSD is technically ready to transmit this information. 
The current proposal is that the CSD calculates such dates as per the 
standards and notify the participants accordingly. The proposal was 
submitted to the market for validation and approved. Developments 
are planned to achieve full compliance with the standard after the 
ECMS go-live, in the course of 2025. 

Compliance gaps maintained following internal plausibility check. 

N/A 

S1 - Legal barrier. The Issuer has no such obligation to inform the 
CSD. Key Dates are not always announced or very late. There is no 
applicable law defining the Issuer to inform specifically the CSD. 

All – Q3 2026 

S2 - Technical barrier. Not all information can be communicated in 
formatted electronic form using standards defined and used by the 
securities industry, such as the ISO standards, irrespective of the 
communication channel used. 

S4 - Technical barrier. Batch solution running EOD and not possible 
to deliver on Pending Transaction in the Underlying Security with the 
Issuer as understood from the event lifecycle processing. 

S5 - Technical barrier. Batch solution running EOD and not possible 
to inform participant who obtains a holding or is subject to a new 
Transaction on the Underlying Security after the announcement until 
the Record Date as understood from the event lifecycle processing. If 
event has an event update, new holdings will be included in this 
updated. 

S6, S9 - Technical barrier. Not all information and events can be 
communicated in formatted electronic form using standards defined 
and used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

S7 - Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. 

Corporate Events Compliance Report – Compliance assessment 

96 

 
 
 
 
Market 

Gaps 

Status 

Plan 

PL - KDPW 

S7, S13-
S15, 
S22d 

S11 - Legal barrier. The Issuer has no such obligation to inform the 
CSD, especially relevant for Bonds. Key Dates are not always 
announced or very late. There is no applicable law defining the Issuer 
to inform specifically the CSD. Technical barrier. Not all information 
can be communicated in formatted electronic form using standards 
defined and used by the securities industry, such as the ISO 
standards, irrespective of the communication channel used. 

S13, S14 - No such function exists in the Norwegian Market. 

S15 - Technical barrier for some cash payment. All Corporate Actions 
payments are paid via national payment infrastructure. 

S18 - Technical barrier. CSD does not use trade date do define 
entitlements. 

S20, S21 - Technical barrier.   

S22a - Technical barrier. All Corporate Actions securities payments 
are paid via write-up of the securities ledger. 

S22d - Technical barrier. Currently not possible to communicate a 
reversal in formatted electronic form using standards defined and 
used by the securities industry, such as the ISO standards, 
irrespective of the communication channel used. Also, all Corporate 
Actions payments are paid via national payment infrastructure. Legal 
Barrier. For Investors, Payments is executed in commercial bank 
money. Therefore, for the vast majority of Investors payments from 
Issuer will be done in commercial bank money. 

S23 - ES-OSL has RD=PD. 

S7, S22d - As per decision of AMI-SeCo NSG PL, the reversals 
processing will not be implemented for voluntary reorganisations. A 
reversal process compliant with the standard cannot be implemented 
currently owing to legal barriers. In the opinion of KDPW, the mere 
fact of an error of an issuer or of KDPW may at most constitute 
grounds for the issuer or KDPW to demand that the person/KDPW 
participant to whom the undue benefit has been paid should return it 
but it does not, in itself, constitute grounds for the issuer or KDPW to 
be able to compulsorily (i.e. against the will of such person) enforce 
such benefit against such person. Furthermore, the risk must also be 
considered that the issuer may not have been in error at all and 
would like to use the reversal to collect the benefit paid through 
KDPW, to which the issuer has no legal title. 

S13, S14 - Manual Buyer Protection Market Practice as well as BP 
Instruction template are in place. Nonetheless, having very limited 
number of real-life scenarios at CSD level, market participants see no 
practical reason to endorse it. Thus, despite being able to, the CSD 
does not provide those dates. 

S15 - In case of securities outturns the PD is the next business day 
after the MD. In case of cash outturns, resulting from securities other 
than treasury bonds, there is a minimum 5-day period between RD 
and PD, due to processes related to withholding of tax. For cash 
outturns, on average there is a 16 business days period between MD 
and PD. Changing the period between Record Date and Payment 
Date requires a change in the Polish law. There are no such plans 
yet. 

S13, S14 - Q4 2026 
S7, S15, S22d – No plan 
No plan 

PT - Euronext 
Securities Porto 

S2, S7, 
S22d 

S2 - The information is communicated electronically through Euronext 
Securities Porto portal or e-mail. The ISO standards are not 
implemented yet. No appetite from the market. 

Q4 2025 

RO – Depozitarul 
Central 

S7, S16-
S21, S23 

S7 - Very few reversals exist in the market. When requested, the 
CSD always announces its participants by email when there is a 
correction and the reason for the same. 

S22d - Very few reversals exist in the market. When requested, the 
CSD makes corrections to the payments. 

As part of the Euronext New Corporate Event Service initiative, the 
compliance deadline is June 2025 for debt instruments (linked to 
ECMS) and November 2025 for other securities. 

S7 - Prior to the processing of a reversal the information is 
communicated by the CSD to the affected parties in a proprietary 
form (email). Voluntary Reorganizations as public offers (e.g. offer to 
existing holders by the issuer to repurchase its own securities, offer 
made to holders by a third party, other than the issuer, to sell their 
securities) are processed as regular trades through Bucharest Stock 
Exchange in accordance with Regulation no. 5/2018 on issuers of 
financial instruments and market operations issued by Romanian 
Financial Supervisory Authority. No plans for compliance can be 
provided as long as the voluntary reorganizations are processed 
through the stock exchange as usual trades and only their settlement 
is processed by the CSD. As next step Depozitarul Central plans to 
discuss the matter with the market participants, Bucharest Stock 
Exchange and FSA in order to search for a common approach. 

No plan 

S7, S16-S21, S23 – No 
plan 

Corporate Events Compliance Report – Compliance assessment 

97 

 
 
Market 

Gaps 

Status 

Plan 

SE – Euroclear 
Sweden 

S2, S3, 
S6, S7, 
S8, S19, 
S20, 
S22a,c,d 

S16- According to Romanian Regulation the offeror/issuer have to 
announce the results of the elections in five business days following 
the market deadline. 

S17-S21, S23 – Currently, in the Romanian market elections are 
processed through the stock exchange, thus the resulting trades are 
settled by the CSD (for more details please refer to the explanation 
provided for Voluntary Reorganisations Standard 7 above). 

S2 - Voluntary reorganisation event information is provided by issuers 
to the CSD via manual means. 

No plan 

S3 - Almost all listed companies provide at least a summary of the 
event narrative in English on their websites. An amendment of the 
CSD rules requiring ""avitext"" in both English and Swedish was 
implemented late 2011. 

S6 - Some intermediaries still use the old, non-ISO, interface. The 
CSD offers an older version of CA information interface. The old 
version contains the same information – the ISO 15022 messages 
are created from that information – but in a different format. CSD 
participants are not required to migrate to ISO 15022 messages and 
as the old version also contains information not provided in ISO 
15022 messages, not all CSD participants want to maintain access to 
both. The CSD's ISO 15022 interface does not cover all events, but 
the "non-covered" events are rare. 

S7, S22d - Reversals are not performed by the CSD due to legal 
reasons, and this has been the case since start of the CSD. In earlier 
years the SE MIG have stated that Standard 7 was complied with 
compliant since Euroclear Sweden, in case a payment would ever be 
reversed, would have sent such an announcement. However, 
following a legal analysis performed by a Government Inquiry, it was 
clarified early 2024 that a reversal of a cash distribution is in breach 
with Swedish property law, which is why the CSD would never 
perform such a reversal. 

S8 - Not all intermediaries can send information on pending 
transactions, only on holdings. 

S19 - Issuers do not use option identifiers. 

S20 - Elections are not sent to the issuer/issuer agent via the CSD. 
CSD participants send aggregated instructions for holdings on CSD 
nominee accounts to the issuer agent, generally as scanned forms 
sent via email. Instructions to such CSD participants are generally in 
formatted electronic form. For holdings on CSD owner accounts, 
investors send their election forms directly to the issuer agent. 

S22a - Payments from issuers in voluntary reorganisations are not 
made via the CSD. 

S22c - Payments from issuers in voluntary reorganisations are not 
made via the CSD. Payments can be made after 12.00 local time. 

SK – CDCP 

All 
standards 

All - Standards in process of implementation 

All – Q1 2026 

Corporate Events Compliance Report – Compliance assessment 

98 

 
 
 
3.3 

Market Claims 

3.3.1 

T2S markets 

Chart 7 
Market Claims – % compliance per market 

Notes: N/A. 

Corporate Events Compliance Report – Compliance assessment 

99 

0%10%20%30%40%50%60%70%80%90%100%AT - OeKBBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - NasdaqES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSHR - SKDDHU - KELERIE - Euroclear BankIT - Euronext Securities MilanLI - SIX SISLT - NasdaqLU - LuxCSDLV - NasdaqMT - Malta Stock ExchangeNL - Euroclear NetherlandsPT - Euronext Securities PortoRO - Depozitarul CentralSI - KDDSK - CDCP 
 
 
Box 9 
Market Claims – Compliance status per Standard 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28 

AT - Oesterreichische 
Kontrollbank 

B 

B 

B 

B 

B 

0%  0%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  B 

B 

B 

B 

B 

BE - Euroclear Bank 

0%  0%  0%  0%  0%  B 

0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

BE - Euroclear Belgium  B 

BE - NBB-SSS 

B 

B 

B 

BG - BNBGSSS 

25%  B 

BG - CDAD 

CH - SIX SIS 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  N/A  B 

B 

B 

B 

B 

B 

B  N/A  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  50%  N/A  B  25%  25%  N/A  25%  N/A  B  50%  25%  25%  25%  25%  N/A  N/A  50%  25%  25%  N/A  25%  25%  25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  50%  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 

DE - Clearstream 
Banking Frankfurt 

DK - Euronext 
Securities Copenhagen 

B 

B 

B 

B 

B 

B 

0%  0%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0%  0%  0%  0%  B 

B 

0%  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 

EE - Nasdaq CSD 

ES - Iberclear 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

FI - Euroclear Finland 

50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50% 

FR - Euroclear France 

GR - BOGS 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B  N/A  B 

B 

B 

B 

B 

B 

B 

B 

B  N/A  B  N/A  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 

HR - SKDD 

50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50%  50% 

HU - KELER 

25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  B  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  B 

IE - Euroclear Bank 

0%  0%  0%  0%  0%  B 

0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

IT - Euronext Securities 
Milan 

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 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - LuxCSD 

LV - Nasdaq CSD 

MT - Malta Stock 
Exchange 

NL - Euroclear 
Nederland 

PT - Euronext 
Securities Porto 

RO - Depozitarul 
Central 

SI - KDD 

SK - CDCP 

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 

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 

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 

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 

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 

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 

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 

B 

B 

B 

B 

B 

B 

B 

Notes: Standards 7, 11 and 13 are not applicable to fixed income securities. 

Corporate Events Compliance Report – Compliance assessment 

100 

 
 
  
Table 8 
Market Claims (T2S Markets) - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the T2S 
Market Claims standards. Markets/CSDs not listed below have been assessed as fully 
compliant. 

Market 

Gaps 

Status 

AT – 
Oesterreichische 
Kontrollbank 

S6, S7, 
S23 

S6, S7: Since T2S Go Live Opt-out indicator is matched in T2S but is 
being disregarded by Market Claim detection process due to common 
understanding in Austrian Market concerning mitigating actions for tax 
fraud risk. 

Plan 

No plan 

BE – Euroclear 
Bank 

S1-S5, 
S7-S28 

S23 - A user friendly facility has been implemented in form of an 
optional flag on the securities account level, which can be set 
separately for cash and securities side, indicating whether a market 
claim generated by the CSD should be automatically put on hold. 

In June 2025, EB will join the T2S community in the frame of ECMS 
and its activity will be strictly limited to collateral monetary policy 
operations where counterparties will always 'opt-out' (NOMC 
indicator) so this situation will not happen. However, the compliance 
rate will grow when Euroclear Bank will deliver the intra-CSD phase 
from its Central Bank Money project, where scope will be wider than 
MPO, which require additional developments. 

T2S CA Standards will become relevant once Euroclear Bank 
enables intra-CSD settlement in T2S. Euroclear Bank confirmed its 
plans to reach full compliance with the T2S CA standards on market 
claims, transformations, and buyer protection by the start of the intra-
CSD settlement phase, currently planned for January 2026. 

Q1 2026 

BG – BNBGSSS 

S1, S6, 
S9, S10, 
S12, S15, 
S16-S19, 
S22-S24, 
S26-S28 

All standards - BNBGSSS's activities with regard to market claims are 
related to interest payment only. Changes in the market practices are 
discussed with BNBGSSS participants and in this regard, regulatory 
amendments are currently being prepared. BNBGSSS intends to 
conduct internal testing in the first half of 2025 and synchronize 
external testing with the testing of SCoRE CA Standard 15 ISO 20022 
messages for corporate actions and the remaining Standards for CA 
processing. 

All standards – Q1 2026 

BG – CD AD 

S14 

Q2 2025 

S14 - The current market practice mirrors the national legislation and 
defines different withholding rates to be applied to Distributions, 
depending on the type of investor (natural person or legal entity, incl. 
EU members or third countries). For pending transactions, the Issuer 
transfers to CD AD the amount due (after taxation) at the EOB on the 
RD as per the List of Shareholders. CD AD has no legal right to make 
changes to the List. Thus, the amount subject to Distribution may 
differ from the MC one. Currently there is no case for MC, where the 
tax differs in regard to the investors type and next procedure of 
equalising the proper tax due. The corresponding amendments in the 
law are expected in the second quarter of 2025. 

DE – 
Clearstream 
Banking 
Frankfurt 

S7, S8, 
S19-S22, 
S25 

S7 - There are some conflicts by implementing the “CUM” flag with 
the German laws e.g. in respect of “manufactured dividends “ when 
non-entitled transactions can be flagged as entitled transaction and 
tax vouchers will be created.  

No plan 

S8, S19-S22, S25 - Market claims are detected on basis of pending, 
matched trades on record date (MT564 REPE ACLA); Market and 
Reverse Claims are generated at CBF on basis of settled 
transactions. Claims on open instructions caused several problems 
(late trades, Rec-Date) when this processing was standard in the 
German market. The Market CA Standards and the T2S CA 
Standards apply on „irrevocable transactions“ which would not be 
fulfilled by „matched transactions“ solely as said as definition/example 
of irrevocableness. There the underlying OTC transaction could be 
set „on hold“ (without settlement) in T2S while the MC settles. Based 
on that fact German MPC don’t treated a matched underlying 
transaction as irrevocable. 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 e.g. the case in T2S by a handful of transactions on non-
German securities. Open question regarding transfer of ownership 
and tax liability. The Zuflussprinzip from tax point of view isn't in time 
with processing of MC when underlying transaction matched. 

Corporate Events Compliance Report – Compliance assessment 

101 

 
 
Plan 

Q4 2029 

Q1 2025 

All – December 2025 

Market 

Gaps 

Status 

FI – Euroclear 
Finland 

All 
standards 

HR - SKDD 

All 
standards 

HU - KELER 

S1-S10, 
S12-S27 

A mechanism for market claims is implemented in the CSD system 
and market claims are detected for security distributions and for other 
cash distributions than dividend payments. Dividends are paid in 
CoBM outside the CSD system and hence excluded from market 
claim detection. Dividend payment is the most common cash 
distribution event in Finland and would cause the majority of market 
claim transactions. The number of market claims in other events is 
minor. Market claims will be implemented for dividend payments once 
the proceeds are paid in CeBM. Full compliance with T2S Corporate 
Action Standards for Market Claims still requires further work and 
significant delay is possible before full implementation can be 
achieved. Currently, the ultimate deadline for full compliance with the 
market claims standards is foreseen for December 2029, but with a 
stepwise implementation to cover the remaining gaps. Euroclear 
Finland plans to develop a precise roadmap after the successful 
migration to ECMS. 

According to its initial planning, SKDD aimed at reaching full 
compliance with the T2S CA Standards on market claims and 
transformations when joining T2S, with a testing phase starting in Q2-
2023 and lasting until implementation on 11 September 2023. 
However, the implementation of the standard progressed at a pace 
slower than what SKDD had expected, and compliance gaps remain 
even as of SKDD’s migration to T2S. As a result, SKDD moved the 
date for full compliance to 2nd January 2025. It was decided to split 
the work into two phases where part of the standards was completed 
with the Go live of T2S and the other part is foreseen to be completed 
with the Go Live of ECMS Project. This approach has been taken to 
manage the operational and technical challenges more effectively 
and to ensure that the work can proceed in a more controlled and 
manageable manner. However, as ECMS is postponed again it is 
decided to implement Market Claims and Transformations from 
beginning of 2025 as technical solution is developed. 

S1-S6, S9, S10, S12, S13, S15-S19, S23, S24, S26, S27 - For 
equities, KELER already implemented the central corporate action 
database due to SRD II requirements. For bonds, that is to be 
implemented by December 2024. For bonds there are no legal 
constraints so for fixed income the CASG standards and the new 
practices have been implemented by February 2017 for EUR DVP 
transactions. 3 laws (Civil Code, Capital Market Act, Act on the Rules 
of Taxation) need to be amended in Hungary to fully comply with the 
Market CA Standards/T2S CA Standards for equities. All necessary 
legal amendments have been elaborated and there are still ongoing 
discussions with regard to the implementation date of the renewed 
legal background. Implementation of T2S Corporate Action Standards 
is planned by December 2025. 

S7 - Due to KELER’s GUI solution as of today IOCs have to indicate 
their intention to participate in MC processing separately from the 
settlement instruction. The “opt-out” indicator is an element in the 
instruction that will be subject of matching and will be considered in 
the claim detection as well. The new software to go live in December 
2021 will implement the opt-out indicator. The standard shall be fully 
implemented by December 2025. 

S8 - The “ex-cum” indicator will be a new element in the instruction 
that will be subject of matching and will be considered in the claim 
detection as well. The development to go live in December 2021 will 
implement the opt-out indicator. The standard shall be fully 
implemented by December 2025. 

S14 - As per current market practice the tax status of the beneficial 
owners does have a direct effect on the amounts to be transferred i.e. 
proper tax rates can be applied as part of the relief at source process 
to avoid a tax refund procedure. 

S20, S21 - There is no market practice to amend instructions (at 
present cancellation and re-instruction is necessary). 

S22 - KELER participants are allowed to cancel instructions 
depending on the type and status of the instructions at present. In 
addition, unilateral cancellations are allowed prior and post matching 
as well.   

S25 - Partial settlement shall be introduced to the Hungarian market 
in line with the renewal of KELER’s CSD system by December 2021 
due to the Settlement Discipline requirements. Currently there is no 
automated market claim service in KELER. 

Corporate Events Compliance Report – Compliance assessment 

102 

 
 
Market 

Gaps 

Status 

IE – Euroclear 
Bank 

S1-S5, 
S7-S28 

In April 2024, EB will join the T2S community in the frame of ECMS 
and its activity will be strictly limited to collateral monetary policy 
operations where counterparties will always 'opt-out' (NOMC 
indicator) so this situation will not happen. However, the compliance 
rate will grow when Euroclear Bank will deliver the intra-CSD phase 
from its Central Bank Money project, where scope will be wider than 
MPO, which require additional developments. 

T2S CA Standards will become relevant once Euroclear Bank 
enables intra-CSD settlement in T2S. Euroclear Bank confirmed its 
plans to reach full compliance with the T2S CA standards on market 
claims, transformations, and buyer protection by the start of the intra-
CSD settlement phase, currently planned for January 2026. 

Plan 

Q1 2026 

3.3.2 

Non-T2S markets 

Chart 8 
Market Claims – % compliance per market 

Notes: N/A. 

Corporate Events Compliance Report – Compliance assessment 

103 

0%10%20%30%40%50%60%70%80%90%100%BE - Euroclear BankCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDGR - ATHEXCSDIS -Nasdaq CSDLU - Clearstream Banking LuxembourgNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4RO - SaFIRSE - Euroclear SwedenUK - Euroclear UK & International 
 
 
 
Table 9 
Market Claims – Compliance status per Standard 

BE - Euroclear Bank 

CY - Cyprus Stock Exchange 

CZ - CSD Prague 

CZ - SKD 

GR - ATHEXCSD 

IE - Euroclear Bank 

IS - Nasdaq CSD 

LU - Clearstream Banking 
Luxembourg 

Creation 

Processing 

1.a 

1.b 

2 

3 

4 

75% 

75% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

75% 

75% 

0% 

0% 

0% 

0% 

5 

0% 

0% 

0% 

6 

0% 

0% 

0% 

7 

0% 

0% 

0% 

Reporting 

8 

9 

75% 

75% 

0% 

0% 

0% 

0% 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

0% 

0% 

B 

B 

B 

B 

0% 

0% 

B 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

B 

B 

75% 

25% 

50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

75% 

75% 

75% 

75% 

75% 

0% 

75% 

75% 

75% 

NO - Euronext Securities Oslo 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

PL - KDPW 

B 

B 

25% 

B 

50% 

0% 

0% 

0% 

75% 

75% 

PL - SKARBNET4 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

RO - SaFIR 

SE - Euroclear Sweden 

N/A 

N/A 

50% 

50% 

B 

B 

75% 

75% 

75% 

75% 

75% 

75% 

75% 

25% 

B 

B 

B 

75% 

25% 

50% 

UK - Euroclear UK & International 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Notes: Market Claims are outside the scope of SKARBNET4 activities, as only Treasury-bills and NBP-bills are registered in 
SKARBNET4. Both of them are short term discount papers and the only Corporate Action which is carried out on these papers is final 
redemption. 

Corporate Events Compliance Report – Compliance assessment 

104 

 
 
 
  
Table 10 
Market Claims (Non-T2S Markets) - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the Market 
Claims standards. Markets/CSDs not listed below have been assessed as fully compliant. 

Plan 

All – Q4 2029 

Market 

Gaps 

Status 

BE – Euroclear 
Bank 

All 
standards 

S1a-S2 - The market claims settle in the form of a "coupon 
compensation", meaning they settle together with the underlying 
settlement instruction. EB processes market claims from the seller to 
the buyer, if the intended settlement date is on or prior to the last 
inclusive date of the interest period and the actual settlement date is 
after the Record Date, for the internal against payment instructions.   

There is no coupon compensation nor market claim on bridge 
instructions. Discussed between two ICSDs in Q2 2023. The 
introduction of the market claims for the Bridge transactions would 
require heavy developments at ICSDs side as impacting a common 
interface and should be planned as part of the relevant project. 
Volumes of the impacted transactions is very low; therefore, such 
developments are not critical and are agreed to be parked until end 
2024.   

S3, S4, S8, S9 - In recognition of the fact that market claims and 
transformations are not executed at all for cross-CSD transactions 
taking place between Euroclear Bank and Clearstream Banking 
Luxembourg via the so-called ‘Bridge’, the CEG agreed to limit all the 
“Market Claims” and “Transformations” standards compliance rates of 
Euroclear Bank and Clearstream Banking Luxembourg to a maximum 
of 75%. 

S5 - For coupon compensation (market claim on eurobonds), we 
settle it simultaneously when the underlying transaction settles (value 
date is aligned with expected payment date or the settlement date of 
the transaction if it settles later than the payment date). Euroclear 
Bank has started a multi-year program which foresees the 
progressive migration of the legacy custody processing to a new 
Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

S6 - Settlement is dependent on the underlying transaction. Euroclear 
Bank has started a multi-year program which foresees the 
progressive migration of the legacy custody processing to a new 
Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

S7 - Taxable securities are not eligible to the coupon compensation 
service Euroclear Bank has started a multi-year program which 
foresees the progressive migration of the legacy custody processing 
to a new Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

Euroclear Bank has started a multi-year program which foresees the 
progressive migration of the legacy custody processing to a new 
Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

CY – CSE 

All 
standards 

All - Technical and regulatory changes for the implementation of this 
standard are currently assessed 

No plan 

CZ – CSD Prague  All 

standards 

All - The claims, transformations and buyer protections on the Czech 
market are processed in a different way and the standard is not 
implemented on the Czech capital market. 

All standards – No plan 

CZ - SKD 

S9 

Following CEG assessment 

GR - ATHEXCSD  All 

standards 

All - Corporate actions are only affected on settled positions as of the 
record date. Market claims are expected to go live by the end of 
2025. The analysis with ATHEXCSD’s tax advisor had been 
completed and a solution has been identified. As next step, 
ATHEXCSD will initiate a consultation with its tax authority and a 
market consultation will be launched thereafter. 

No plan 

All – Q4 2025 

Corporate Events Compliance Report – Compliance assessment 

105 

 
 
Plan 

All – Q4 2029 

All - No plan 

Market 

Gaps 

Status 

IE – Euroclear 
Bank 

All 
standards 

LU – 
Clearstream 
Banking 
Luxembourg 

All 
standards 

S2 - The market claims settle in the form of a "coupon 
compensation", meaning they settle together with the underlying 
settlement instruction. EB processes market claims from the seller to 
the buyer, if the intended settlement date is on or prior to the last 
inclusive date of the interest period and the actual settlement date is 
after the Record Date, for the internal against payment instructions. 
There is no coupon compensation nor market claim on bridge 
instructions Euroclear Bank has started a multiyear program which 
foresees the progressive migration of the legacy custody processing 
to a new Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

S4 - Today, market claims relating to cash distributions with currency 
options and distributions with both cash and security options are 
generated in EUR, provided a EUR option is offered by the issuer. If 
not, the market claim is generated in the default currency of the 
distribution. Euroclear Bank has started a multi-year program which 
foresees the migration of the legacy custody processing to a new 
Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

S5 - Today, cash market claims are booked as of payment date +1 
BD during the overnight batch process with value date equal to the 
market claim settlement date. Euroclear Bank has started a multi-
year program which foresees the migration of the legacy custody 
processing to a new Asset Servicing Platform. Compliance with 
corporate action standards is part of the scope of this project divided 
into multiple phases with an end delivery date expected around 2029. 

S6 - Euroclear Bank has started a multi-year program which foresees 
the migration of the legacy custody processing to a new Asset 
Servicing Platform. Compliance with corporate action standards is 
part of the scope of this project divided into multiple phases with an 
end delivery date expected around 2029. 

S1a, b, S3, S7, S8, S9 – Revised downwards following internal 
assessment to reflect the absence of compensation applied for the 
Bridge transactions. 

S1.a, b - Implemented for transactions between Clearstream 
participants but no compensation applied for the Bridge transactions 
between Clearstream and Euroclear. Discussed between two ICSDs 
in Q2 2023. The introduction of the market claims for the Bridge 
transactions would require heavy developments at ICSDs side as 
impacting a common interface and should be planned as part of the 
relevant project. Volumes of the impacted transactions is very low 
therefore such developments are not critical and are agreed to be 
parked until end 2024.   

In recognition of the fact that market claims and transformations are 
not executed at all for cross-CSD transactions taking place between 
Euroclear Bank and Clearstream Banking Luxembourg via the so-
called ‘Bridge’, the CEG agreed in 2023 to limit all the “Market 
Claims” and “Transformations” standards compliance rates of 
Euroclear Bank and Clearstream Banking Luxembourg to a maximum 
of 75%. 

S6 - The market claims are generated upon i) settlement of the 
underlying transaction, ii) payment of the underlying corporate action. 

S2-5, S7-S9 – Revised downwards following internal assessment to 
reflect the absence of compensation applied for the Bridge 
transactions. 

NO – Euronext 
Securities Oslo 

All 
standards 

S1, S3 - Technical barrier. Entitlement calculation do not use trade 
date. 

Q3 2026 

S2, S5 - Technical barrier. All CA securities payments are paid via 
writeup of the securities ledger therefore the there is no settlement 
function exist.   

S4, S6-S9 - Technical barrier. Entitlement calculation do not use trade 
date. All CA securities payments are paid via write-up of the securities 
ledger therefore the there is no settlement function to move securities 
also cash payments are executed in commercial bank money. 

PL – KDPW 

S2, S4-S9  S2 - Settlement instructions allow to indicate whether the trade is "ex" 

All - Q2 2027 

or "cum", however, these are not catered for by the CSD which is 
responsible for generating market claims. 

S4 - Standard complied with for cash outturns. In case of securities 
outturns there is a cash compensation. 

S5, S6 - The ISD of the market claim is settlement of the underlying 
transaction or Payment Date/Posting Date, whichever occurs later. 
Legal barrier, Securities Trading Act, Art. 7 (2). 

Corporate Events Compliance Report – Compliance assessment 

106 

 
 
Market 

Gaps 

Status 

Plan 

S7 - Market claims are paid on a gross basis. 

S8 - Market claims are reported as such with reference to the 
underlying transaction. However, there is no reference to the 
distribution event. 

S9 - The reporting is in formatted electronic form; however it is 
proprietary format based on ISO 

RO - SaFIR 

S3-S9 

S3-S9 - Ongoing development and implementation  

All – Q4 2025  

SE – Euroclear 
Sweden 

S1a,b, 
S3, S7-S9 

S1.a, b - The CSD provides a list of claims for cash dividends, but 
offers no other support. The CSD participants bilaterally agree and 
create market claims. The CCPs, or the GCMs upon information from 
the CCP, create market claims. 

No plan 

S3 - The CCPs, or the GCMs upon information from the CCP, create 
market claims after end of record date. The CSD members create 
market claims after settlement of the underlying transaction. 

S7 - The CSD distributes gross to all Swedish custodians. All cash 
market claims are paid gross (the respective withholding agent will 
debit the tax).    For cash market claims where the dividend was paid 
in EUR in the CSD, the market claim will be paid in gross in EUR 
except for transactions where the CSD is the withholding agent. The 
CSD may use the current FX rate in the FX of the withheld tax 
amount, which may result in a discrepancy with the gross amount. 

S8 - Market claims are not created, and thus not reported, by the 
CSD. CCPs do not report transactions as such but do provide 
information regarding market claims. Intermediaries report, upon 
settlement only, according to the standard ISO format. 

S9 - The CSD is not compliant. The CCPs are not compliant. The 
intermediaries are compliant. 

3.4 

Transformations 

3.4.1 

T2S markets 

Chart 9 
Transformations – % compliance per market 

Notes: N/A. 

Corporate Events Compliance Report – Compliance assessment 

107 

0%10%20%30%40%50%60%70%80%90%100%AT - OeKBBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - NasdaqES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSHR - SKDDHU - KELERIE - Euroclear BankIT - Euronext Securities MilanLI - SIX SISLT - NasdaqLU - LuxCSDLV - NasdaqMT - Malta Stock ExchangeNL - Euroclear NetherlandsPT - Euronext Securities PortoRO - Depozitarul CentralSI - KDDSK - CDCP 
 
 
 
Table 11 
Transformations – Compliance status per Standard 

AT - Oesterreichische 
Kontrollbank 

1 

B 

BE - Euroclear Bank 

50% 

BE - Euroclear Belgium 

BE - NBB-SSS 

B 

B 

2 

B 

B 

B 

B 

3 

B 

B 

B 

B 

4 

B 

5 

B 

6 

B 

7 

B 

8 

B 

9 

B 

10 

11 

12 

13 

B 

B 

B 

B 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

N/A 

B 

B 

B 

B 

BG - BNBGSSS 

0% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

0% 

25% 

0% 

25% 

25% 

BG – CD AD 

CH - SIX SIS 

DE - Clearstream Banking 
Frankfurt 

DK - Euronext Securities 
Copenhagen 

EE - Nasdaq CSD 

ES - Iberclear 

FI - Euroclear Finland 

FR - Euroclear France 

GR - BOGS 

HR - SKDD 

HU - KELER 

IE - Euroclear Bank 

IT - Euronext Securities 
Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - LuxCSD 

LV - Nasdaq CSD 

MT - Malta Stock 
Exchange 

NL - Euroclear Nederland 

PT - Euronext Securities 
Porto 

RO - Depozitarul Central 

SI - KDD 

SK - CDCP 

Notes N/A. 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

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 

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 

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 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

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 

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 

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 

Corporate Events Compliance Report – Compliance assessment 

108 

 
 
  
Table 12 
Transformations (T2S Markets) - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the T2S 
Transformations standards. Markets/CSDs not listed below have been assessed as fully 
compliant. 

Market 

Gaps 

Status 

BE – Euroclear 
Bank 

S1, S4-S13 

BG – BNBGSSS 

S1-S4, S10, 
S11 

In June 2025, EB will join the T2S community in the frame of ECMS and 
its activity will be strictly limited to collateral monetary policy operations 
where counterparties will always 'opt-out' (NOMC indicator) so this 
situation will not happen. However, the compliance rate will grow when 
Euroclear Bank will deliver the intra-CSD phase from its Central Bank 
Money project, where scope will be wider than MPO, which require 
additional developments. Euroclear Bank as T2S CSD will detect and 
manage the cancellation of the settlement underlying instruction. 

T2S CA Standards will become relevant once Euroclear Bank enables 
intra-CSD settlement in T2S. Euroclear Bank confirmed its plans to 
reach full compliance with the T2S CA Standards on market claims, 
transformations, and buyer protection by the start of the intra-CSD 
settlement phase, currently planned for January 2026. 

All standards - BNBGSSS's activities with regard to transformations are 
related to redemptions only. Changes in the market practices are 
discussed with BNBGSSS participants and in this regard, regulatory 
amendments are currently being prepared. BNBGSSS intends to 
conduct internal testing in the first half of 2025 and synchronize external 
testing with the testing of SCoRE CA Standard 15 ISO 20022 messages 
for corporate actions and the remaining Standards for CA processing. 

Plan 

Q1 2026 

All – Q1 2026 

CH – SIX SIS 

S2 

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. There is currently no 
implementation plan. 

No plan 

All standards – No 
plan 

Q1 2025 

CZ – SKD 

All standards 

Following CEG assessment. 

HR - SKDD 

All standards  According to its initial planning, SKDD aimed at reaching full compliance 
with the T2S CA Standards on market claims and transformations when 
joining T2S, with a testing phase starting in Q2-2023 and lasting until 
implementation on 11 September 2023. However, the implementation of 
the standard progressed at a pace slower than what SKDD had 
expected, and compliance gaps remain even as of SKDD’s migration to 
T2S. As a result, SKDD moved the date for full compliance to 2nd 
January 2025. It was decided to split the work into two phases where 
part of the standards was completed with the Go live of T2S and the 
other part is foreseen to be completed with the Go Live of ECMS 
Project. This approach has been taken to manage the operational and 
technical challenges more effectively and to ensure that the work can 
proceed in a more controlled and manageable manner. However, as 
ECMS is postponed again it is decided to implement Market Claims and 
Transformations from beginning of 2025 as technical solution is 
developed. 

HU – KELER 

S3  

Opt-out of instructions from the standard transformation is not applied 
for the time being. 

December 2025 

IE – Euroclear 
Bank 

S1, S4-S11 

Q1 2026 

In April 2024, EB will join the T2S community in the frame of ECMS and 
its activity will be strictly limited to collateral monetary policy operations 
where counterparties will always 'opt-out' (NOMC indicator) so this 
situation will not happen. However, the compliance rate will grow when 
Euroclear Bank will deliver the intra-CSD phase from its Central Bank 
Money project, where scope will be wider than MPO, which require 
additional developments. Euroclear Bank as T2S CSD will detect and 
manage the cancellation of the settlement underlying instruction. 

T2S CA Standards will become relevant once Euroclear Bank enables 
intra-CSD settlement in T2S. Euroclear Bank confirmed its plans to 
reach full compliance with the T2S CA standards on market claims, 
transformations, and buyer protection by the start of the intra-CSD 
settlement phase, currently planned for January 2026. 

LI – SIX SIS 

S2 

Liechtenstein 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 
CSD (SIX Settlement System “SECOM”) with a disproportionality in 
terms of costs versus current number of affected transactions. 

There is currently 
no implementation 
plan. 

Corporate Events Compliance Report – Compliance assessment 

109 

 
 
 
3.4.2 

Non-T2S markets 

Chart 10 
Transformations – % compliance per market 

Notes: N/A. 

Table 13 
Transformations – Compliance status per Standards 

Creation 

Processing 

Reporting 

1 

2 

3 

4 

5 

6 

7 

8 

9.a 

9.b 

10 

11 

BE - Euroclear Bank 

25% 

25% 

25% 

25% 

25% 

25% 

0% 

0% 

0% 

0% 

25% 

25% 

CY - Cyprus Stock Exchange 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

CZ - CSD Prague 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

CZ - SKD 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

GR - ATHEXCSD 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

IE - Euroclear Bank 

25% 

25% 

0% 

25% 

25% 

25% 

0% 

0% 

0% 

0% 

25% 

25% 

IS - Nasdaq CSD 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

LU - Clearstream Banking 
Luxembourg 

75% 

75% 

75% 

75% 

75% 

75% 

75% 

75% 

75% 

75% 

75% 

75% 

NO - Euronext Securities Oslo 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

25% 

PL - KDPW 

B 

25% 

25% 

50% 

0% 

50% 

50% 

0% 

0% 

0% 

0% 

0% 

PL - SKARBNET4 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

RO - SaFIR 

B 

B 

50% 

75% 

75% 

75% 

75%  N/A 

N/A 

N/A 

B 

B 

SE - Euroclear Sweden 

25% 

25% 

0% 

25% 

25% 

25% 

25% 

0% 

25% 

B 

0% 

0% 

UK - Euroclear UK & International 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Corporate Events Compliance Report – Compliance assessment 

110 

0%10%20%30%40%50%60%70%80%90%100%BE - Euroclear BankCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDGR - ATHEXCSDIS -Nasdaq CSDLU - Clearstream Banking LuxembourgNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4RO - SaFIRSE - Euroclear SwedenUK - Euroclear UK & International 
 
 
  
 
Table 14 
Transformations (Non-T2S Markets) - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the 
Transformations standards. Markets/CSDs not listed below have been assessed as fully 
compliant. 

Market 

Gaps 

Status 

BE – Euroclear 
Bank 

All 
standards 

S1-S6, S10, S11 - Today Euroclear Bank generates transformations 
on mandatory reorganisations in securities without options with a ratio 
that is a whole integer. Euroclear Bank has started a multi-year 
program which foresees the migration of the legacy custody 
processing to a new Asset Servicing Platform. Compliance with 
corporate action standards is part of the scope of this project divided 
into multiple phases with an end delivery date expected around 2029. 

S7-S9b - Euroclear Bank has started a multi-year program which 
foresees the migration of the legacy custody processing to a new 
Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

Plan 

All – Q4 2029 

CY – CSE 

All 
standards 

All - Technical and regulatory changes for the implementation of this 
standard are currently assessed 

No plan 

CZ – CSD Prague  All 

CZ - SKD 

standards 

All 
standards 

GR – ATHEXCSD  All 

standards 

IE – Euroclear 
Bank 

All 
standards 

LU – 
Clearstream 
Banking 
Luxembourg 

All 
standards 

NO – Euronext 
Securities Oslo 

All 
standards 

All - The claims, transformations and buyer protections on the Czech 
market are processed in a different way and the standard is not 
implemented on the Czech capital market. 

All standards - No plan 

Information to be provided in next year’s monitoring exercise. 

N/A 

All - Corporate actions are only affected on settled positions as of 
record date. Implementation is currently in progress and 
Transformations are on track to go live in December 2024. 
ATHEXCSD are currently testing the corresponding functionality with 
its participants and no significant issues have been identified. 

All – Q4 2024 

All – Q4 2029 

All – No plan 

S1-S6, S10, S11 - Today Euroclear Bank generates transformations 
on mandatory reorganisations in securities without options with a ratio 
that is a whole integer. Euroclear Bank has started a multi-year 
program which foresees the migration of the legacy custody 
processing to a new Asset Servicing Platform. Compliance with 
corporate action standards is part of the scope of this project divided 
into multiple phases with an end delivery date expected around 2029. 

S7-S9b - Euroclear Bank has started a multi-year program which 
foresees the migration of the legacy custody processing to a new 
Asset Servicing Platform. Compliance with corporate action 
standards is part of the scope of this project divided into multiple 
phases with an end delivery date expected around 2029. 

S1, S2 - Implemented for transactions between Clearstream 
participants but no compensation applied for the Bridge transactions 
between Clearstream and Euroclear. Discussed between two ICSDs 
in Q2 2023. The introduction of the re-instructions for the Bridge 
transactions would require heavy developments at ICSDs side as 
impacting a common interface and should be planned as part of the 
relevant project. Volumes of the impacted transactions is very low, 
therefore such developments are not critical and are agreed to be 
parked until end 2024. 

In recognition of the fact that market claims and transformations are 
not executed at all for cross-CSD transactions taking place between 
Euroclear Bank and Clearstream Banking Luxembourg via the so-
called ‘Bridge’, the CEG agreed to limit all the “Market Claims” and 
“Transformations” standards compliance rates of Euroclear Bank and 
Clearstream Banking Luxembourg to a maximum of 75%. 

S1 - Technical barrier. Entitlement calculation do not use trade date. 

Q3 2026 

S2, S3, S6, S7 - Technical barrier. All CA securities payments are 
paid via writeup of the securities ledger therefore the there is no 
settlement function exist.   

S4, S5, S8, S9a, S10, S11 - Technical barrier. Entitlement calculation 
do not use trade date. All CA securities payments are paid via write-
up of the securities ledger therefore the there is no settlement 
function to move securities also cash payments is executed in 
commercial bank money. As such we cannot utilise industry 
standards 

S9b - As there is no transformation process, the CCP may perform 
transformation if they so choose to. 

Corporate Events Compliance Report – Compliance assessment 

111 

 
 
Plan 

All - Q2 2027 

Q4 2025 

No plan 

Market 

Gaps 

Status 

PL – KDPW 

S2-S11 

S2 - There is no cancellation of matched instructions. Matched 
instructions are modified to reflect the transformation in accordance 
with the terms of the Reorganisation. 

S3 - Settlement instructions allow for "opt-out", however, this not 
catered for by the CSD which is responsible for generating 
transformations. 

S4 - Standard complied with in case of securities outturns only.   

S5 – No feedback provided 

S6, S7 - There are no replacement transactions. Matched instructions 
are modified to reflect the transformation. 

S8 - There are no replacement transactions. 

S9a-S11 - No feedback provided 

RO - SaFIR 

S3-S7 

Ongoing development and implementation. 

SE - Euroclear 
Sweden 

S1-S9.a, 
S10, S11 

S1 - No CSD support exists for transformations. The CCPs, or the 
GCMs upon information from the CCP, will transform at least their 
own instructions. Intermediaries do not transform; clients are advised 
to cancel and reinstruct. 

S2, S4, S6, S7 - The CSD is not compliant. The CCPs are compliant, 
at least for their own instructions. 

S3 - The CSD does not provide this since there is no transformation 
support. Opt-out is N/A for instructions against CCPs. 

S5 - No CSD support exists for transformations. Instructions in the old 
ISIN are not allowed by the CSD after pay date. 

S8 - No CSD support exists for transformations. Not applicable to 
CCPs as these kinds of securities are not centrally cleared in the 
Swedish market. Intermediaries currently perform this (manually and 
outside the CSD system). 

S9.a - This is done, but not by the CSD. 

S10, S11 - Transformation is not supported, and thus not reported, by 
the CSD. CCPs do not report transactions as such but do provide 
information regarding transformation. Intermediaries do not perform 
transformation, and thus do not perform reporting. 

Corporate Events Compliance Report – Compliance assessment 

112 

 
 
 
3.5 

Buyer Protection 

3.5.1 

T2S markets 

Chart 11 
Buyer Protection – % compliance per market 

Notes: N/A. 

Corporate Events Compliance Report – Compliance assessment 

113 

0%10%20%30%40%50%60%70%80%90%100%AT - OeKBBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - NasdaqES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSHR - SKDDHU - KELERIE - Euroclear BankIT - Euronext Securities MilanLI - SIX SISLT - NasdaqLU - LuxCSDLV - NasdaqMT - Malta Stock ExchangeNL - Euroclear NetherlandsPT - Euronext Securities PortoRO - Depozitarul CentralSI - KDDSK - CDCP 
 
 
Table 15 
Buyer Protection – Compliance status per Standard 

AT - Oesterreichische 
Kontrollbank 

1 

B 

2 

B 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

BE - Euroclear Bank 

0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

BE - Euroclear 
Belgium 

BE - NBB-SSS 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

BG – BNBGSSS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

BG – CD AD 

CH - SIX SIS 

DE - Clearstream 
Banking Frankfurt 

DK - Euronext 
Securities 
Copenhagen 

EE - Nasdaq CSD 

ES - Iberclear 

FI - Euroclear 
Finland 

FR - Euroclear 
France 

GR - BOGS 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  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 

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 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

HR - SKDD 

0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

HU - KELER 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

IE - Euroclear Bank  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0%  0% 

IT - Euronext 
Securities Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

LU - LuxCSD 

25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25%  25% 

LV - Nasdaq CSD 

MT - Malta Stock 
Exchange 

NL - Euroclear 
Nederland 

PT - Euronext 
Securities Porto 

RO - Depozitarul 
Central 

SI - KDD 

SK - CDCP 

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 

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 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

Notes: Elective corporate actions are outside the scope of BNBGSSS’s activities. CD AD exercises Manual Buyer Protection 
procedures. 

Corporate Events Compliance Report – Compliance assessment 

114 

 
 
 
Table 16 
Buyer Protection (T2S Markets) - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the T2S 
Buyer Protection standards. Markets/CSDs not listed below have been assessed as fully 
compliant. 

Plan 

Q1 2026 

No plan 

Q4 2024 

Q2 2025 

Q1 2026 

All - 2025 

Market 

Gaps 

Status 

BE – Euroclear 
Bank 

All 
standards 

In June 2025, EB will join the T2S community in the frame of ECMS 
and its activity will be strictly limited to collateral monetary policy 
operations where counterparties will always 'opt-out' (NOMC 
indicator) so this situation will not happen. However, the compliance 
rate will grow when Euroclear Bank will deliver the intra-CSD phase 
from its Central Bank Money project, where scope will be wider than 
MPO, which require additional developments. 

T2S CA Standards will become relevant once Euroclear Bank 
enables intra-CSD settlement in T2S. Euroclear Bank confirmed its 
plans to reach full compliance with the T2S CA Standards on market 
claims, transformations, and buyer by the start of the intra-CSD 
settlement phase, currently planned for January 2026. 

BE – Euroclear 
Belgium 

BG – CD AD 

S9 

S8 

Buyer protection is not guaranteed on rights in case of capital 
increase events (1 or 2 events/year). 

S8 - Ongoing process for development the ISO 20022 BP 
instructions. Full implementation is planned by Q4 2024. 

HR - SKDD 

All 
standards 

IE – Euroclear 
Bank 

All 
standards 

LU - LuxCSD 

All 
standards 

With regards to Buyer Protection standards, SKDD, as well as the 
majority of CSDs, shall use the Manual Buyer protection mechanism 
and the implementation of an automated buyer protection mechanism 
is not likely in the coming years. Full compliance with T2S Buyer 
Protection standards is planned for 16 June 2025. 

In April 2024, EB will join the T2S community in the frame of ECMS 
and its activity will be strictly limited to collateral monetary policy 
operations where counterparties will always 'opt-out' (NOMC 
indicator) so this situation will not happen. However, the compliance 
rate will grow when Euroclear Bank will deliver the intra-CSD phase 
from its Central Bank Money project, where scope will be wider than 
MPO, which require additional developments. 

T2S CA Standards will become relevant once Euroclear Bank 
enables intra-CSD settlement in T2S. Euroclear Bank confirmed its 
plans to reach full compliance with the T2S CA standards on market 
claims, transformations, and buyer protection by the start of the intra-
CSD settlement phase, currently planned for January 2026. 

All - Luxembourg market decided to not introduce an automated BP 
infrastructure. Volume of impacted events are very low. To facilitate a 
bilateral BP process between counterparties, in 2019 LuxCSD has 
published a final version of BP invocation template agreed by the 
CAJWG and the T2S CASG as well as all the requirements of the 
market and T2S BP standards, including the agreed timeline. 
https://www.luxcsd.com/luxcsd-en/products-and-
services/assetservices/l19023-1642862 

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. The current proposal is that 
the CSD calculates such dates as per the standards and notify the 
participants accordingly. The proposal was submitted to the market 
for validation and approved. Developments are planned to achieve 
full compliance with the standard after the ECMS go-live, in the 
course of 2025. 

Corporate Events Compliance Report – Compliance assessment 

115 

 
 
 
3.5.2 

Non-T2S markets 

Chart 12 
Automatic Buyer Protection– % compliance per market 

Notes: N/A. 

Table 17 
Automatic Buyer Protection – Compliance status per Standards 

Creation 

Processing 

1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

BE - Euroclear Bank 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

B 

CY - Cyprus Stock Exchange 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

CZ - CSD Prague 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

CZ - SKD 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

GR - ATHEXCSD 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

IE - Euroclear Bank 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

IS - Nasdaq CSD 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

LU - Clearstream Banking 
Luxembourg 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

NO - Euronext Securities Oslo 

0% 

0% 

0% 

0% 

0% 

25% 

0% 

50% 

0% 

0% 

0% 

0% 

PL - KDPW 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

PL - SKARBNET4 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

RO - SaFIR 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

SE - Euroclear Sweden 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

UK - Euroclear UK & International 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Notes: Buyer Protection is outside the scope of SKD activities. Buyer Protection is outside the scope of SKARBNET4 activities, as only 
Treasury-bills and NBP-bills are registered in SKARBNET4. Both of them are short term discount papers and the only Corporate 
Action which is carried out on these papers is final redemption. 

Corporate Events Compliance Report – Compliance assessment 

116 

0%10%20%30%40%50%60%70%80%90%100%BE - Euroclear BankCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDGR - ATHEXCSDIS -Nasdaq CSDLU - Clearstream Banking LuxembourgNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4RO - SaFIRSE - Euroclear SwedenUK - Euroclear UK & International 
 
 
 
  
Chart 13 
Manual Buyer Protection – % compliance per market 

Notes: N/A. 

Table 18 
Manual Buyer Protection – Compliance status per Standards 

Creation 

Processing 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

BE - Euroclear Bank 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

B 

CY - Cyprus Stock Exchange 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

CZ - CSD Prague 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

CZ - SKD 

N/A  N/A  N/A 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

GR - ATHEXCSD 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

IE - Euroclear Bank 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

IS - Nasdaq CSD 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

LU - Clearstream Banking Luxembourg 

25%  25%  25% 

25%  25%  25%  25%  25%  25%  25%  25% 

B 

B 

NO - Euronext Securities Oslo 

0% 

0% 

0% 

0% 

0% 

25% 

0% 

0% 

0% 

0% 

0% 

0% 

PL - KDPW 

50%  50%  50% 

50%  50%  50%  50%  50%  50%  50%  50%  50% 

PL - SKARBNET4 

N/A  N/A  N/A 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

RO - SaFIR 

N/A  N/A  N/A 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

SE - Euroclear Sweden 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

25% 

UK - Euroclear UK & International 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

Notes: Standard 18 is applicable to buyer protection instructions against CCPs. Buyer Protection is outside the scope of SKD 
activities. Buyer Protection is outside the scope of SKARBNET4 activities, as only Treasury-bills and NBP-bills are registered in 
SKARBNET4. Both of them are short term discount papers and the only Corporate Action which is carried out on these papers is final 
redemption. 

Corporate Events Compliance Report – Compliance assessment 

117 

0%10%20%30%40%50%60%70%80%90%100%BE - Euroclear BankCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDGR - ATHEXCSDIS -Nasdaq CSDLU - Clearstream Banking LuxembourgNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4RO - SaFIRSE - Euroclear SwedenUK - Euroclear UK & International 
 
 
 
  
Table 19 
Buyer Protection (Non-T2S Markets) - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the Buyer 
Protection standards. Markets/CSDs not listed below have been assessed as fully compliant. 

Market 

Gaps 

Status 

BE – Euroclear 
Bank 

S1-S11, 
S13-S23 

All - The key BP dates are not yet notified although Euroclear Bank is technically 
ready to transmit this information via non structured field. Both ICSDs agreed on 
the common rules for generating the BP key dates for the international market. 
This process will be fully handled by ICSDs; therefore, the question of the 
implementation is only on the ICSDs side and will depend on available technical 
release. Preferably, a common implementation date should be agreed between 
both ICSDs (not expected before end 2024) to be followed by an update of the 
ISMAG standards accordingly. Euroclear has a development plan to first create 
the BP dates in their swifts and data bases, and another one to derive the BP 
when necessary. The current implementation deadline is Q2 2025. 

Plan 

Q2 2025 

CY – CSE 

All 
standards 

All - Technical and regulatory changes for the implementation of this standard 
are currently assessed. 

S1 – S12 – No 
plan 

S13-S24 - A manual process is expected go live Q4 2024. 

CZ – CSD Prague  All 

standards 

All - The claims, transformations and buyer protections on the Czech market are 
processed in a different way and the standard is not implemented on the Czech 
capital market. 

S13-S24 - Q4 
2024 

All standards 
– No plan 

GR – ATHEXCSD  S13-S24 

S1-S12 – N/A. An automated Buyer Protection mechanism will not be 
implemented. Manual Buyer Protection will be available. 

H2 2025 

S13-S24 - Corporate actions are only affected on settled positions as of the 
record date. ATHEXCSD does not expect buyer protection changes to be 
significant because the process would be manual (carried out by Participants 
based on our guidance). ATHEXCSD has identified only a few changes to ISO 
messages to include information like Guaranteed Participation Date, Buyer 
Protection Deadline, etc. Currently, the CSD expects to achieve full compliance 
with the standard by 2025H2. 

IE – Euroclear 
Bank 

All 
standards 

S1-S23 - EB as Irish CSD does not offer a buyer protection service. The key BP 
dates are transmitted in the narrative field. Euroclear Bank is foreseeing the 
development to report such information in the appropriate structured fields. 

S1-S23 – 
2025, 

S24 - 2029 

S13-S23  

LU – 
Clearstream 
Banking 
Luxembourg 

S24 - Euroclear Bank has started a multi-year program which foresees the 
migration of the legacy custody processing to a new Asset Servicing Platform. 
Compliance with corporate action standards is part of the scope of this project 
divided into multiple phases with an end delivery date expected around 2029. 

All - CBL is technically ready to support the manual buyer protections, however 
the key buyer protection dates are not yet notified as no market practice is 
defined for the Eurobonds market due to the low volumes of impacted CA 
events. Both ICSDs agreed on common rules for generating the buyer 
protection key dates for the International market. This process will be fully 
handled by ICSDs, therefore, the question of the implementation is only on the 
ICSDs side and will depend on available technical release. Preferably, a 
common implementation date should be agreed between both ICSDs (not 
expected before end 2024) to be followed by an update of the ISMAG standards 
accordingly. 

No plan 

NO – Euronext 
Securities Oslo 

All 
standards 

S1-S5, S7-S11, S15-S18 - Legal barrier. Existing model where the issuer agent 
is operating the CSD system via contractual obligation based both on 
Norwegian Law and CSD rule book does not contain such requirements. 

Q3 2026 

S6 - Buyer Protection exist in the CCP for some voluntary events but is not 
automated or have notification connected to it. These are mostly do bilaterally 
between the C/P`s 

S13, S14 - These are mostly do bilaterally between the C/P`s 

PL – KDPW 

All 
standards 

S1-S12 – KDPW has no intentions to implement Automated Buyer Protection for 
the time being. 

S13-S24 – Q2 
2027 

S13-S24 - CSD Perspective: Legal barrier exists and relates to some elective 
events are not being processed centrally through the CSD system, which is a 
precondition for BP processing. Manual Buyer Protection Market Practice as 
well as BP Instruction template are in place. Nonetheless, having very limited 
number of real-life scenarios at CSD level, market participants see no practical 
reason to endorse it. CCP Perspective: Central Counterparty is in process of 
implementation of Manual BP Mechanism. BPM rules are awaiting approval 
from the Competent Authority. 

SE - Euroclear 
Sweden 

S24 

No CSD support exists for transformations. Instructions in the old ISIN are not 
allowed by the CSD after pay date. 

No plan 

Corporate Events Compliance Report – Compliance assessment 

118 

 
 
 
3.6 

Shareholder Identification 

3.6.1 

Shareholder Identification Standards 

Chart 14 
Shareholder Identification – % compliance per market 

Notes: N/A. 

Box 10 
Shareholder Identification – Compliance status per Standard 

1.1 

1.2 

1.3 

1.4 

1.5 

1.6 

1.7 

1.8.
a 

1.8.
b 

1.8.
c 

1.8.
d 

1.8.
e 

1.9 

1.10 

2.1 

2.2 

3.1 

3.2 

3.3 

3.4 

3.5 

AT - Oesterreichische 
Kontrollbank 

BE - Euroclear Bank 

BE - Euroclear Belgium 

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 

75%  75%  75%  75%  75% 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

BE - NBB-SSS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

BG - BNBGSSS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

BG - CD AD 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

CH - SIX SIS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

CY - Cyprus Stock 
Exchange 

CZ - CSD Prague 

B 

B 

B 

B 

50%  50%  50%  50% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50%  50% 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

50%  50% 

B 

B 

B 

B 

CZ - SKD 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

DE - Clearstream 
Banking Frankfurt 

DK - Euronext 
Securities Copenhagen 

EE - Nasdaq CSD 

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 

B 

B 

B 

B 

B 

0% 

B 

75% 

B 

B 

75% 

B 

B 

B 

75% 

75% 

B 

B 

B 

B 

75%  75% 

B 

B 

Corporate Events Compliance Report – Compliance assessment 

119 

0%10%20%30%40%50%60%70%80%90%100%AT - Oesterreichische KontrollbankBE - Euroclear BankBE - Euroclear BelgiumBE - NBB-SSSBG - BNBGSSSBG - CD ADCH - SIX SISCY - Cyprus Stock ExchangeCZ - CSD PragueCZ - SKDDE - Clearstream Banking FrankfurtDK - Euronext Securities CopenhagenEE - Nasdaq CSDES - IberclearFI - Euroclear FinlandFR - Euroclear FranceGR - BOGSGR - ATHEXCSDHR - SKDDHU - KELERIE - Euroclear BankIS - NasdaqIT - Euronext Securities MilanLI - SIX SISLT - Nasdaq CSDLU - Clearstream Banking LuxembourgLU - LuxCSDLV - Nasdaq CSDMT - Malta Stock ExchangeNL - Euroclear NederlandNO - Euronext Securities OsloPL - KDPWPL - SKARBNET4PT - Euronext Securities PortoRO - Depozitarul CentralRO - SaFIRSE - Euroclear SwedenSI - KDDSK - CDCPUK - Euroclear UK & International 
 
 
 
1.1 

1.2 

1.3 

1.4 

1.5 

1.6 

1.7 

ES - Iberclear 

75% 

FI - Euroclear Finland 

FR - Euroclear France 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

1.8.
a 

1.8.
b 

1.8.
c 

1.8.
d 

1.8.
e 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75%  75%  75%  75% 

1.9 

1.10 

2.1 

2.2 

3.1 

3.2 

3.3 

3.4 

3.5 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

GR - BOGS 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

GR - ATHEXCSD 

HR - SKDD 

HU - KELER 

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 

75%  75%  75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75%  75%  75%  75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

IE - Euroclear Bank 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

IS – Nasdaq CSD 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

IT - Euronext Securities 
Milan 

LI - SIX SIS 

LT - Nasdaq CSD 

LU - Clearstream 
Banking Luxembourg 

LU - LuxCSD 

LV - Nasdaq CSD 

MT - Malta Stock 
Exchange 

NL - Euroclear 
Nederland 

NO - Euronext 
Securities Oslo 

PL - KDPW 

B 

B 

B 

B 

50% 

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 

0% 

B 

50% 

B 

50% 

B 

B 

B 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

B 

B 

B 

B 

B 

B 

75% 

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 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

75% 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75%  75%  75%  50%  75% 

B 

75%  75% 

B 

75% 

B 

B 

75%  75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

PL - SKARBNET4 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

PT - Euronext 
Securities Porto 

RO - Depozitarul 
Central 

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 

B 

B 

B 

RO - SaFIR 

N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

SE - Euroclear Sweden 

SI - KDD 

SK - CDCP 

UK - Euroclear UK & 
International 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75%  75% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

75% 

B 

B 

B 

B 

B 

B 

B 

B 

0% 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

B 

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  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A  N/A 

Notes: SI Standards are outside the scope of NBB-SSS, BNBGSSS, SIX SIS, SKD, BOGS, Nasdaq CSD (Iceland), SKARBNET4, SaFIR, Euroclear UK & International. 

Table 20 
Shareholder Identification - Gap analysis 

This table lists all markets/CSDs that have not yet achieved full compliance with the SI 
Standards. Markets/CSDs not listed below have been assessed as fully compliant. 

Market 

Gaps 

Status 

Plan 

AT - 
Oesterreichische 
Kontrollbank 

S1.9, 
S3.1 

S1.9 - some clients are not able to receive ISO 20022 

S3.1 - not all issuers follow the standard. 

BE – Euroclear 
Belgium 

1.8a-1.8e, 
S3.1, 
S3.4 

S1.8a-1.8e – Euroclear Belgium systematically sends SI requests to 
all CSD participants without considering whether those parties held 
the position on the record date. 

S1.9, S3.1 – ongoing 
discussions 

S1.8a-1.8e - Q4 2025 

S3.1, S3.4 - Not all intermediaries respond. Although SRD II has 
global reach, US and APAC, and even some EU institutions refuse to 
respond. Average response rate between 85-95%. 

Corporate Events Compliance Report – Compliance assessment 

120 

 
 
 
 
Market 

Gaps 

Status 

Plan 

CY - CSE 

S1.4-
S1.6, 
S1.9, 
S1.10, 
S3.3. 
S3.4 

CZ – CSD Prague  1.8d 

DE – 
Clearstream 
Banking 
Frankfurt 

S3.1, 
S3.4 

S1.4-S1.6, S1.9, S1.10, S3.3. S3.4 - Not all shareholder identification 
requests are transmitted in an electronic form. 

No plan 

S1.8d - The request is transmitted only to "holding" intermediaries, 
pending transactions are currently not reflected. New holding 
intermediaries are informed on record date. CSD plan to implement 
reporting to all new holders by June 2025 (implementation goes 
together with SCoRE release). 

Q2 2025 

All - Compliance depends 
on external parties 

S3.1 – Comments by Clearstream Banking Frankfurt (CBF): The 
German law referring to the Regulation also allows a transmission 
through the chain. However, market members currently follow the 
recommendation from the Standards and reply directly. We have 
seen requests with deadlines shorted than ten business days, mainly 
from one issuer agent that feel bound by requirements from the 
regulation and are not willing to adhere to the Standards. 

Comments by WM Datenservice: Not all Intermediaries are yet able 
to process SI request electronically. Due to technical difficulties on 
the side of intermediaries not all responses were received within the 
defined time frame. As WM Datenservice is only on the receiving end, 
no implementation date is set. 

S3.4 – Comments by Clearstream Banking Frankfurt (CBF): Issuer 
agents reported that some smaller intermediaries (unknown whether 
they are from Germany) do not respond via seev.047. Several banks 
from outside Europe do not respond at a or send information in 
unstructured files or as text. 
WM: Not all Intermediaries are yet able to process SI request 
electronically. 

DK - Euronext 
Securities 
Copenhagen 

S3.1, 
S3.4, 
S3.5 

S3.1, S3.4 - Not all intermediaries respond including Euronext 
Copenhagen, who only provide participants using the value-add asset 
servicing platform of Euronext Copenhagen. The average response 
rate is between 75-95%. 

No plan 

EE – Nasdaq 
CSD 

S2.1, 
S3.1 

ES – Iberclear 

S1.1 

S3.5 - Barrier - Euronext Copenhagen (Issuer CSD and First 
Intermediary) does not respond. 

S2.1 - CSD does not set any technical or legal limits for the Issuers. 

No plan 

S3.1 - CSD does not set any technical or legal limits for the Issuers 
when it becomes to days between when request was made and 
Issuer's deadline 

Some issuer agents in Spain are sending their shareholder 
identification requests directly to the investor CSDs instead of the 
issuer CSD (Iberclear) and flag them as to be forwarded down the 
chain which is not compliant. 

No plan 

FR – Euroclear 
France 

S1.8a-
S1.8e, 
S3.1, 
S3.4 

S1.8a-1.8e – Euroclear France systematically sends SI requests to all 
CSD participants without considering whether those parties held the 
position on the record date. 

S1.8 – Q4 2025 

S3.1, S3.4 - Not all intermediaries respond. Although SRD II has 
global reach, US and APAC, and even some EU institutions refuse to 
respond. Average response rate between 85-95%. 

GR - ATHEXCSD  S3.1-S3.5  The CEG noted that the receipt of disclosure information may be 

All – N/A 

used as a basis and as a binding source for the release of a 
subsequent dividend payment in the Greek market. As a result of this 
practice, (some) investors holding securities in an omnibus account 
will not receive the dividend payments on time in cases where 
disclosure of information is not provided. Further information on the 
case at hand is provided in the Key Takeaways (Section 2 of this 
report).   

S1.8.c, d, e - KELER fully complies with the standard regarding 
intermediaries having holdings in the Underlying security, but does 
not forward the request for intermediaries with Pending Transaction in 
the Underlying Security. Treatment of Pending transactions by 
KELER is planned to be implemented by December 2025. 

All – November 2025 

HU - KELER 

S1.8.c-
S1.8.e 

IE – Euroclear 
Bank 

All 
standards 

Despite the fact that SRDII was transposed into Irish law, there is 
currently no SI process in the market due to legal issues. 

N/A 

IT - Euronext 
Securities Milan 

S1.3, 
S3.1, 
S3.3 

S1.3 - The types of information are in line with SRD II provisions, 
however ISO20022 messages are not yet available. 

Q1 2026 

Corporate Events Compliance Report – Compliance assessment 

121 

 
 
Market 

Gaps 

Status 

Plan 

S3.1 - The response to the request to disclose shareholder identity 
shall be provided and transmitted by each Intermediary to the 
address defined in the request without delay and no later than during 
the business day immediately following the record date or the date of 
receipt of the request by the responding Intermediary, whichever 
occurs later. In addition, each Intermediary shall provide and transmit 
the response to the SI request by the Issuer Deadline. The Issuer 
Deadline should be at least ten Business Days after the date of the SI 
request. The deadline referred to in the first paragraph of Standard 
3.1 shall not apply to responses to requests or those parts of 
requests, as applicable, which a) cannot be processed as machine-
readable and straight-through processing; or b) are received by the 
Intermediary more than seven business days after the record date. In 
such cases, the response shall be provided and transmitted by the 
intermediary without delay and in any event by the Issuer Deadline. 

S3.3 - ISO20022 (MX type) messages are not yet available. 

LT – Nasdaq 
CSD 

S2.1, 
S3.1 

S2.1 - CSD does not set any technical or legal limits for the Issuers. 

No plan 

S3.1 - CSD does not set any technical or legal limits for the Issuers 
when it becomes to days between when request was made and 
Issuer's deadline 

LU – 
Clearstream 
Banking 
Luxembourg 

All 
standards 

All - Not enough volumes to assess the compliance. 

No plan 

S3.1, S3.4 - Not all intermediaries respond. Although SRD II has 
global reach, US and APAC, and even some EU institutions refuse to 
respond. Average response rate between 85-95%. 

LV – Nasdaq 
CSD 

S2.1, 
S3.1 

S2.1 - CSD does not set any technical or legal restriction for the 
issuers. 

No plan 

S3.1 - CSD does not set any technical or legal restriction for the 
issuer when it comes to days between when request was made and 
issuer's deadline. 

MT - Malta Stock 
Exchange 

S2.2 

The issuer deadline date would be taken as the last date when such 
responses are to be received. 

NA 

Corporate Events Compliance Report – Compliance assessment 

122 

 
 
Market 

Gaps 

Status 

Plan 

NL - Euroclear 
Nederland 

S1.1, 
S1.7, 
S1.8c,d, 
S1.10, 
S2.1, 
S3.1, 
S3.4, 
S3.5 

S1.8c,d – Q4 2025 

  S1.1, S1.7, S1.10, S2.1, 
S3.1, S3.3, S3.4, S3.5 – 
No plan 

S1.1 - A number of Intermediaries, mainly foreign custodians, will not 
process requests unless the request originates with the CSD. This is 
not in line with current regulation. 

S1.7 Intermediaries in the US, IT and a few other jurisdictions 
besides the NL still request the LoA to be sent separately to them. 
This is the case for NL ISINs as well 

S1.8 - If the Intermediary receives the request after 16:00 the 
information is not always transmitted by 10:00 the next day but later 
that day. 

S1.8a,b,c,d - Euroclear Nederland systematically sends SI requests 
to all CSD participants without considering whether those parties held 
the position on the record date. 

S1.8c,d - Apparently, different (First) Intermediaries apply different 
approaches: some restrict communication to next intermediaries with 
a holding above threshold, others communicate irrespective of the 
threshold. 

S1.9, S1.10 – Dutch Issuer Agents (DIAs) have determined that there 
is no practical benefit in issuing Requests with future record dates 
and have encountered difficulties when doing so. As a result, they’ve 
chosen to discontinue this practice. Taking note of the DIA’s new 
practices, the CEG agreed from a methodology standpoint to apply 
the compliance rates applied in the previous assessment (100% for 
standard 1.9 and 75% for standard 1.10). 

S1.10 - Various foreign Intermediaries do not use appropriate 
messages. 

S2.1 ESES CSDs are not capable of responding over SWIFT if the 
record date is older than 3 months. Their response method is in 
machine-readable format but is not automated and creates additional 
labour for Issuer/Agents. 

S3.1 - Some (foreign) intermediaries respond (very) closely before 
Deadline, making challenging, questioning and correcting difficult. 
A significant number of (last) intermediaries has outsourced the 
responding to SI requests. We are not (yet) confident that these 
responses are timely, complete and correct. Sometimes the 
Requestor sets the Issuer Deadline less than ten Business Days after 
the SI request. 

S3.1, S3.4 - Not all intermediaries respond. Although SRD II has 
global reach, US and APAC, and even some EU institutions refuse to 
respond. Average response rate between 85-95%. 

S3.4 - Various foreign Intermediaries do not use appropriate 
messages. 

S3.5 - Some Intermediaries misinterpret this classification which 
results in misleading data towards the Issuer/Agent. This can 
negatively impact Corporate decisions. We do see (foreign) 
Intermediaries responding with NORE reason code when having no 
position, as well as Intermediaries responding with NORE reason 
code when having all BENEs below threshold 
- We do see Intermediaries reporting beneficiaries as Nominees 
- We also see holdings reported as own account, but specified as 
nominee holding. 

NO - Euronext 
Securities Oslo 

S3.5 

PL - KDPW 

S2.1 

S3.5 - Euronext Oslo has not developed seev.047 and does not reply. 
An issuer agent can request a copy of the legacy share register in 
Excel, i.e. in a non-machine readable format, but it includes all 
holders direct at the CSD, duplicating any data received from 
intermediaries. 

No plan 

S2.1 - In case of SI requests registered with KDPW, acting as the first 
intermediary and an entity collecting SI responses, according to 
Polish Securities Trading Act the issuer is not able, nor allowed to 
choose the Record Date from the past. 

No plan 

PT – Euronext 
Securities Porto 

S3.1 

S3.1 - Not all intermediaries are responding to SI requests. The CEG 
agreed to revise downwards the status of compliance with Standard 
3.1 accordingly, consistent with the approach taken for other markets. 

No plan 

SE – Euroclear 
Sweden 

S1.8b, 
S1.8e, 
S2.2 

S1.8b,e - Euroclear Sweden does not support updates. Cancellations 
must be requested prior to issuer deadline. 

All – No plan 

S2.2 - The CSD does not allow issuers to perform a shareholder 
identification disclosure request with a record date in the past. This is 
consistent with other corporate events, where Swedish law does not 
support record dates in the past. 

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123 

 
 
 
 
 
3.6.2 

Additional information on shareholder identification processes 

This section provides additional information on the functioning of the shareholder 
identification process, encompassing aspects not directly covered by the SI 
Standards contained in section 3.6.1.   

Box 11 provides information per market on: 

• 

• 

• 

• 

• 

• 

the status of the transposition of the Shareholder Rights Directive II (SRD II) 
into national legislation   

whether the legal definition of shareholder for the purpose of SRD II 
shareholder identification for securities issued in the market corresponds to the 
end investor 

whether the market’s definition of SRD II corresponds to the following definition: 
Shares of companies having their registered office in a Member State and 
whose shares of which are admitted to trading on a regulated market situated or 
operating within a Member State. 

whether entities in the market use the SI response to reconcile eligible investors 
for the General Meetings process. 

whether entities in the market use the SI response to reconcile eligible investors 
for the other corporate actions (e.g. dividend payments). 

whether the CSD in the market acts as an agent receiving responses on behalf 
of the issuer and, if yes, whether it is mandatory for issuers to choose this agent 
to comply with national law or CSD requirements. 

Box 11 
Information on SRD II transposition 

Yes 

No but planned 

No 

1) Has the Shareholder Rights Directive II (SRD II) been transposed into national legislation in your market? 
2) Please confirm that the legal definition of shareholder for the purpose of SRD II shareholder identification for securities issued in 
your market corresponds to the end investor. If it does not, please advise which party in the custody chain is legally considered to be 
the shareholder for the purpose of SRD II shareholder identification, and how this impacts both the operational process for the 
identification of shareholders, and compliance with the standards 
3) Does your country’s definition of SRD II correspond to the following definition “Shares of companies having their registered office in 
a Member State and whose shares of which are admitted to trading on a regulated market situated or operating within a Member 
State”? Guidance: Please select No if your country also classifies other asset types or non-tradable shares as SRD II. 
4) Do entities in your market use the SID response to reconcile eligible investors for the General Meetings process? If yes, please 
provided more information on this process. 
5) Do entities in your market use the SID response to reconcile eligible investors for other corporate actions (like dividend payments)? 
If yes, please provided more information on this process. 
6) Is the CSD in your country acting as a agent receiving responses on behalf of the issuer? If yes, is it mandatory for issuers to 
choose this agent to comply with national law or CSD requirements? 

1 

2 

3 

4 

5 

6 

AT - Oesterreichische Kontrollbank (T2S) 

BE - Euroclear Bank (T2S) 

BE - Euroclear Belgium (T2S) 

BE - NBB-SSS (T2S) 

BG - BNBGSSS (T2S) 

BG - CDAD (T2S) 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

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124 

 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1 

2 

3 

4 

5 

6 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

CH - SIX SIS (T2S) 

CY - Cyprus Stock Exchange 

CZ - CSD Prague 

CZ - SKD 

DE - Clearstream Banking Frankfurt (T2S) 

DK - Euronext Securities Copenhagen (T2S) 

EE - Nasdaq CSD (T2S) 

ES - Iberclear (T2S) 

FI - Euroclear Finland (T2S) 

FR - Euroclear France (T2S) 

GR - BOGS (T2S) 

GR - ATHEXCSD 

HR - SKDD (T2S) 

HU - KELER (T2S) 

IE - Euroclear Bank (T2S) 

IS - Nasdaq CSD 

IT - Euronext Securities Milan (T2S) 

LI - SIX SIS 

LT - Nasdaq CSD (T2S) 

LU - Clearstream Banking Luxembourg 

LU - LuxCSD (T2S) 

LV - Nasdaq CSD (T2S) 

MT - Malta Stock Exchange (T2S) 

NL - Euroclear Nederland (T2S) 

NO - Euronext Securities Oslo 

PL - KDPW 

PL - SKARBNET4 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

PT - Euronext Securities Porto (T2S) 

RO - Depozitarul Central (T2S) 

RO - SaFIR 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

SE - Euroclear Sweden 

SI - KDD (T2S) 

SK - CDCP (T2S) 

UK - Euroclear UK & International 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Additional explanations 

1) Has the Shareholder Rights Directive II (SRD II) been transposed into national legislation in your market? 

CH - SIX SIS (T2S) 

No. SRD II is a directive applicable to EU and EEA countries and has to be transposed into their national 
legislation accordingly. For Switzerland, however, this directive does not apply and therefore there is no 
obligation to transpose it into national Swiss law. Against this background and for the purposes of SRD II 
there is no definition of shareholder. 

DE - CBF (T2S) 

Yes. § 67d German Stock Corporation Act / § 67d Aktiengesetz. 

ES - Iberclear (T2S)  Yes. Law 5/2021, of April 12, amending the revised text of the Capital Companies Law, approved by Royal 
Legislative Decree 1/2010, of July 2, 2010, and other financial regulations, with respect to the promotion of 
long-term shareholder involvement in listed companies https://www.boe.es/buscar/act.php?id=BOE-A-2021-
5773#at 

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FR – Euroclear 
France (T2S) 

GR - ATHEXCSD 

Yes. SRD II is fully transposed under French law - Decree 2022-888 published on 14/06/2022. 

Yes. SRD II was transposed into national legislation in the Greek Market on 17/07/2020 by Greek Law no. 
4706/2020. 

HU - KELER (T2S) 

Yes. SRD II has been transposed into Hungarian law by Law LXVII of 2019 on Encouraging Long-Term 
Shareholder Engagement and amendments of further regulations for harmonization purposes. 

IS - Nasdaq CSD 

No but planned. The Ministry of Finance is currently working on transposing SRD2, and the work is 
expected to be concluded in 2025. 

IT - ES MIL (T2S) 

Yes. Consolidated Law on Financial Intermediation (TUF) - Regulation of central counterparties, central 
securities depositories and centralised management (“Single measure on post-trading” - Adopted by Consob 
and the Bank of Italy). 

LI - SIX SIS 

Yes. For EEA/EFTA States the SRD II also needs to be incorporated into the EEA Agreement. The 
corresponding Joint Committee Decisions (JCD 235/2020 and JCD 236/2020) took effect as of 1 October 
2021. At the same time the Liechtenstein national legislation entered into force, however the national 
Liechtenstein legal text passed in advance of this EEA incorporation date. 

LU - CBL 

No. The positioning of CBL is cross-jurisdictional and it depends on the regulation in place in the country of 
the issuer sending the disclosure request. 

LU - LuxCSD (T2S) 

Yes. Law of 1 August 2019 amending the amended Law of 24 May 2011 on the exercise of certain 
shareholders’ rights at general meetings of listed companies for the purpose of transposing Directive (EU) 
2017/828 of the European Parliament and of the Council of 17 May 2017 amending Directive 2007/36/EC as 
regards the promotion of long-term shareholder engagement. Article 3, Chapter 1, Art. 1 bis. (1-5). 
https://legilux.public.lu/eli/etat/leg/loi/2019/08/01/a562/jo 

PT - ES Porto (T2S)  Yes. SRD II was transposed into the national legislation through Law No. 50/2020, of August 25, 2020. 

RO - Depozitarul 
Central 

Yes. SRD II was transposed in the Romanian legal framework through Law no. 158/2020 for the 
amendment, completion and repealing of certain legislative acts, as well as for the establishment of certain 
measures for the application of (EU) Regulation 2017/2.402 of the European Parliament and of the Council 
of 12 December 2017 laying down a general framework for securitisation and creating a specific framework 
for simple, transparent and standardised securitisation and amending Directives 2009/65/EC, 2009/138/EC 
and 2011/61/EU, and Regulations (EC) no. 1060/2009 and (EU) no. 648/2012 

2) Please confirm that the legal definition of shareholder for the purpose of SRD II shareholder identification for securities issued in 
your market corresponds to the end investor. If it does not, please advise which party in the custody chain is legally considered to be 
the shareholder for the purpose of SRD II shareholder identification, and how this impacts both the operational process for the 
identification of shareholders, and compliance with the standards. 

CH - SIX SIS (T2S) 

CZ - CSD Prague 

No. SRD II is a directive applicable to EU and EEA countries and has to be transposed into their national 
legislation accordingly. For Switzerland, however, this directive does not apply and therefore there is no 
obligation to transpose it into national Swiss law. Against this background and for the purposes of SRD II 
there is no definition of shareholder. Nevertheless, in the context of an SRD II shareholder identification 
request coming from the EU/EEA area and which is addressed to Swiss intermediaries, the last intermediary 
will report the end-investor, which is considered to be the shareholder. 

No. Legal transposition of SRD II does not reflect End Investors, only shareholders are considered. 
Shareholders are supposed to be owners of shares registered on accounts on second level of central 
register. Therefore, only two intermediaries are taken into account in the law (the CSD and the custodian 
having an account at the CSD) and information is collected from these two levels of register. End Investors 
are defined only in Market Standards, not in any legally binding documents, and means physical or legal 
person who holds the shares for his own account. In cases where the second level of register is not an End 
Investor, the law does not impose the obligation to take that into account because shareholders are known 
(to the issuer) and these are executing shareholders' rights.   

As there is a difference between shareholder (used in EU and Czech legislation) and end investor (as 
defined in MS), there might be complications in interpretation. There is currently no plan or intention to 
recognise a longer chain of intermediaries. 

EE - Nasdaq CSD 
(T2S) 

No. In Estonia, the Commercial Code § 228 section 2 defines the shareholder "The rights attaching to a 
registered share shall belong to the person who is entered as the shareholder in the share register." 

According to Securities Register Maintenance Act § 5, 6, 9, the list of shareholders is generated on the basis 
of on whose name the account on which the securities are kept is opened, e.g. beneficial owner accounts.   

In case of nominee accounts, the owner of the nominee account is entitled to exercise the rights deriving 
from the shares. According to Securities Register Market Act § 6 section 9-2 - The holder of a nominee 
account shall, at the request of an issuer of shares admitted for trading on a regulated securities market or a 
third party nominated by the issuer, provide the issuer or the third party immediately with the information on 
the end investor. No threshold is applied to ownership/votes as from 30 April 2023. 

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ES - Iberclear (T2S)  Yes. The definition of “shareholder” in the Spanish legislation is not specifically focused for the purposes of 
SRD II however. There is only one general definition of “shareholder”, and it refers to the presumption that 
the holders of the securities according to the accounting records held by the CSD and its participants are 
the shareholders. Additionally, and in the case of registered shares, the issuer maintains Shareholders 
Registry with the information contained in the accounting records referred to above, and also confers 
legitimation effects in the relationship issuer-registered shareholder.   

However, the above definition has no impact at the SRD II identification level because the issuer can 
request both the identification of the shareholders (and will receive the information relating holders of 
securities at the CSD or participants level) and the identification of final beneficiaries (where the one 
presumed to be the shareholder is an intermediary entity that held the securities on behalf of those 
beneficiaries). The implementation of SRD II introduced the concept of final beneficiaries in the Spanish 
Corporate Law. 

GR - ATHEXCSD 

Yes. As regards the individual accounts, the shareholder is the one registered in the registry of the CSD 
which is also the end investor. As regards the omnibus accounts, the shareholder is the one identified as 
such by the intermediary which holds the account or any case of more than one intermediary in a chain of 
intermediaries the shareholder is identified as such by the intermediary who possess the relevant 
information.     

IT – ES Milan (T2S) 

Yes. Under the Italian regime of dematerialisation (that is mandatory for companies with listed shares) there 
is no explicit definition of shareholder, although, according to Art. 83-quinquies TUF, there is an implicit 
assumption it corresponds to the end-investor, i.e. the natural or legal person that has full and exclusive 
legitimacy to exercise the rights related to the financial instruments registered in the account by the last 
intermediary. 

LI – SIX SIS 

Yes. According to the corresponding national law, the "End Investor" is considered to be the relevant 
Shareholder for the purposes of SRD II.     

NO – ES Oslo 

Yes. The last intermediary is to report the holdings of the shareholder. 

PT – ES Porto (T2S)  Yes. The definition of shareholder aligned with the objectives of SRD II was clarified in the new version of 
the Securities Code published on December 31, 2021 that entered into force at the end of January 2022.   

RO    Depozitarul 
Central 

Yes. According to Art. 2 par. (1) point 1 of Law 24/2017 on issuers of financial instruments and market 
operations: “For the purposes of this law, the terms and expressions below shall have the following 
meanings:   

1. shareholder – means any natural person or legal entity governed by private or public law, who holds, 
directly or indirectly:   

(i) shares of the issuer in its own name and on its own account; 

(ii) shares of the issuer in its own name, but on behalf of another natural person or legal entity;   

(iii) certificates of deposit representing securities, in which case the holder of the certificate of deposit shall 
be considered the holder of the shares represented by the depository receipts;” 

SE – Euroclear 
Sweden 

For custody accounts held by multiple owners, intermediaries report all custody account holders. For CSD 
owner accounts held by multiple owners, the CSD reports only the appointed representative, as per other 
Swedish reporting of shareholders. 

3) Does your country’s definition of SRD II correspond to the following definition “Shares of companies having their registered office in 
a Member State and whose shares of which are admitted to trading on a regulated market situated or operating within a Member 
State”? Guidance: Please select No if your country also classifies other asset types or non-tradable shares as SRD II. 

ES - Iberclear (T2S)  No. The scope of SRD II as implemented in Spain also includes shares admitted to trading on an MTF. 

FR - Euroclear 
France (T2S) 

Yes. Text fully transposed for shares although national framework covers a wider scope of instruments 
(funds, corporate bonds, CP…) not considered as SRD II. 

IT - ES (T2S) 

Yes. According to Italian law, the articles of association of Italian companies with shares admitted to trading 
with the consent of the issuer on Italian multilateral trading facilities or those of other countries of the 
European Union may require that this article be applied. (art. 83 duodecies. 5). 

NL - ENL (T2S) 

No. The disclosure arrangements as implied by SRD II do also apply to "Shares …. traded on an OTF or 
MTF licensed in The Netherlands. 

RO - Dep. Cen. 
(T2S) 

Yes. Although the provisions which transpose SRD II are applicable only for issuers which have their 
registered office in Romania and whose shares are admitted to trading on a regulated market located or 
operating in a Member State, according to the national legislative framework, even before SRD II, there was 
the obligation to report information regarding the identity of the holders of all types of financial instrument, 
regardless of whether the respective financial instruments are traded on a regulated market or in another 
trading venue. 

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127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
4) Do entities in your market use the SID response to reconcile eligible investors for the General Meetings process? If yes, please 
provided more information on this process. 

BE - Euroclear 
Belgium (T2S) 

Yes. One company uses the SI process to reconcile the position of investors that want to participate in 
General Meetings. If the position is not matching, a manual process is in place to request participation for 
the position of the investor at the financial institution concerned. 

CZ - CSD Prague 

No. Only shareholders are entitled to attend a general meeting. Shareholders are determined by the list of 
shareholders provided by the CSD. The CSD requests only second level of register to provide the list of 
shareholders. If a shareholder is not provided in the list of shareholders, he needs to prove it to the issuer. 

DE - CBF (T2S) 

No. It was planned that, as of 01.01.2025, issuers would be required to submit information on shareholders 
identity for tax refund purposes to the local tax office (Bundeszentralamt für Steuern – BZSt). The 
transmission of such details might happen automatically based on the shareholder identification disclosure 
responses collected. The implementation has been postponed to 2026. 

DK ES Copenhagen 
(T2S) 

Yes. There were couple of instances were in the SI request it was noted that the positions that we need to 
disclose is for voting shares, for meeting purposes etc. 

EE – Nasdaq CSD 
(T2S) 

No. For this purpose, there is a system called eRegister in Estonia which allows issuers/issuer agents to 
access shareholder data for any record date without sending any SI request. This is the main reason why 
the number of SI requests in Estonia is lower than in Lithuania, Latvia. 

ES – Iberclear (T2S)  Yes. Issuers may request a SID on the occasion of the holding of a General Meeting and may use it for that 

purpose as they deem appropriate. 

GR – ATHEXCSD 

Yes. The SID responses are used to reconcile eligible investors for the General Meetings process in 
approximately 33% of the GMs. When a GM is announced, the issuers, send an SI request setting the 
record date 5 days prior to the GM, as per local law, and the response deadline on RD+1. Further to 
reconciliation of shareholders' disclosed information, the issuers accept the investors as eligible to 
participate and vote in the GM. 

HU – KELER (T2S) 

No. Issuers used to reconcile eligible investors through the issuer CSD’s (KELER) automated ownership 
identification procedure or they are collecting statement of holdings of the eligible investors. Issuers with 
large investor basis usually use the CSD’s service for that purpose. 

MT – MSE (T2S) 

Possibly. The CSD is a mostly a retail investor CSD and therefore the Issuers know the identity of the 
majority of the eligible investors. Where positions are held through an investor CSD and an issuer requires 
the details of eligible investors, a disclosure request would be submitted to the Issuer CSD under SRD II for 
transmission to the next intermediary in the chain. We are however not aware whether SID responses are 
used for reconciliation purposes. 

5) Do entities in your market use the SID response to reconcile eligible investors for other corporate actions (like dividend payments)? 
If yes, please provided more information on this process. 

CZ - CSD Prague 

No. In case of dividend payments, it is crucial to determine the tax residence of the beneficial owner. 
Therefore, the issuer should receive confirmation on the tax domiciliation, but they do not use the SID 
request at the CSD. The CSD provides the list of shareholders to the issuer and its administrators (agents). 

DK - ES 
Copenhagen (T2S) 

Yes. Some SI requests were received for the purpose of some corporate action such as bankruptcy and 
voluntary corporate actions. 

EE – Nasdaq CSD 
(T2S) 

No. For this purpose, there is a system called eRegister in Estonia which allows issuers/issuer agents to 
access shareholder data for any record date without sending any SI request. This is the main reason why 
number of SI requests in Estonia is lower than Lithuania, Latvia. 

GR - ATHEXCSD 

Yes. In the case of Bank of Greece (BoG), the SID response is used to reconcile eligible investors for 
dividend payments. An SI request is sent by BoG in order to identify eligible shareholders holding positions 
through omnibus accounts and exclude persons. 

HU – KELER (T2S) 

No. Issuers used to reconcile eligible investors through the issuer CSD's (KELER) automated ownership 
identification procedure or, if they know the investors, they are directly paying the end investors. 

LT – Nasdaq CSD 
(T2S) 

No. Issuers/issuer agents use both SRD II and non-SRD II lists of shareholders/investors to calculate taxes 
(based on country and type of person) for dividend/interest payments. 

LV – Nasdaq CSD 
(T2S) 

No. Issuers/issuer agents use both SRD II and non-SRD II lists of shareholders/investors to calculate taxes 
(based on country and type of person) for dividend/interest payments. 

6) Is the CSD in your country acting as agent receiving responses on behalf of the issuer? If yes, is it mandatory for issuers to choose 
this agent to comply with national law or CSD requirements? 

BE – Euroclear 
Belgium (T2S) 

Yes. It is not mandatory to use the CSD as agent. This service is optional while the market recommends that 
SID requests follow the chain of intermediaries starting with the Issuer CSD. 

BG - CDAD (T2S) 

Yes. It is mandatory for issuers to choose the CSD to comply with national law as per the Public Offering of 
Securities Act. 

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128 

 
 
 
 
 
 
 
 
 
CZ - CSD Prague 

Yes. Shares of companies traded on regulated market have to be registered at CSD. Therefore, CSD 
Prague would receive request for SID. It is not mandatory, and the issuer may request an intermediary 
further down the chain. 

DK – ES 
Copenhagen (T2S) 

EE – Nasdaq CSD 
(T2S) 

No. It is not mandatory for issuers to choose the CSD to comply with national law. 

Yes. It is not mandatory to choose the CSD. 

ES – Iberclear (T2S)  Yes. In accordance with Spanish law, the issuer or a third party appointed by the issuer shall have the right 

to obtain at any time from the CSD information enabling the identity of its shareholders to be determined. 
The request must be done through the CSD, and it centralises the information from its participants to be 
provided to the issuer, but the CSD does not receive the information on behalf of the issuer. The SID 
response will be provided to the issuer or its agent according to the request. For requests used to identify 
the beneficial owners, the CSD may act as the issuer designated agent and receive responses on behalf of 
such issuer. This intervention is not mandatory to the issuer. 

Yes. The issuer can choose the agent for receiving responses, EFi or some other service provider. 

FI – Euroclear 
Finland (T2S)   

FR – Euroclear 
France (T2S) 

Yes. It is not mandatory to use the CSD as agent. This service is optional while the market recommends that 
SID requests follow the chain of intermediaries starting with the Issuer CSD. 

GR – ATHEXCSD 

Yes. ATHEXCSD may act as Issuer Agent for Greek Issuers, however it is not mandatory for issuers to 
choose this agent. 

HR – SKDD (T2S) 

Yes. The CSD acts as an agent, but it is not mandatory for the issuers to use the CSD. 

HU - KELER (T2S) 

Yes. KELER acts as agent for collecting SID responses, but issuers are free to choose a different agent. 

LT - Nasdaq CSD 
(T2S) 

LV – Nasdaq CSD 
(T2S) 

PL – KDPW 

Yes. It is not mandatory for issuers to choose the CSD. 

Yes. It is not mandatory for issuers to choose the CSD. 

Yes. The CSD acts as an agent receiving responses on behalf of the issuer, but it is not mandatory for 
issuers to choose the CSD as an agent. 

PT – ES Porto (T2S)  Yes. Issuers can receive the information directly from the CSD or can choose to nominate a Third Party as 

its agent to receive the information reconciled and consolidated by the CSD. 

SE – Euroclear 
Sweden 

Yes. It is not mandatory for issuers to choose the CSD as agent. It is an optional service; issuers can 
choose another agent to receive responses to a request sent via the CSD. 

Box 12 provides information per market on the adoption of the five main ISO 20022 
messages used for the processing of shareholder identification requests namely the: 

• 

• 

• 

• 

• 

Shareholder Identification Disclosure Request (SIDR) – seev.045 

Shareholder Identification Disclosure Request Cancellation Advice (SIDC) – 
seev.046 

Shareholder Identification Disclosure Response (SIRE) – seev.047 

Shareholder Identification Disclosure Response Cancellation Advice (SIRC) – 
seev.048 

Shareholder Identification Disclosure Response Status Advice (SIRS) – 
seev.049 

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129 

 
 
   
Box 12   
Information on market adoption of ISO 20022 messaging by message type 

Used by all entities in the market 

Used by the majority of entities in the market 

Used only by some of the entities in the market 

Not used but planned 

Not used 

AT - Oesterreichische Kontrollbank (T2S) 

BE - Euroclear Bank (T2S) 

BE - Euroclear Belgium (T2S) 

BE - NBB-SSS (T2S) 

BG - BNBGSSS (T2S) 

BG - CDAD (T2S) 

CH - SIX SIS (T2S) 

CY - Cyprus Stock Exchange 

CZ - CSD Prague 

CZ - SKD 

DE - Clearstream Banking Frankfurt (T2S) 

DK - Euronext Securities Copenhagen (T2S) 

EE - Nasdaq CSD (T2S) 

ES - Iberclear (T2S) 

FI - Euroclear Finland (T2S) 

FR - Euroclear France (T2S) 

GR - BOGS (T2S) 

GR - ATHEXCSD 

HR - SKDD (T2S) 

HU - KELER (T2S) 

IE - Euroclear Bank (T2S) 

IS - Nasdaq CSD 

IT - Euronext Securities Milan (T2S) 

LI - SIX SIS 

LT - Nasdaq CSD (T2S) 

LU - Clearstream Banking Luxembourg 

LU - LuxCSD (T2S) 

LV - Nasdaq CSD (T2S) 

MT - Malta Stock Exchange (T2S) 

NL - Euroclear Nederland (T2S) 

NO - Euronext Securities Oslo 

PL - KDPW 

PL - SKARBNET4 

PT - Euronext Securities Porto (T2S) 

RO - Depozitarul Central (T2S) 

RO - SaFIR 

SE - Euroclear Sweden 

Level of usage of the SI message 

SIDR 
(seev.045) 

SIDC 
(seev.046) 

SIRE 
(seev.047) 

SIRC 
(seev.048) 

SIRS 
(seev.049) 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

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Level of usage of the SI message 

SIDR 
(seev.045) 

SIDC 
(seev.046) 

SIRE 
(seev.047) 

SIRC 
(seev.048) 

SIRS 
(seev.049) 

SI - KDD (T2S) 

SK - CDCP (T2S) 

UK - Euroclear UK & International 

N/A 

N/A 

N/A 

N/A 

N/A 

Additional explanations 

BE - EBe (T2S) 

SIRE (seev.047) Euroclear InvestorInsight offers intermediaries the ability to respond via file upload. 

SIRC (seev.048) Some "small" intermediaries are not able to send the seev.048. 

SIRS (seev.049) Some service providers do not send a confirmation through the seev.049. 

CZ - CSD Prague 

SRD II messages are fully supported by majority of entities on the market (CSD, participants), however 
seev.045 is used only for foreign securities, because for the Czech securities there is a local list of 
shareholders/bondholders that provide analogical information to SI which is legally more appropriate to the 
requirements of the Czech corporate law. 

DE - CBF (T2S) 

SIRS (seev.049) One of the largest domestic issuer agents does not send/plan to send seev.049 messages. 
Another issuer agent does not send seev.049 messages currently, but they plan the implementation. 

ES - Iberclear (T2S) 

Iberclear provides participating entities with a translation service (ISO20022 / ISO15022) for all the flow and 
information of shareholder meetings.   

FI - EFi (T2S) 

Seev.045 to seev.049 are implemented in the Finnish market. EFi participants are able to send/receive the 
messages. There is no visibility on the usage of the messages in the whole custody chain. 

FR - EF (T2S) 

SIRE (seev.047) Euroclear InvestorInsight offers intermediaries the ability to respond via file upload. 

SIRC (seev.048) Some "small" intermediaries are not able to send the seev.048. 

SIRS (seev.049) Some service providers do not send a confirmation through the seev.049. 

GR - ATHEXCSD 

SIDR (seev.045) ATHEXCSD uses the aforementioned ISO 20022 message. 

SIDC (seev.046) ATHEXCSD uses the aforementioned ISO 20022 message. 

SIRE (seev.047) ATHEXCSD uses the aforementioned ISO 20022 message. According to ATHEXCSD's 
experience when acting as Issuer Agent for Greek Issuers, approximately 80% of the SI responses received 
uses this message which is transmitted via FIN Plus or email to ATHEXCSD. 

SIRC (seev.048) ATHEXCSD uses the aforementioned ISO 20022 message. According to ATHEXCSD's 
experience when acting as Issuer Agent for Greek Issuers, approximately 30% of the SI responses received 
uses this message which is transmitted via FIN Plus or email to ATHEXCSD. As of 28/11/2023, the 
transmission of the aforementioned files is no longer accepted via email, but only through SWIFT FIN Plus 
services or the AXIA platform. 

SIRS (seev.049) ATHEXCSD uses the aforementioned ISO 20022 message. When ATHEXCSD acts as 
Issuer Agent for Greek Issuers, it transmits this message in all cases, via FIN Plus or email. 

IT – ES Milan (T2S) 

ISO20022 (MX type) messages are not yet available and are planned to be implemented in Q1 2026. 

LU – CBL 

SIRS (seev.049) One of the largest issuer agents does not send/plan to send seev.049 messages. Another 
issuer agent does not send seev.049 messages currently, but they plan the implementation. 

NL – ENL (T2S) 

SIDR (seev.045), SIDC (seev.046) Some account servicers use the MT564 to forward the request down the 
chain. Some use their own platform for SID request dissemination. 

SIRE (seev.047) Some major parties respond using EXCEL/PDF. Implementation is slow. 

SIRC (seev.048) Few parties support cancellation messages, which is needed considering the high amount 
of double messages received. 

SIRS (seev.049) Few parties are reconciling the status messages with the actual responses sent. 

PT – ES Porto (T2S)  SIDR (seev.045), SIDC (seev.046), SIRS (seev.049) The message is used by the CSD. Some 

intermediaries in the intermediation chain are using the message and the others are using other means, 
namely proprietary formats defined by the CSD and aligned with the ISO message, Excel/PDF files. 

SIRE (seev.047), SIRC (seev.048) Some intermediaries in the intermediation chain are using the message 
and the others are using other means, namely proprietary formats defined by the CSD and aligned with the 
ISO message, Excel/PDF files. 

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131 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RO – Dep. Cen. 
(T2S) 

SIDR (seev.045) Depozitarul Central makes available seev.045 for the participants that are able to receive 
and use it. Also, in our market there is a proprietary format available that has been set-up long before the 
SRD II implementation in order to be used by CSD and CSD participants for disclosure request and 
reporting. 

SIDC (seev.046) Depozitarul Central makes the seev.046 available to the participants that are able to 
receive and use it. 

SIRE (seev.047) Depozitarul Central is able to receive and process seev.047 sent by a participant and the 
intermediaries from its custody chain if the respective CSD participant subscribes to this service. In addition, 
a proprietary format is available that has been set-up long before the SRD II implementation in order to be 
used by CSD and CSD participants for disclosure request and reporting. 

SIRC (seev.048) Depozitarul Central is able to receive and process the seev.048 sent by a participant and 
the intermediaries from its custody chain if the respective participant subscribes to this service. 

SIRS (seev.049) Depozitarul Central makes available the seev.049 in response to a received seev.047. 

SI – KDD (T2S) 

SIDR (seev.045) SIDR is sent to KDD members as seev.045 (via SWIFT or in KDD GUI) and as information 
on screen in KDD GUI. Usage of SWIFT or KDD GUI is at discretion of each KDD member. 

SIDC (seev.046) SIDC is sent to KDD members as seev.046 (via SWIFT or in KDD GUI) and as information 
on screen in KDD GUI. Usage of SWIFT or KDD GUI is at discretion of each KDD member.     

SIRS (seev.049) SIRS is sent by KDD in response to each seev.047 received. 

SK – CDCP (T2S) 

SIDR (seev.045) Not used by the CDCP but implemented. Custodians are able to receive and send SIDR 
messages in ISO20022, but these are used for foreign securities in custody of a custodian (for its clients) 
rather than for domestic (Slovak) securities. Issuers do not use it. 

Box 13 provides information per market on how the messages are being used, in 
particular: 

• 

• 

• 

• 

whether issuers, or agents acting on behalf of issuers, use ISO20022 
messages (seev.045 – seev.049) via SWIFT FinPlus for SRD II requests. 

whether issuers, or agents acting on behalf of issuers, offer an alternative to 
ISO20022 messages (seev.045 – seev.049) for SRD II requests. 

whether issuers, or agents acting on behalf of issuers, use ISO20022 
messages (seev.045 – seev.049) for other disclosure requests (i.e. not related 
to SRD II). 

whether issuers, or agents acting on behalf of issuers, respond to a disclosure 
response (seev.047) with a disclosure response status advice (seev.049). 

Box 13   
Information on usage of ISO 20022 messaging (1/2) 

Yes 

No but planned 

No 

1) Do issuers, or agents acting on behalf of issuers, from your country use ISO20022 messages (seev.045 – seev.049) via SWIFT 
FinPlus for SRD II requests? 
2) Do issuers or agents acting on behalf of issuers from your country offer an alternative to ISO20022 messages (seev.045 – 
seev.049) for SRD II requests? 
3) Do issuers or agents acting on behalf of issuers from your country use ISO20022 messages (seev.045 – seev,049) for other 
disclosure request (non-SRD II)? 
4) Do issuers or agents acting on behalf of issuers from your country respond to a received seev.047 with a seev.049? 

1 

2 

3 

4 

AT - Oesterreichische Kontrollbank (T2S) 

BE - Euroclear Bank (T2S) 

BE - Euroclear Belgium (T2S) 

BE - NBB-SSS (T2S) 

N/A 

N/A 

N/A 

N/A 

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132 

 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
BG - BNBGSSS (T2S) 

BG - CDAD (T2S) 

CH - SIX SIS (T2S) 

CY - Cyprus Stock Exchange 

CZ - CSD Prague 

CZ - SKD 

DE - Clearstream Banking Frankfurt (T2S) 

DK - Euronext Securities Copenhagen (T2S) 

EE - Nasdaq CSD (T2S) 

ES - Iberclear (T2S) 

FI - Euroclear Finland (T2S) 

FR - Euroclear France (T2S) 

GR - BOGS (T2S) 

GR - ATHEXCSD 

HR - SKDD (T2S) 

HU - KELER (T2S) 

IE - Euroclear Bank (T2S) 

IS - Nasdaq CSD 

IT - Euronext Securities Milan (T2S) 

LI - SIX SIS 

LT - Nasdaq CSD (T2S) 

LU – Clearstream Banking Luxembourg 

LU - LuxCSD (T2S) 

LV - Nasdaq CSD (T2S) 

MT - Malta Stock Exchange (T2S) 

NL - Euroclear Nederland (T2S) 

NO - Euronext Securities Oslo 

PL - KDPW 

PL - SKARBNET4 

PT - Euronext Securities Porto (T2S) 

RO - Depozitarul Central (T2S) 

1 

N/A 

2 

N/A 

3 

N/A 

4 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

RO - SaFIR 

N/A 

N/A 

N/A 

N/A 

SE - Euroclear Sweden 

SI - KDD (T2S) 

SK - CDCP (T2S) 

UK - Euroclear UK & International 

N/A 

N/A 

N/A 

N/A 

Additional explanations 

1) Do issuers, or agents acting on behalf of issuers, from your country use ISO20022 messages (seev.045 – seev.049) via SWIFT 
FinPlus for SRD II requests? 

CZ - CSD Prague 

No. For domestic shares, ISO 20022 and SRD II messages are not used. For foreign securities, CSD 
Prague received ISO 20022 via SWIFT FinPlus. 

ES - Iberclear (T2S)  Yes. Iberclear acting on behalf of issuers managing the disclosures requests and responding to other SI 

requests provides the possibility to use SWIFT FinPlus. A custodian and a credit institution indicate that only 
some agents and entities. Another custodian points out that it is not a common practice that issuer use 
ISo20022 and that only the major agents acting on behalf of issuers use it. 

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133 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
FI - EFi (T2S) 

Yes. When EFi acts as issuer agent. EFi only supports ISO2022 messages in SRDII requests   

GR - ATHEXCSD 

Yes. When ATHEXCSD acts as Issuer Agent for Greek Issuers it uses ISO 20022 messages via SWIFT 
FinPlus. 

HU - KELER (T2S) 

Yes. To our awareness, in Hungary, ISO20022 messages are only supported in cases where KELER is 
acting as issuer agent for SI requests. The answer is valid for the CSD in its capacity as issuer agent. 

IT - ES MIL (T2S) 

No. To be noted that some issuer agents have shown their readiness to process SHID request through MX 
series messages. 

PT - ES PTO (T2S) 

No. Issuer/Issuer Agent SI Request are mainly sent through the private area of the CSD web portal, subject 
to registration. 

RO - Dep. Cen. 
(T2S) 

Yes. Depozitarul Central in its capacity as issuer agent for issuers domiciled in Romania is able to use ISO 
20022 messages via SWIFT FinPlus for SRDII requests. 

SK - CDCP (T2S) 

No. While CDCP supports ISO20022 messages, issuers in the Slovak market do not use ISO20022 
messages. 

2) Do issuers or agents acting on behalf of issuers from your country offer an alternative to ISO20022 messages (seev.045 – 
seev.049) for SRD II requests? 

CZ - CSD Prague 

Yes. Proprietary messages are used for more than 30 years. 

ES - Iberclear (T2S)  Yes. In addition to SWIFT FinPlus service, Iberclear offers the possibility to use proprietary formats in its SI 

requests and responses. One credit institution indicates that until now, they will continue to process the 
information received from their CSD in MT format. A custodian and a credit institution indicate that 
alternatives to ISO20022 messages are only offered by some agents and entities. 

FI -EFi (T2S) 

No. EFi only supports ISO2022 messages in SRDII requests. No information available on other service 
providers. 

GR - ATHEXCSD 

Yes. When ATHEXCSD acts as Issuer Agent for Greek Issuers it offers the alternative to receive xml files 
through email in ISO 20022 format. 

IT - ES MIL (T2S) 

Yes. The Italian domestic mode offers the CSD proprietary platform and format to announce and process 
SHID requests. 

LU - LuxCSD (T2S) 

Yes. Some issuer agents offer an alternative. 

PT - ES PTO (T2S) 

Yes. Issuer/Issuer Agent SI Request are mainly sent through the private area of the CSD web portal, subject 
to registration. 

RO - Dep. Cen. 
(T2S) 

SE - Euroclear 
Sweden 

Yes. Depozitarul Central in its capacity as issuer agent for issuers domiciled in Romania offers to its 
participants a proprietary format reporting channel of communication (SFTP), by collecting the disclosure 
responses back through the custody chain of intermediaries. 

Yes. Some agents offer an alternative solution; the CSD does not. 

SI - KDD (T2S) 

Yes. ISO20022 is not used by issuers; a dedicated form is used instead.   

3) Do issuers or agents acting on behalf of issuers from your country use ISO20022 messages (seev.045 – seev,049) for other 
disclosure request (non-SRD II)? 

ES - Iberclear (T2S)  Yes. Iberclear acting on behalf of issuers managing the disclosures requests and responding to other SI 

requests provides the possibility to use SWIFT FinPlus. In addition to SWIFT FinPlus service, Iberclear 
offers the possibility to use proprietary formats in its SI requests and responses. One credit institution 
indicates that until now, they will continue to process the information received from their CSD in MT format. 

FI - EFi (T2S) 

No. EFi only supports shareholder identifications within SRDII. No information available on non-SRDII 
requests. 

GR - ATHEXCSD 

Yes. When ATHEXCSD acts as Issuer Agent for Greek Issuers it may use ISO20022 messages (seev.045 – 
seev.049) for other disclosure requests (non-SRDII) upon Issuers' request. 

PT - ES PTO (T2S) 

Yes. ISO messages are used for all the securities registered at the CSD. 

RO - Dep. Cen. 
(T2S) 

Yes. It is currently used only on local level by some of the CSD's participants. 

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134 

 
 
 
 
 
 
 
4) Do issuers or agents acting on behalf of issuers from your country respond to a received seev.047 with a seev.049? 

BE - EBe (T2S) 

Yes. Some Service Providers do not send confirmation through the seev.049. 

CZ - CSD Prague 

Yes. However, not for domestic securities 

DE - CBF (T2S) 

Yes. Most of them do. One of the largest domestic issuer agents does not send/plan to send seev.049 
messages. Another issuer agent does not send seev.049 messages currently, but they plan the 
implementation. 

ES - Iberclear (T2S)  Yes. Iberclear acting on behalf of issuers responds with seev.049 messages. One credit institution indicates 

that until now, they will continue to process the information received from their CSD in MT format. 

FI - EFi (T2S) 

No. Issuers are not able to receive SWIFT messages. 

FR - EF (T2S) 

Yes. Some Service Providers do not send confirmation through seev.049. 

GR - ATHEXCSD 

Yes. When ATHEXCSD acts as Issuer Agent for Greek Issuers it responds to a received seev.047 with a 
seev.049. 

IT - ES MIL (T2S) 

No. There is no usage of MX series messages in the Italian market, due to limited number of event the 
occurrence has not been identified until now. 

PT - ES PTO (T2S) 

Yes. In its role as issuer agent, the CSD always responds to a received seev.047 with a seev.049. 

SI - KDD (T2S) 

Yes. Only KDD responds with seev.049 to each seev.047 received. 

SK - CDCP (T2S) 

No. While CDCP supports ISO20022 messages, issuers in the Slovak market do not use ISO20022 
messages. 

Box 14 provides information per market on: 

• 

• 

• 

how the rejection of requests is communicated to the requestor. 

whether a rejection reason is provided in the communication whenever a 
request is rejected. 

whether issuers, or agents acting on behalf of issuers, populate the SRD 
indicator in the ISO20022 message in accordance with the SMPG definition. 

Box 14   
Information on usage of ISO 20022 messaging (2/2) 

Yes 

No but planned 

No 

5) How is the rejection of requests communicated to the requestor? 
6) When a request is rejected, is the rejection reason mentioned in the communication? 
7) Do issuers or agents acting on behalf of issuers from your country use the SRD Indicator of the ISO20022 message as per the 
SMPG definition?1) 

AT - Oesterreichische Kontrollbank (T2S) 

BE - Euroclear Bank (T2S) 

BE - Euroclear Belgium (T2S) 

BE - NBB-SSS (T2S) 

BG - BNBGSSS (T2S) 

BG - CDAD (T2S) 

CH - SIX SIS (T2S) 

5 

By email 

By email 

By email 

N/A 

N/A 

Other (details below) 

Other (details below) 

6 

7 

N/A 

N/A 

N/A 

N/A 

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CY - Cyprus Stock Exchange 

CZ - CSD Prague 

CZ - SKD 

5 

By email 

Other (details below) 

6 

7 

N/A 

N/A 

N/A 

DE - Clearstream Banking Frankfurt (T2S) 

By email 

DK - Euronext Securities Copenhagen (T2S) 

By email 

EE - Nasdaq CSD (T2S) 

Other (details below) 

ES - Iberclear (T2S) 

Other (details below) 

FI - Euroclear Finland (T2S) 

FR - Euroclear France (T2S) 

GR - BOGS (T2S) 

GR - ATHEXCSD 

HR - SKDD (T2S) 

HU - KELER (T2S) 

IE - Euroclear Bank (T2S) 

IS - Nasdaq CSD 

By email 

By email 

N/A 

Other (details below) 

By email 

Request will be ignored 

IT - Euronext Securities Milan (T2S) 

Other (details below) 

LI - SIX SIS 

By semt.001 

LT - Nasdaq CSD (T2S) 

Other (details below) 

LU - Clearstream Banking Luxembourg 

LU - LuxCSD (T2S) 

By email 

By email 

LV - Nasdaq CSD (T2S) 

Other (details below) 

MT - Malta Stock Exchange (T2S) 

By email 

NL - Euroclear Nederland (T2S) 

Other (details below) 

NO - Euronext Securities Oslo 

Other (details below) 

PL - KDPW 

PL - SKARBNET4 

By email 

N/A 

PT - Euronext Securities Porto (T2S) 

Other (details below) 

RO - Depozitarul Central (T2S) 

RO - SaFIR 

By email 

N/A 

SE - Euroclear Sweden 

Other (details below) 

SI - KDD (T2S) 

SK - CDCP (T2S) 

Other (details below) 

Other (details below) 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

UK - Euroclear UK & International 

N/A 

N/A 

N/A 

Note: (1) The SMPG definition on the SRD Indicator usage:   
- The indicator should be set to YES (value “true”) only when the corporate event is in scope of SRD II and the notification/event 
information has been received from the issuer. Once the indicator has been set to YES because of an announcement received from 
the issuer CSD or first intermediary, it cannot be changed back to NO. 
- The indicator should be set to NO (value “false”) when the corporate event is to be intended as in scope of SRD II but the issuer CSD 
or first intermediary did not receive the notification/event information from the issuer.   
- The indicator should not be populated if the corporate event is outside the scope of SRD II 

Additional explanations 

5) How is the rejection of requests communicated to the requestor? 

BG - CDAD (T2S) 

The rejection is sent through the same channel by which the request was received, whether that be via 
email, semt.001, or another communication way. 

CH – SIX SIS (T2S) 

SRD II is a directive applicable to EU and EEA countries and has to be transposed into their national 
legislation accordingly. For Switzerland, however, this directive does not apply and therefore there is no 
obligation to transpose it into national Swiss law. 

Against this background, SRD II Standards are "not applicable" and thus specific SRD II ISO20022 
messages are not used in the Swiss domestic market. 

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CY - CSE 

For some custodians, rejections are received through email. For one custodian rejections are received in the 
custodian’s platform. 

CZ - CSD Prague 

The rejection is communicated via the CSD’s application for issuers (My Depository) in proprietary XML 
format. 

EE - Nasdaq CSD 
(T2S) 

There are some cases in the market where end investors behind the omnibus/nominee accounts are not 
disclosed by the participants for non-SRD II requests. This is not an entire rejection of the request as such, 
rather a consequence of participants' internal arrangements in regard to disclosure of investors behind the 
omnibus/nominee accounts in case of required cross-border disclosures. In these rare instances, the 
requestor sees a name of omnibus/nominee account on the final shareholder list, with no separate 
communication provided. 

ES - Iberclear (T2S) 

Iberclear would contact the requestor by phone or by e-mail. One credit institution indicates that until now, 
they will continue to process the information received from their CSD in MT format (ISO 15022). One 
custodian and one credit institution indicate that the seev.049 is used by Iberclear (CSD), while other agents 
respond by email. 

FI - EFi (T2S) 

Communication with the requestor is conducted either via email or via phone. 

GR - ATHEXCSD 

When ATHEXCSD acts as Issuer Agent for Greek Issuers, the rejection of requests is communicated by 
intermediaries either via email or via the AXIA platform (owned by ATHEX). 

IT - ES MIL (T2S) 

Rejection of requests are communicated to the issuer through the graphical user interface (GUI) or via a 
proprietary message. 

LT - Nasdaq CSD 
(T2S) 

LV - Nasdaq CSD 
(LV) 

There are some cases in the market where end investors behind the omnibus/nominee accounts are not 
disclosed by the participants for non-SRD II requests. This is not an entire rejection of the request as such, 
rather a consequence of participants' internal arrangements in regard to disclosure of investors behind the 
omnibus/nominee accounts in case of required cross-border disclosures. In these rare instances, the 
requestor sees a name of omnibus/nominee account on the final shareholder list, with no separate 
communication provided. 

There are some cases in the market where end investors behind the omnibus/nominee accounts are not 
disclosed by the participants for non-SRD II requests. This is not an entire rejection of the request as such, 
rather a consequence of participants' internal arrangements in regard to disclosure of investors behind the 
omnibus/nominee accounts in case of required cross-border disclosures. In these rare instances, the 
requestor sees a name of omnibus/nominee account on the final shareholder list, with no separate 
communication provided. 

NL - ENL (T2S) 

Some intermediaries will reject the request but will not communicate this at all. Few parties are 
communicating it via SWIFT messages and/or via email as well. 

NO - ES OSL 

Online solution via the CSD web portal, which Issuer Agents can access. 

PT - ES PTO (T2S) 

Issuer/Issuer Agent SI requests are mainly sent through the private area of the CSD web portal, subject to 
registration. In case the SI request is rejected, the Issuer/Issuer Agent receives a rejection message in the 
graphical user interface (GUI) or by email. 

SE - Euroclear 
Sweden 

Only issuers in scope of SRD II can request a seev.045 to be sent via the CSD, and only authorised 
representatives of those issuers have access to the CSD interface for this. Thus, no requests will need to be 
rejected. 

For intermediaries that receive a seev.045 for an ISIN for which the intermediary did not have holdings on 
the record date, no response is sent - the request is ignored. 

SI - KDD (T2S) 

The communication method is not strictly defined. 

SK - CDCP (T2S) 

CSD: According to the option chosen by the issuer in the application. Custodian: by semt.001. 

6) When a request is rejected, is the rejection reason mentioned in the communication? 

CZ - CSD Prague 

Yes. However, not for domestic securities. 

GR - ATHEXCSD 

Yes. When ATHEXCSD acts as Issuer Agent for Greek Issuers, the rejection of requests communicated via 
email by the intermediaries include also the rejection reason. 

NL - ENL (T2S) 

No. Most parties that do communicate the rejection simply do so with NORE. Few parties communicate 
more details on the reason behind the rejection. 

PT - ES PTO (T2S) 

Yes. The reason is mentioned in the rejection message. 

SE - Euroclear 
Sweden 

N/A. Only issuers in scope of SRD II can request a seev.045 to be sent via the CSD, and only authorised 
representatives of those issuers have access to the CSD interface for this. Thus, no requests will need to be 
rejected. 

For intermediaries that receive a seev.045 for an ISIN for which the intermediary did not have holdings in 
record date, no response is sent - the request is ignored. 

7) Do issuers or agents acting on behalf of issuers from your country use the SRD Indicator of the ISO20022 message as per the 
SMPG definition? 

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137 

 
 
 
 
 
 
 
 
BG - CDAD (T2S) 

No but planned. Ongoing development process. Implementation is planned for Q4 2024. 

CZ - CSD Prague 

Yes. It is used, but only for foreign securities. The SRD Indicator is used in the described way. 

ES - Iberclear (T2S)  No. Iberclear would implement the use of this indicator according to the SMPG definition. 

Several Iberclear participants (following intermediaries in the custody chain) have declared that they will 
only send SI responses if the indicator is filled in with the value "TRUE". This could be an issue because 
some SI requests with an SRD2 indicator 'false' or 'non-populated' could be potentially not responded to, 
although it is compulsory according to Spanish law. Iberclear is currently evaluating how to use and 
implement a new indicator in the seev.045 message to clearly express this requirement even if the SRD2 
indicator is not set to 'true'. 

One credit institution indicates that until now, they will continue to process the information received from 
their CSD in MT format. 

FI - EFi (T2S) 

Yes. The indicator is used in shareholder request and meeting notification messages. 

GR - ATHEXCSD 

Yes. When ATHEXCSD acts as Issuer Agent for Greek Issuers or as First Intermediary it uses the SRD 
Indicator of the ISO20022 message as per the SMPG definition 

IT - ES MIL (T2S) 

Yes. The SRD indicator used in the CSD proprietary and XML format message. 

NL - ENL (T2S) 

Yes. The SRD II indicator FALSE is not supported by Euroclear ESES and cannot be used. 

NO - ES OSL 

SE - Euroclear 
Sweden 

SK - CDCP (T2S) 

No. For the new ISO 20022 messages seev.001 and seev.045 the new indicator is in use. For the messages 
processed in ISO 15022 (Corporate Actions) the indicator is not in use. The nature of the implementation 
that the requirements of SRD2 in Norwegian law is only applicable to Nominee accounts, makes the usage 
of the indicator complicated. Implementation plan: N/A 

Yes. The response applies to shareholder identification disclosure requests. 

No. While CDCP supports ISO20022 messages, issuers in the Slovak market do not use ISO20022 
messages. 

Note: The SMPG definition on the SRD Indicator usage:   
- The indicator should be set to YES (value “true”) only when the corporate event is in scope of SRD II and the notification/event 
information has been received from the issuer. Once the indicator has been set to YES because of an announcement received from 
the issuer CSD or first intermediary, it cannot be changed back to NO. 
- The indicator should be set to NO (value “false”) when the corporate event is to be intended as in scope of SRD II but the issuer CSD 
or first intermediary did not receive the notification/event information from the issuer.   
- The indicator should not be populated if the corporate event is outside the scope of SRD II 

Corporate Events Compliance Report – Compliance assessment 

138 

 
 
 
 
Annex 1: Market Reporting 

Table A.1 
Overview of participation 

Market 

Market CA Standards 

T2S CA Standards 

SI Standards 

AT - Oesterreichische 
Kontrollbank (T2S) 

BE - Euroclear Bank 
(T2S) 

BE - Euroclear 
Belgium (T2S) 

No information provided 

No information provided 

No information provided 

Euroclear Bank (CSD) 

Euroclear Bank (CSD) 

Euroclear Bank (CSD) 

Euroclear Belgium (CSD) 

Euroclear Belgium (CSD) 

Euroclear Belgium (CSD) 

BE - NBB-SSS (T2S) 

NBB-SSS (CSD) 

NBB-SSS (CSD) 

NBB-SSS (CSD) 

BG - BNBGSSS (T2S)  BNBGSSS (CSD) 

BNBGSSS (CSD) 

BNBGSSS (CSD) 

BG - CDAD (T2S) 

CD AD (CSD), Industry 
Association, Custodian 

CD AD (CSD), Industry 
Association, Custodian 

CD AD (CSD), Industry 
Association, Custodian 

CH - SIX SIS (T2S) 

Swiss National Stakeholder 
Group (Swiss NSG) and Swiss 
Securities Post Trade-Council 
(swissSPTC) are responsible for 
the compilation of this report. All 
Swiss Securities Value Chain 
Stakeholders are represented in 
these Committees (CSD, 
Custodian, Credit Institution, 
Industry Association, Issuer, 
Issuer Agents, NCB). 

Swiss National Stakeholder 
Group (Swiss NSG) and Swiss 
Securities Post Trade-Council 
(swissSPTC) are responsible for 
the compilation of this report. All 
Swiss Securities Value Chain 
Stakeholders are represented in 
these Committees (CSD, 
Custodian, Credit Institution, 
Industry Association, Issuer, 
Issuer Agents, NCB). 

Swiss National Stakeholder 
Group (Swiss NSG) and Swiss 
Securities Post Trade-Council 
(swissSPTC) are responsible for 
the compilation of this report. All 
Swiss Securities Value Chain 
Stakeholders are represented in 
these Committees (CSD, 
Custodian, Credit Institution, 
Industry Association, Issuer, 
Issuer Agents, NCB). 

CY - Cyprus Stock 
Exchange 

Cyprus Stock Exchange (CSD), 
Bank of Cyprus (Custodian), The 
Cyprus Investment and Securities 
Corporation (Other), Citibank 
Europe Plc (Custodian), 
Eurobank S.A. (Custodian), 
Public Debt Management Office 
(Issuer), Treasury of the Republic 
of Cyprus (Other) 

CZ - CSD Prague 

Centrální depozitář cenných 
papírů, a.s. (CSD) 

CZ - SKD 

No information on participation 
provided 

N/A 

N/A 

N/A 

Cyprus Stock Exchange (CSD), 
Bank of Cyprus (Custodian), The 
Cyprus Investment and Securities 
Corporation (Other), Citibank 
Europe Plc (Custodian), 
Eurobank S.A. (Custodian), 
Public Debt Management Office 
(Issuer), Treasury of the Republic 
of Cyprus (Other) 

Centrální depozitář cenných 
papírů, a.s. (CSD) 

N/A 

DE - Clearstream 
Banking Frankfurt 
(T2S) 

DK - Euronext 
Securities 
Copenhagen (T2S) 

EE - Nasdaq CSD 
(T2S) 

ES - Iberclear (T2S) 

Clearstream Banking Frankfurt 
(CSD) 

Clearstream Banking Frankfurt 
(CSD) 

Clearstream Banking Frankfurt 
(CSD) 

Danish National Stakeholder 
Group (DK NSG) 

Danish National Stakeholder 
Group (DK NSG) 

Danish National Stakeholder 
Group (DK NSG) 

Nasdaq CSD (CSD) 

Nasdaq CSD (CSD) 

Nasdaq CSD (CSD) 

Iberclear (CSD), BNP Paribas 
Securities Services (Custodian), 
Banco Santander (Credit 
Institution), Sabadell (Custodian), 
Ibercaja Banco S.A. (Credit 
Institution), Cecabank 
(Custodian), Unicaja Banco 
(Credit Institution), CACEIS 
BANK SPAIN (Custodian). 

Iberclear (CSD), BNP Paribas 
Securities Services (Custodian), 
Banco Santander (Credit 
Institution), Sabadell (Custodian), 
Ibercaja Banco S.A. (Credit 
Institution), Cecabank 
(Custodian), Unicaja Banco 
(Credit Institution), CACEIS 
BANK SPAIN (Custodian). 

Iberclear (CSD), BNP Paribas 
Securities Services (Custodian), 
Banco Santander (Credit 
Institution), Sabadell (Custodian), 
Ibercaja Banco S.A. (Credit 
Institution), Cecabank 
(Custodian), Unicaja Banco 
(Credit Institution), CACEIS 
BANK SPAIN (Custodian). 

FI - Euroclear Finland 
(T2S) 

Euroclear Finland (CSD) 

Euroclear Finland (CSD) 

Euroclear Finland (CSD) 

Corporate Events Compliance Report – Annex 1: Market Reporting 

139 

 
 
FR - Euroclear 
France (T2S) 

Citi (Custodian), BPCE (Credit 
Institution), Euronext (Other), 
BNP Paribas Securities Services 
(Custodian), CA-CIB (Credit 
Institution), CM-CIC (Credit 
Institution), SG Securities 
Services (Custodian), SG 
Securities Services (Issuer 
Agents), CA-Titres (Custodian), 
Euroclear France SA (CSD), 
CACEIS (Custodian), ANSA 
(Issuer), Banque de France 
(Central Bank) 

Citi (Custodian), BPCE (Credit 
Institution), BNP Paribas 
Securities Services (Custodian), 
CA-CIB (Credit Institution), CM-
CIC (Credit Institution), SG 
Securities Services (Custodian), 
CA-Titres (Custodian), Euroclear 
France SA (CSD), CACEIS 
(Custodian), Banque de France 
(Central Bank) 

BNP Paribas Securities Services 
(Custodian), BPCE (Credit 
Institution), CA-Titres 
(Custodian), CACEIS 
(Custodian), CM-CIC (Credit 
Institution), Citi (Custodian), 
Euroclear France SA (CSD), 
Euronext (Other), La Banque 
Postale (Credit Institution), 
Uptevia (Issuer Agents), Oddo 
BHF (Other), Procapital (Other), 
SG Securities Services 
(Custodian), SG Securities 
Services (Issuer Agents), BNP 
Paribas - Retail (Custodian), 
ANSA (Issuer), Credit Mutuel 
Titres (Custodian), Banque de 
France (Central Bank) 

GR - BOGS (T2S) 

BOGS (CSD), National Bank of 
Greece SA (Custodian), BNP 
Paribas (Custodian), Alpha Bank 
(Custodian), Citibank 
(Custodian), Piraeus Bank 
(Custodian), Eurobank 
(Custodian) 

BOGS (CSD), National Bank of 
Greece SA (Custodian), BNP 
Paribas (Custodian), Alpha Bank 
(Custodian), Citibank 
(Custodian), Piraeus Bank 
(Custodian), Eurobank 
(Custodian) 

N/A 

GR - ATHEXCSD 

ATHEXCSD (CSD) 

N/A 

ATHEXCSD (CSD, Issuer Agents, 
Custodian) 

HR - SKDD (T2S) 

SKDD (CSD) 

SKDD (CSD) 

SKDD (CSD) 

HU - KELER (T2S) 

KELER (CSD), Magyar Nemzeti 
Bank (NCB), KELER CCP (CCP), 
BNP Paribas Securities Services 
(Custodian), CIB Bank 
(Custodian), Citibank Europe 
(Custodian), Deutsche Bank 
(Custodian), Erste Bank 
(Custodian), ING Bank N.V. 
(Custodian), KDB (Custodian), 
K&H Bank (Custodian), MBH 
Bank (Custodian), OTP Bank 
(Custodian), Raiffeisen Bank 
(Custodian), Sberbank 
Magyrorszak (Custodian), Sopron 
Bank (Custodian), Unicredit 
Hungary (Custodian), 
Government Debt management 
Agency (Issuer), MOL (Issuer), 
OTP Bank (Issuer), Richter 
(Issuer), Association of 
Investment Services Providers 
(Industry Association), Hungarian 
Banking Association (Industry 
Association), BAMOSZ (Industry 
Association), Budapest Stock 
Exchange (Custodian), Concorde 
Securities (Custodian), Equilor 
Investment (Custodian), SPB 
Investment (Custodian) 

KELER (CSD), Magyar Nemzeti 
Bank (NCB), KELER CCP (CCP), 
BNP Paribas Securities Services 
(Custodian), CIB Bank 
(Custodian), Citibank Europe 
(Custodian), Deutsche Bank 
(Custodian), Erste Bank 
(Custodian), ING Bank N.V. 
(Custodian), KDB (Custodian), 
K&H Bank (Custodian), MBH 
Bank (Custodian), OTP Bank 
(Custodian), Raiffeisen Bank 
(Custodian), Sberbank 
Magyrorszak (Custodian), Sopron 
Bank (Custodian), Unicredit 
Hungary (Custodian), 
Government Debt management 
Agency (Issuer), MOL (Issuer), 
OTP Bank (Issuer), Richter 
(Issuer), Association of 
Investment Services Providers 
(Industry Association), Hungarian 
Banking Association (Industry 
Association), BAMOSZ (Industry 
Association), Budapest Stock 
Exchange (Custodian), Concorde 
Securities (Custodian), Equilor 
Investment (Custodian), SPB 
Investment (Custodian) 

KELER (CSD), Magyar Nemzeti 
Bank (NCB), KELER CCP (CCP), 
BNP Paribas Securities Services 
(Custodian), CIB Bank 
(Custodian), Citibank Europe 
(Custodian), Deutsche Bank 
(Custodian), Erste Bank 
(Custodian), ING Bank N.V. 
(Custodian), KDB (Custodian), 
K&H Bank (Custodian), MBH 
Bank (Custodian), OTP Bank 
(Custodian), Raiffeisen Bank 
(Custodian), Sberbank 
Magyrorszak (Custodian), Sopron 
Bank (Custodian), Unicredit 
Hungary (Custodian), 
Government Debt management 
Agency (Issuer), MOL (Issuer), 
OTP Bank (Issuer), Richter 
(Issuer), Association of 
Investment Services Providers 
(Industry Association), Hungarian 
Banking Association (Industry 
Association), BAMOSZ (Industry 
Association), Budapest Stock 
Exchange (Custodian), Concorde 
Securities (Custodian), Equilor 
Investment (Custodian), SPB 
Investment (Custodian) 

IE - Euroclear Bank 
(T2S) 

Euroclear Bank (CSD) 

Euroclear Bank (CSD) 

Euroclear Bank (CSD) 

IS - Nasdaq CSD 

Nasdaq CSD (CSD) 

N/A 

Nasdaq CSD (CSD)   

IT - Euronext 
Securities Milan 
(T2S) 

LI - SIX SIS 

IT National Stakeholder Group 
(NSG) 

IT National Stakeholder Group 
(NSG) 

IT National Stakeholder Group 
(NSG) 

Liechtenstein Bankers 
Association (Industry 
Association), LGT Bank AG 
(Credit Institution), 
Liechtensteinische Landesbank 
AG (Credit Institution), VP Bank 
AG (Credit Institution), SIX SIS 
AG (CSD) 

Liechtenstein Bankers 
Association (Industry 
Association), LGT Bank AG 
(Credit Institution), 
Liechtensteinische Landesbank 
AG (Credit Institution), VP Bank 
AG (Credit Institution), SIX SIS 
AG (CSD) 

Liechtenstein Bankers 
Association (Industry 
Association), LGT Bank AG 
(Credit Institution), 
Liechtensteinische Landesbank 
AG (Credit Institution), VP Bank 
AG (Credit Institution), SIX SIS 
AG (CSD) 

LT - Nasdaq CSD 
(T2S) 

Nasdaq CSD (CSD) 

Nasdaq CSD (CSD) 

Nasdaq CSD (CSD) 

LU - Clearstream 
Banking Luxembourg 

Clearstream Banking SA 
Luxembourg (CSD) 

N/A 

Clearstream Banking SA 
Luxembourg (CSD) 

Corporate Events Compliance Report – Annex 1: Market Reporting 

140 

 
 
LU - LuxCSD (T2S) 

LuxCSD (CSD) 

LuxCSD (CSD) 

LuxCSD (CSD) 

LV - Nasdaq CSD 
(T2S) 

MT - Malta Stock 
Exchange (T2S) 

Nasdaq CSD (CSD) 

Nasdaq CSD (CSD) 

Nasdaq CSD (CSD) 

No information provided 

No information provided 

No information provided 

NL - Euroclear 
Nederland (T2S) 

Euroclear ESES (CSD), DACSI 
(Industry association) 

Euroclear ESES (CSD), DACSI 
(Industry association) 

Euroclear ESES (CSD), ABN 
AMRO Bank (Issuer Agents), 
Rabobank (Custodian), Citibank 
(Custodian), Van Lanschot 
Kempen (Custodian), CACEIS 
(Issuer Agents), Deutsche Bank 
(Custodian), Van Lanschot 
Kempen (Custodian), DACSI 
(Industry association) 

NO - Euronext 
Securities Oslo 

PL - KDPW 

Euronext Securities Oslo (CSD) 

N/A 

Euronext Securities Oslo (CSD) 

N/A   

KDPW (CSD), KDPW CCP 
(CCP), Narodowy Bank Polski 
(NCB), Citi Handlowy 
(Custodian), ING Bank Śląski 
(Custodian), BNP Paribas 
(Custodian), Societe Generale 
(Custodian), Deutsche Bank 
Polska (Custodian), Bank Pekao 
(Custodian), SEG (The Polish 
Association of Listed Companies) 
(Industry Association) 

KDPW (CSD), KDPW CCP 
(CCP), Narodowy Bank Polski 
(NCB), Citi Handlowy 
(Custodian), ING Bank Śląski 
(Custodian), BNP Paribas 
(Custodian), Societe Generale 
(Custodian), Deutsche Bank 
Polska (Custodian), Bank Pekao 
(Custodian), SEG (The Polish 
Association of Listed Companies) 
(Industry Association). 

PL - SKARBNET4 

SKARBNET4 (NCB) 

N/A 

N/A 

PT - Euronext 
Securities Porto 
(T2S) 

RO - Depozitarul 
Central (T2S) 

Euronext Securities Porto (CSD) 

Euronext Securities Porto (CSD) 

Euronext Securities Porto (CSD) 

Depozitarul Central (CSD) 

Depozitarul Central (CSD) 

Depozitarul Central (CSD) 

RO - SaFIR 

SaFIR (CSD) 

SaFIR (CSD) 

SaFIR (CSD) 

SE - Euroclear 
Sweden 

N/A   

Euroclear Sweden (CSD), 
Swedish Securities Markets 
Association (Industry 
Association), SEB (Custodian), 
SEB (Issuer Agent), SEB (Issuer), 
Handelsbanken (Custodian), 
Handelsbanken (Issuer Agent), 
Handelsbanken (Issuer), Nordea 
(Custodian), Nordea (Issuer 
Agent), Nordea (Issuer), 
Swedbank (Custodian), 
Swedbank (Issuer Agent), 
Swedbank (Issuer), Danske Bank 
(Custodian), Danske Bank (Issuer 
Agent), Danske Bank (Issuer), 
Citibank (Custodian), Citibank 
(Issuer Agents) 

Euroclear Sweden (CSD), 
Swedish Securities Markets 
Association (Industry 
Association), SEB (Custodian), 
SEB (Issuer Agent), SEB (Issuer), 
Handelsbanken (Custodian), 
Handelsbanken (Issuer Agent), 
Handelsbanken (Issuer), Nordea 
(Custodian), Nordea (Issuer 
Agent), Nordea (Issuer), 
Swedbank (Custodian), 
Swedbank (Issuer Agent), 
Swedbank (Issuer), Danske Bank 
(Custodian), Danske Bank (Issuer 
Agent), Danske Bank (Issuer), 
Citibank (Custodian), Citibank 
(Issuer Agents) 

SI - KDD (T2S) 

KDD (CSD) 

KDD (CSD) 

KDD (CSD) 

SK - CDCP (T2S) 

CDCP (CSD), Československá 
obchodná banka, a.s. 
(Custodian), Citibank Europe plc, 
pobočka zahraničnej banky 
(Custodian), Slovenská 
sporiteľňa, a.s. (Custodian), 
UniCredit Bank Czech Republic 
and Slovakia, a.s. pobočka 
zahraničnej banky (Custodian) 

CDCP (CSD), Československá 
obchodná banka, a.s. 
(Custodian), Citibank Europe plc, 
pobočka zahraničnej banky 
(Custodian), Slovenská 
sporiteľňa, a.s. (Custodian), 
UniCredit Bank Czech Republic 
and Slovakia, a.s. pobočka 
zahraničnej banky (Custodian) 

CDCP (CSD), Československá 
obchodná banka, a.s. 
(Custodian), Citibank Europe plc, 
pobočka zahraničnej banky 
(Custodian), Slovenská 
sporiteľňa, a.s. (Custodian), 
UniCredit Bank Czech Republic 
and Slovakia, a.s. pobočka 
zahraničnej banky (Custodian) 

UK - Euroclear UK & 
International 

No information provided 

No information provided 

No information provided 

Corporate Events Compliance Report – Annex 1: Market Reporting 

141 

 
 
 
Annex 2: Methodology 

The table below provides further details of the colour-coding methodology employed 
by AMI-SeCo as part of the compliance assessment exercise. 

Table A.2 
Methodology 

BLUE 

The market has achieved full compliance with the harmonisation standard. 

GREEN 

Changes are still pending (technical, regulatory or legal) before the market can achieve full compliance with the 
harmonisation standard, although no obstacles have been identified to achieving full compliance by the deadline. 

and 

The market has established a clear/detailed plan for implementing the harmonisation standard and publicly announced 
deadlines for full implementation. 

YELLOW  Changes are still pending (technical, regulatory or legal) before the market can achieve full compliance with a given 

harmonisation standard, although obstacles have been identified which may threaten the achievement of full 
compliance by the deadline. 

or 

The market has issued a statement declaring that it will implement the standard, although it has not yet committed to 
concrete and publicly announced dates for the implementation. 

RED 

The market has not provided any information on its level of compliance with the standard. 

or 

The market has decided to (fully) comply with the standard. 

or 

Changes are still pending (technical, regulatory or legal) before the market can achieve full compliance with the 
harmonisation standard and obstacles have been identified that have halted the implementation plan for the market 
and/or will prevent its full implementation by the deadline. 

N/A 

The standard outside the scope of the activities covered by the monitored entity. 

Notes: In accordance with the standard AMI-SeCo methodology, a blue colour-code is assigned to those standards where full 
compliance has been achieved while a red colour-code is assigned if compliance has not yet been achieved. In the case of the T2S 
CA Standards, if the target date for compliance has not yet been reached (i.e. the market has not yet migrated to T2S) then a yellow or 
green status is also possible. 

Corporate Events Compliance Report – Annex 2: Methodology 

142 

 
 
 
© European Central Bank, 2024 

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). 

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ISBN 978-92-899-6962-8, ISSN 2811-6801, doi:10.2866/2521899, QB-01-24-060-EN-N