Structured addresses: why banks can’t afford to slow down

Swift’s extension of the ISO 20022 structured address deadline highlights the tension between banks’ growing regulatory demands and the need to advance structured data to improve transparency, compliance, and cross-border payment efficiency.

When Swift agreed to the community's request to extend the structured address migration deadline for ISO 20022 payment messages—postponing the mandatory deadline for structured address requirements within CBPR+ flows due to uneven industry readiness—two key realisations immediately stood out to me.

The first is just how much the world of cross-border payments has evolved since I began my career in a banking Customer Service role in the summer of 2000. The second is a stark reminder of the immense, compounding pressure banks face today: complying with non-negotiable regulations and shifting market mandates, all while fighting to remain competitive in a fiercely contested landscape.

A look back: the search for structure

When I entered the industry, I remember banks transitioning to MT103s and moving away from MT100s, which were considered less structured and less suited for automation. Furthermore, MT202 COVs had not yet been introduced, making it impossible for intermediary banks to identify the originating and beneficiary parties. The adoption of the new FIN standards for customer credit transfers delivered a level of structure and transparency that the industry previously lacked.

But let’s take a look at where we are now. As of November 2025, the global banking community completed the migration to ISO 20022 XML messages (CBPR+) for in-scope cross-border payment instructions, moving away from legacy FIN MT messages.

ISO 20022 XML messages are considerably richer and more structured than the legacy FIN MT messages. This means significantly more information within a payment instruction, allowing for more granular data to be included in the message itself.

FIN messages had limited character sets, while XML introduces an expanded character set. FIN often resulted in truncated data, while XML allows for substantially greater field lengths which, for example, allow for long corporate names and complete addresses without truncation. Remittance information can now support up to 9,000 characters, enabling the transmission of information like full invoice numbers and purchase orders, thereby facilitating reconciliation processes for the ultimate beneficiary of the payment transfer. Furthermore, FIN did not support dedicated structured fields for ultimate party details, while XML messages introduced dedicated data elements, eliminating the need to guess who the ultimate parties are and providing clean, machine-readable information.

In a world where information is key and transparency is a priority, FIN could no longer cut it. ISO 20022 brought unprecedented structure and richer data to our industry, allowing for less human intervention, higher STP rates, and more accurate screening.

What is the big deal about a structured address?

If ISO 20022 has already given us so much, why is the industry making such a "big deal" out of structured addresses?

The structured address is simply the next step towards increased transparency and even greater efficiency. Having specific tags for each element of the address—city, street name, building number, and country code—removes the ambiguity that plagues legacy screening engines. It simplifies screening, reduces false positives, and can help payments clear without unnecessary investigations. During my years in customer service, free‑format addresses often triggered sanctions‑related false positives simply because a street name contained a word like “Cuba” or “Havana”—even when the payment originated and ended entirely outside embargoed territories. These unnecessary stops generated manual investigations, delays, and customer frustration. Structured addresses can significantly reduce this ambiguity by providing clean, machine‑readable tags for each element of the address.

The overloaded banking plate

However, implementing these changes is far from easy. Banks are working incredibly hard to keep pace with the transition.

If we look back at all the changes in messaging, we cannot forget that banking is not just about sending and receiving cross-border payments; there are many other moving components. Banks are under pressure to keep up with the constant, simultaneous evolution of their environment.

Think about the mandatory transformation of SEPA Instant Credit Transfers (SCT Inst) triggered by the Instant Payment Regulation (IPR). The regulation is not a “nice to have”; it is mandatory. While many banks were already offering SCT Inst, the IPR fundamentally changes the scale and operating requirements. Banks must make instant payments universally available at the same price as standard SEPA transfers, across the same customer initiation channels, and ensure 24/7 availability. They must also introduce Verification of Payee (VoP) and meet the 10-second execution requirement, while replacing transaction-by-transaction screening for targeted sanctions with at least daily customer screening. What was once an additional payment capability now has to operate as a fully integrated, always-on service across the bank’s payment infrastructure.

Another important deadline is the PSD3/PSR framework expected to take effect from mid-2028, which fundamentally shifts financial liability and mandates significantly stricter open banking rules. For institutions, this requires a major shift in current operations and an aggressive upgrade of real-time fraud-detection capabilities. Under the agreed framework, banks will face greater liability for fraud and, in specified cases of sophisticated scams such as bank impersonation fraud, will be required to refund customers. Furthermore, banks must re-engineer their Open Banking APIs to guarantee reliable performance and deliver fully functional consumer consent dashboards within their mobile apps, allowing users to instantly view and revoke data access. As standard multi-factor authentication alone can be insufficient against modern cybercrime, advanced, continuous transaction monitoring has become a necessity. Finally, while inter-bank fraud data sharing is designed to protect the wider financial community, navigating the requirements under the EU GDPR makes its practical implementation highly complex.

Furthermore, what about innovation, which often goes hand in hand with competition? These are just a few of the topics that come to mind, but they all point to the same challenge: banks need to keep moving, adapting and innovating, while ensuring that customer experience and expectations remain the top priority.

The risks of the pause

So, what am I trying to say here? Banks need to keep their eye on the ball and not let their guard down. There is so much happening across the banking community that working toward any milestone can feel like climbing Mount Everest: not enough time, not enough people, and too many requirements demanding immediate attention.

XML has brought structure to what used to be a very unstructured landscape, but the journey cannot end with the November 2025 migration. So, what about structured addresses?

The extension of the deadline makes sense operationally to prevent immediate payment failures, but it should not be interpreted as a reason to slow down. The community must continue working at full speed to ensure it captures the benefits structured addresses will bring: greater transparency, fewer false positives, fewer investigations, and stronger compliance screening.

And if we consider all this, in a world where many still argue that correspondent banking makes cross‑border payments slow, shouldn’t we be doing everything in our power to increase efficiency, enable faster payments, and ensure that banks remain relevant in the international payments landscape?

The industry cannot afford to stand still. Structured data is the path forward.

About Alessandra D’Este

Alessandra D’Este is a senior transaction banking and financial institutions professional with more than 20 years of experience in correspondent banking, payments, cash management and financial institutions coverage. She has worked with leading Italian and European financial institutions, supporting payments modernisation, cross-border transactions and strategic business development. Most recently, Alessandra served as Senior Payment Expert EMEA at Swift, advising financial institutions on payments modernisation, cross-border transactions and industry transformation initiatives. Prior to Swift, she spent nearly two decades at Wells Fargo in Financial Institutions Coverage, managing strategic relationships with leading European financial institutions across correspondent banking, payments and transaction banking services. Her areas of expertise include financial institutions coverage, payments, transaction banking, cash management, correspondent banking and cross-border payments.