The report, ISO 20022 Deadlines: Are Banks Ready for November 2026? surveyed 308 senior payments professionals across Europe and North America. It assesses readiness across two critical challenges banks face in 2026: the structured address migration and changes to exceptions and investigations handling.
The payments industry reached the ISO 20022 CBPR+ (dubbed the “end of co-existence”) milestone in 2025. Banks must now prepare for the next phase of implementation in 2026.
From mid-November 2026, unstructured postal addresses will no longer be permitted in CBPR+ messages. Banks must also support structured ISO 20022 exceptions and investigations messaging, replacing traditional free-text workflows with standardised CAMT processes. If they don’t, payments risk failing, potentially causing mass disruption for customers.
Nearly half (44%) of all banks are not currently on track to meet the structured address deadline. Of those, four in ten (40%) describe their project as ”recoverable,” suggesting there’s work to be done. 4% say they are “at risk”.
One in five (20%) of the largest banks (assets $250bn or greater) say the structured address deadline is unrealistic, compared to 5% for other banks.
Readiness for the exceptions and investigations 2026 “receive” requirement deadline reflects a similar pattern. Just over a quarter (27%) say they are “partially ready” to receive structured ISO 20022 exception and investigation messages.
That’s despite investing heavily. Most banks are spending around $20 million to meet 2026 requirements. Larger institutions are spending over $30 million. On average, banks are deploying 13 additional dedicated staff to support delivery, with nearly two-thirds (64%) allocating between six and 20 specialists to ISO 20022 programmes.
Underlying data challenges remain significant, with, on average, 32% of customer address records still unstructured, and nearly one in ten institutions reports that more than half of their address data remains non-compliant. Three-fifths (60%) report gaps in core banking systems when supporting structured address fields. In parallel, 45% of institutions are pursuing minimum-compliance changes to exceptions and investigations workflows rather than broader operational reform.
Additional notable findings include:
48% of institutions describe structured address migration as a pure regulatory requirement.
61% are delivering ISO 20022 reforms through multiple parallel initiatives rather than a single consolidated programme.
Only 10% are pursuing major transformation of exceptions and investigations workflows.
Pratiksha Pathak, Partner & Head of Payments at RedCompass Labs, said: “If banks thought their ISO 20022 migration was over in November 2025, they’d be mistaken. The end of coexistence was really just the end of the beginning. A new wave of deadlines is already approaching, with major changes required for structured addresses and Exceptions & Investigations (E&I) handling. There is still a lot of work to do.
“Once enforcement begins, systems will not accommodate incomplete data. Payments can be rejected, exception volumes can increase, and operational strain will rise quickly. And that could mean major disruption and unhappy customers.
“ISO 20022 is now a multi-billion-dollar transformation. It must be taken seriously. The institutions that industrialise change now will be in a far stronger position than those relying on last-minute compliance.”
