Circular on T+1 Settlement: Finalisation of the Regulatory Framework and Immediate Readiness Actions

For compliance and operations teams, this is a firm-wide readiness programme, not a back-office IT project. The finalised framework raises expectations around trade-date processing, affirmation and matching, settlement instruction quality, funding and FX liquidity, and governance over third-party dependencies. Firms should expect closer supervisory attention to operational resilience and settlement discipline as the industry moves to shorter settlement cycles.

What this means for compliance teams: map the full trade lifecycle and identify where manual intervention, late allocations or mismatched instructions could create fails under T+1. Test contingency funding, custody and CSD connectivity, and vendor readiness. Update client-facing documentation and escalation procedures, and coordinate with counterparties and industry bodies.

Board-level oversight should be evidenced. Actions needed now: run a T+1 gap assessment; prioritise same-day affirmation and exception management; validate data quality; schedule end-to-end testing; confirm contractual and operational arrangements with custodians, brokers and technology providers; and track MFSA, ESMA and industry milestones. Firms with cross-border activity should align Malta readiness with UK, EU and Swiss timelines and client expectations.

Opportunities: firms that automate and streamline settlement can reduce fails, funding costs and counterparty risk, and differentiate on operational reliability. Risks: penalties, buy-ins, liquidity strain, client attrition and supervisory scrutiny. RegCanary expects implementation complexity to be high and readiness to be board-visible.