ISO 20022 isn't done
Many banks met the Swift cutover with translation layers. Structured addresses, exceptions and investigations, and statements arrive between 2026 and 2028, and each one exposes data you don't hold yet.
Translation was survival, not modernization
A large share of the industry met the Swift ISO 20022 cutover by translating. That was rational under a hard deadline. It also deferred the data problem. If your core still thinks in unstructured postal lines and free-text remittance, you have not modernized payments—you have rented time.
The next waves do not forgive that debt. Structured-only addresses, the end of MT101, exceptions and investigations on ISO 20022 messages, and the retirement of MT9xx statements each assume you can produce and consume richer data than a translator invents on the wire.
What breaks when the crutches leave
Structured addresses expose every customer record that was never cleaned. Exceptions and investigations expose every operations process that still prints a PDF and phones a correspondent. Statement retirement exposes every reconciliation job that never left MT940-shaped thinking.
None of these are 'Swift projects' in the narrow sense. They are data quality, operating model and vendor programmes that happen to have Swift dates attached. Treat them as one remediation register, not three separate sponsor decks.
A practical register
I ask clients for four artefacts: a structured-address remediation plan with owners; an MT101 exit path; an exceptions and investigations readiness view against the 2027 message set; and an honest list of translation debt that still sits in hubs and cores. Then we put dates from 2026 through 2028 against each item.
That register is what a board can fund. 'We are ISO 20022 compliant' is what a board hears when nobody wants to fund the next three years.
Where this lands
If you only staffed the cutover, restaff for phase two. If your vendors sold you a translator as a target state, reopen the conversation. The institutions that look finished in 2028 will be the ones that treated 2023–2025 as the on-ramp, not the destination.