EPC Delays SEPA Structured Address Migration: Revised Timeline

On 9 September 2026 the European Payments Council (EPC) removed the fixed end date it had set for unstructured customer addresses in SEPA payments. Its Payment Scheme Management Board (PSMB) decided to delay the 15 November 2026 sunset of the unstructured address format across all five EPC payment scheme rulebooks, and support for unstructured addresses will now continue beyond that date. For payment service providers that had scoped their SEPA structured address migration around a fixed November go-live, the deadline they were planning against no longer stands in its earlier form.

No replacement date has been set. The PSMB will reconvene in October 2026 to fix a new end date, and the EPC expects to publish revised documentation, including the 2025 payment scheme rulebooks, implementation guidelines and supporting guidance materials, by October 2026 at the latest. Until that documentation lands, the rulebooks continue to permit unstructured, hybrid and fully structured address formats side by side.

The decision is a change to the calendar while the direction of travel holds. The EPC has restated its commitment to structured addresses and is still urging participants to keep migrating on their existing plans. The live question for payment operations and reporting teams is which internal milestones to freeze, which build work to keep running, and which parallel November 2026 deadlines at the Eurosystem and on the Swift network still apply.

Related reading: our explainer on the original 15 November 2026 SEPA structured address deadline.

The revised calendar at a glance

The delay leaves one confirmed decision, one open date, and a documentation deliverable that carries the detail. Treat every internal cut-over milestone tied to 15 November 2026 as provisional until the revised rulebooks name a new end date.

  • 9 September 2026: PSMB decides to delay the 15 November 2026 end date for the unstructured address format across all five scheme rulebooks.
  • 15 November 2026: the previously announced end date for unstructured addresses. Support now continues past this date.
  • October 2026: the PSMB reconvenes to set a new end date based on market and payment industry readiness.
  • By October 2026 at the latest: the EPC publishes revised 2025 rulebooks, implementation guidelines and supporting guidance reflecting the change.

What the PSMB actually decided

The scope of the decision is the end date, and only the end date. The five affected rulebooks are the SEPA Credit Transfer and SEPA Instant Credit Transfer schemes, the two SEPA Direct Debit rulebooks (Core and Business-to-Business), and One-Leg Out Instant Credit Transfer. All of them had inherited 15 November 2026 as the point at which the fully unstructured address format would drop out of the scheme. That point has moved, with no successor date attached yet.

The EPC has reaffirmed its commitment to structured addresses. EPC Director General Giorgio Andreoli framed the vote as a conscious decision to move the date while keeping the destination, stating that the implementation timeline is being delayed but the direction of travel remains unchanged. The rulebooks continue to steer participants toward structured data, and the EPC still recommends moving customers directly to the fully structured format wherever possible.

Structured, hybrid and unstructured are not interchangeable end states

The 2025 rulebooks already support both hybrid and fully structured address formats, so the delay extends the window in which three formats coexist. A hybrid address keeps some free-text address lines alongside mandatory structured elements such as town name and country; a fully structured address carries each component in its own field. The EPC’s stated preference is the fully structured form, because it is the format that reduces sanctions-screening false positives, improves reconciliation and raises straight-through processing rates.

The EPC recommends that participants move directly from unstructured to fully structured addresses where possible, but its current address-format guidance does not set an end date for the hybrid format. The CPMI harmonised data requirements likewise encourage alignment by the end of 2027 while allowing additional postal-address information to remain in free-formatted Address Line fields where necessary. Firms should therefore distinguish the EPC’s preference for fully structured data from any binding requirement to eliminate hybrid addresses.

Why the date moved, and what else moves with it

The EPC tied the decision to readiness signals from PSP participants, clearing and settlement mechanisms and technical players, and to the state of the wider ecosystem. That ecosystem is realigning in the same direction at the same time. The Eurosystem has now decided to proceed with the November 2026 TARGET Services releases, shifting deployment from 14 to 28 November 2026. It will introduce a temporary measure in T2 allowing fully unstructured postal addresses in T2 RTGS messages for a limited period, while participants are expected to continue implementing structured or hybrid addresses.

On 4 September 2026 the Eurosystem confirmed that fully unstructured postal addresses would remain temporarily usable in T2 RTGS messages for a limited period, alongside the 28 November TARGET Services release. Swift had already announced on 27 August 2026 that it would defer all payments changes under Standards Release 2026, including the structured-address requirement; it said the replacement timing and approach would be defined after consultation, with a further update by December 2026 at the latest. The EPC, Eurosystem and Swift remain separately governed, so each timetable must be tracked independently. For the Eurosystem strand, our summary of the November 2026 TARGET Services reassessment and of the CPMI harmonised ISO 20022 data requirements sets out the adjacent detail.

Keeping the SEPA structured address migration on plan

The EPC has been explicit that the delay is an invitation to continue, not to pause. It strongly encourages participants to maintain their current implementation plans, and to step up support for customers moving from unstructured to preferably fully structured addresses. In practice that separates outbound work from inbound work. Outbound migration to structured data can and, on the EPC’s recommendation, should continue on plan; the benefits accrue whether or not a hard deadline exists.

Inbound handling is where the extended window bites. Because counterparties may keep sending unstructured or hybrid addresses past 15 November 2026, receiving systems and validation rules cannot be switched to structured-only on the old date without risking rejected payments. Firms that had scheduled a clean cut-over should hold that step until the revised rulebooks confirm a new end date. The document to watch is the revised 2025 rulebook package due by October 2026, which will carry both the operative date and the format rules for any rebuilt go-plan.

Frequently Asked Questions

Does the EPC delay also move the November 2026 milestones on the Swift network or in TARGET Services?

No. Those are separate programmes with their own governance. The PSMB decision covers only the EPC scheme rulebooks. Swift deferred its Standards Release 2026 payments changes on 27 August 2026, and the Eurosystem confirmed on 4 September 2026 that it would proceed with the TARGET Services release at 28 November 2026, with a temporary measure allowing fully unstructured addresses in T2 RTGS messages. Each infrastructure publishes its own timeline; check each one directly.

We have already switched to fully structured addresses. Does the delay require us to reverse anything?

No. The rulebooks continue to support fully structured addresses, which is the EPC’s preferred end state, so the delay provides no reason in itself to reverse a completed move to fully structured addresses. It does extend the period during which systems may need to accept unstructured and hybrid addresses; any additional implementation impacts should be assessed against the revised EPC documentation and the independently governed Swift and TARGET changes.

Does this change any obligations under the Instant Payments Regulation or Verification of Payee?

No. The address-format end date is a scheme-rulebook matter and is distinct from statutory instruments. Obligations under the SEPA Instant Payments Regulation and the timelines for EPC Verification of Payee are governed separately and are not affected by the PSMB decision on unstructured addresses.

Key Takeaways

  • 15 November 2026 is no longer a binding end date for unstructured SEPA addresses; treat any internal cut-over milestone anchored to it as provisional.
  • The new end date will come from the PSMB’s October 2026 meeting and the revised 2025 rulebooks and implementation guidelines, expected by October 2026 at the latest.
  • Keep receiving systems and validation rules able to accept unstructured and hybrid addresses past November 2026, because counterparties may still send them.
  • Continue outbound migration to fully structured addresses on plan; it is the EPC’s recommended end state and the format that improves screening and straight-through processing.
  • Prefer fully structured addresses where feasible, as the EPC recommends, but do not treat hybrid as subject to a confirmed sunset: the current EPC guidance sets no end date for hybrid, and the CPMI’s end-2027 alignment objective permits free-formatted Address Line information where necessary.
  • Track the Swift CBPR+ and Eurosystem TARGET Services positions independently: Swift has deferred its Standards Release 2026 payments changes, while the Eurosystem has shifted the TARGET Services release to 28 November 2026 and will temporarily continue allowing fully unstructured postal addresses in T2 RTGS messages.

Sources and References

  • European Payments Council, “EPC delays address format migration timeline” (10 September 2026): europeanpaymentscouncil.eu
  • European Payments Council, “November 2026 end-date of the unstructured address format for EPC payment scheme transactions”: europeanpaymentscouncil.eu
  • European Payments Council, “What is a payment scheme?” (the five EPC payment schemes): europeanpaymentscouncil.eu
  • ECB / Eurosystem, MIP News: “November 2026 TARGET Services releases” (4 September 2026): ecb.europa.eu
  • ECB / Eurosystem, T2 Change Request T2-0188-SYS, “Allow fully unstructured postal address format in RTGS messages” (3 September 2026): ecb.europa.eu (PDF)
  • CPMI / BIS, “Harmonised ISO 20022 data requirements for enhancing cross-border payments” (updated report, 26 February 2026): bis.org (PDF)
  • Swift, “Swift accepts community request to extend structured address migration for ISO 20022 payment messages” (27 August 2026): swift.com

What to lock in before the October update

The next hard fact arrives with the revised 2025 rulebooks and implementation guidelines, due by October 2026, and with whatever new end date the PSMB sets that month. Until that documentation names a date, the structured address programme runs without a fixed finish line: outbound migration to fully structured addresses continues as the EPC recommends, inbound acceptance of unstructured and hybrid data stays switched on, and the clean cut-over waits for a calendar the EPC has yet to publish.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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