Riksbank Starts T2S Negotiations: What SEK Securities Settlement on the Eurosystem Platform Means for Swedish Banks and Cross-Border Reporting

ByOfficer

Last updated: June 2026

A platform migration in securities settlement is the kind of project that looks like an IT problem until the first cross-border trade fails on a date nobody mapped. On 23 June 2026 the Riksbank decided to open contract negotiations with the Eurosystem to settle Swedish krona securities transactions on TARGET2-Securities, the common Eurosystem platform that already settles in euro and Danish kroner. For Swedish banks, custodians and the desks that book cross-border settlement, the Riksbank T2S decision is the moment to stop treating a 2030 migration as a far horizon and start mapping how settlement instructions, collateral movements and CSDR settlement-fails reporting change when SEK settlement leaves the current domestic system and lands on a Eurosystem rail.

The decision itself is narrow. It authorises the Head of the Payments Department to negotiate, nothing more. The operational weight sits behind it. Euroclear Sweden has pulled its harmonisation and transition work forward to September 2030, the Riksbank is targeting a Currency Participation Agreement signature around October 2027, and the legal questions around settlement finality, confidentiality and account-management law are still open. Reporting teams who wait for a signed agreement before they look at the change will be doing impact analysis under a fixed go-live date instead of ahead of one.

This article walks through what the Riksbank actually decided, how the T2S contract structure works for a non-euro central bank, why the change touches CSDR reporting rather than creating a new return, and where Swedish institutions tend to underestimate the work. It is written for reporting and settlement practitioners, not for the project board.

Related reading: ECB TARGET Services Annual Report 2025

What the Riksbank decided on 23 June 2026

The Executive Board took a two-line decision. First, contractual negotiations will be initiated with the Eurosystem to enable the settlement of securities transactions in Swedish kronor on the TARGET2-Securities platform. Second, the Board authorised the Head of the Payments Department to conduct those negotiations. The decision carries the reference DNR 2026-01008 and was taken by Governor Erik Thedeen, First Deputy Governor Aino Bunge and Deputy Governor Per Jansson.

The legal basis the Riksbank cites is its mandate to promote a well-functioning payment system, which it reads as including safe and efficient systems for settling payments and securities transactions in central bank money. The Sveriges Riksbank Act (2022:1568) lets the Riksbank participate in settlement, payment and clearing systems within the European Economic Area. Settlement in central bank money is the point that matters for risk: when both the cash and the securities legs settle across a central bank rather than a commercial counterparty, the participants are not exposed to a private settlement agent failing mid-chain.

One detail teams skip on a first read. This is a decision to negotiate, not a decision to join. The Riksbank’s own analysis flags that the future negotiations must safeguard the bank’s interests and ensure compatibility with Swedish national legislation, and that some legal issues remain open. A negotiation mandate is not a signed Currency Participation Agreement, and the article numbers, finality rules and go-live date that reporting teams need will firm up through that negotiation, not before it.

What Riksbank T2S negotiations mean for a non-euro central bank

TARGET2-Securities is the Eurosystem’s technical platform on which connected central securities depositories perform their securities settlement, meaning the process of finalising a purchase or sale by transferring both the money and the ownership of a security between the parties. It has been in operation since 2015 and is currently used by 24 connected CSDs from 23 different countries. The platform is one of the four TARGET services, alongside T2 for payment settlement, TIPS for instant payments and ECMS for collateral management, and it is built, developed and operated by the four largest Eurosystem central banks, the Bundesbank, Banca d’Italia, Banque de France and Banco de Espana, known as the 4CB.

Here is the constraint that forces a negotiation. T2S currently settles securities in euro or in Danish kroner only, even though the platform is designed to handle more currencies. A national central bank in the EEA that does not have the euro can still use T2S by providing central bank money for settlement, but only if it enters into an agreement with the Eurosystem. That agreement is the Currency Participation Agreement, set out under Article 18 of the ECB’s T2S Guideline (ECB/2012/13 of 18 July 2012), and its use requires approval by the ECB’s Governing Council. The Swedish krona is not on the platform today, so the Riksbank cannot simply opt in. It has to put SEK central bank money onto the platform through a CPA, and Euroclear Sweden separately has to connect as a CSD.

A point that gets lost in the harmonisation language. A CSD joining T2S outsources part of its operations to the Eurosystem, and the Riksbank’s analysis is explicit that this differs from ordinary outsourcing, because a CSD does not have the same ability to impose requirements on T2S that it would on a commercial IT provider. The platform sets the standards. Swedish participants adapt to T2S, not the other way round, and that is the real source of the harmonisation work Euroclear Sweden has scheduled.

The contract structure: CPA, Collective Agreement and the agreements you do not sign

The legal architecture is layered, and confusing the layers leads to the wrong people tracking the wrong document. The basic legal act governing T2S is the ECB T2S Guideline. On top of it sit several agreements, and they do not all involve the same parties.

The Currency Participation Agreement is concluded between the Riksbank and the Eurosystem central banks. It sets out the mutual obligations and rights for using T2S and for providing settlement accounts in Swedish kronor. The Collective Agreement is a multilateral agreement between the Eurosystem central banks, the connecting central bank and the CSDs participating in T2S, and it regulates the moment at which a transfer order becomes irrevocable and final, the finality questions that matter most for legal risk. The Riksbank needs both.

The agreements the Riksbank does not sign matter too, because they shape who carries which liability. There is a cooperation agreement on supervisory cooperation between the Eurosystem central banks, supervisory authorities and CSDs, which, according to information from the ECB, the Riksbank will not sign. There is also a framework agreement between the Eurosystem central banks and the CSD concerned, to which the Riksbank is not a party. Euroclear Sweden joins through that framework agreement. So the central bank and the CSD enter T2S through different doors, and a reporting team that assumes a single all-in contract will misread where its obligations actually come from.

The Riksbank notes that these agreements follow an established template but that specific exceptions or alternative wording can be agreed where Swedish law requires it. That is where the open legal issues get resolved, and it is why the precise finality and confidentiality terms are not yet fixed.

The timeline practitioners should plan against

The dates are firmer than the headline decision suggests, and they are the part worth pinning to a project plan. The Riksbank has assumed since a September 2021 orientation decision that T2S would be used in future to make Swedish kronor available for securities settlement, and it confirmed that direction in a June 2024 study. The original sequencing was to migrate to T2S only after the T2 migration was complete, which implied preparations around 2030 and a transition around 2035.

That timetable has moved. In 2025, Euroclear Sweden communicated that it wishes to consolidate its harmonisation work and bring the T2S transition forward to September 2030, because it identified synergies in combining already-planned harmonisation work with the T2S transition and reducing costs for all actors. The Riksbank therefore began the activities needed to start contract negotiations in 2026. Because the Eurosystem prefers agreements signed in October, the Riksbank’s stated ambition is to sign the CPA and the Collective Agreement by October 2027. In the second half of 2026 the Riksbank intends to start the technical preparations as an implementation project, and the Executive Board intends to decide on the budget and timetable for that project before the end of 2026.

Where teams misjudge the lead time. The 2030 go-live is set by Euroclear Sweden’s harmonisation schedule, not by the central bank, and the harmonisation work involves changes to specific post-trade processes that are prerequisites for joining T2S. Those process changes hit participants, not only the CSD. Treating September 2030 as the date you start adapting, rather than the date you must be done, is the planning error this kind of migration punishes.

Euroclear Sweden, the VPC system and the single-CSD reality

Sweden has one CSD. Euroclear Sweden AB has been the country’s central securities depository since 1971, has been part of the group owned by the Belgian company Euroclear SA/NV since 2008, and is authorised as a central securities depository under the Central Securities Depositories Regulation, Regulation (EU) No 909/2014 (CSDR). Its activities are supervised by Finansinspektionen and overseen by the Riksbank. Today Euroclear Sweden runs an approved settlement system under the Swedish Settlement Act, known as the VPC system, and account management and securities settlement currently take place within it.

That single-CSD structure is why the Riksbank frames the change around competition neutrality. At present only Euroclear Sweden has access to central bank money in Swedish kronor for securities settlement, because it is the only CSD. The Riksbank’s position is that access to central bank money in kronor should be offered in a competition-neutral manner to any CSD that meets the CSDR requirements. Putting SEK onto T2S is the mechanism that makes that neutrality possible, because the platform is shared and any qualifying CSD could in principle settle SEK there rather than only the incumbent.

A practical consequence reporting teams should sit with. When settlement migrates from the VPC system to T2S, the holdings recorded on a securities account at Euroclear Sweden have to be moved to, or at least reflected on, the T2S platform, while each security and securities account in T2S remains linked to a CSD that stays responsible for those accounts. T2S is not itself a CSD. So the legal owner of the account relationship does not change, but the settlement venue and the instruction interfaces do, and that distinction governs which of your reconciliations and reports need rework.

Why this is a CSDR reporting change, not a new return

The most common misreading is that joining T2S creates a new reporting obligation. The reporting framework is CSDR, and it already applies to Euroclear Sweden as an authorised CSD. What a platform migration changes is the data, the instruction flow and the settlement-fails picture that feed the existing CSDR settlement-discipline reporting, not the existence of the obligation.

Under CSDR, settlement discipline is governed by the Regulatory Technical Standards in Commission Delegated Regulation (EU) 2018/1229 of 25 May 2018, which supplements Regulation (EU) No 909/2014. Those RTS require CSDs to operate a system that monitors the number and value of settlement fails for every intended settlement date, including the length of each fail in business days, and to report that information to their competent authority and relevant authorities. The cash penalty mechanism for late settlement sits in Article 7 of CSDR, and the penalty modalities are in the RTS. For Swedish banks, custodians and settlement participants, the practical question is whether the settlement instructions, fail reasons, cash penalties and reconciliation data they provide to the CSD still reconcile once SEK instructions route through T2S. EMIR transaction reporting remains a separate post-trade regime and should not be treated as the reporting channel for CSDR settlement-discipline data.

The regime is also moving on its own track, independent of Sweden. ESMA’s 13 October 2025 Final Report on amendments to the CSDR RTS on settlement discipline, which follows the CSDR Refit (Regulation (EU) 2023/2845 of 13 December 2023), proposes further changes to settlement-fails reporting and disclosure. The current Article 14 monthly reporting model already requires CSDs to report by close of business on the fifth business day of the following month and to express relevant values in EUR. ESMA’s proposed amendments would keep that monthly model, add more granular settlement-fails data such as place-of-trading and financial-instrument-type breakdowns, and remove the separate annual settlement-fails report. Swedish participants face the platform change and these CSDR data changes in overlapping windows, so they should be scoped together rather than sequentially.

Central bank money settlement and what it does to collateral and monetary-policy plumbing

The reason a central bank involves itself in securities settlement at all is to let the cash leg settle in central bank money, which reduces the risk that a settlement agent fails between the parties. On T2S, affiliated CSDs settle on a delivery-versus-payment basis against central bank money, and the platform supports functionality such as auto-collateralisation that lets participants raise intraday liquidity against securities. For Swedish participants used to the domestic arrangement, the cash-side mechanics and intraday liquidity management change shape even though the regulatory category, settlement in central bank money, stays the same.

The Riksbank’s own operations are affected, which is a useful signal of how deep the change runs. Its 2024 study found that monetary-policy transactions such as the issuance of Riksbank Certificates, purchases and sales of securities and repurchase agreements can be carried out on T2S, but only with changes to technical systems, because the processes, logic and interfaces differ from those at the Riksbank today. It also examined how pledging collateral for credit at the Riksbank is affected. If the central bank has to rebuild interfaces for its own securities operations, treasury and collateral desks at participant banks should assume their own collateral-mobilisation and repo workflows will need similar attention well before go-live.

Where the assumption goes wrong. Treating T2S as a settlement venue swap, with collateral management untouched, misses that collateral mobility is one of the explicit benefits the Riksbank is pursuing. The 2021 analysis listed easier movement of securities between CSDs and improved liquidity and collateral management as core arguments for joining. That benefit only materialises if participant collateral and liquidity processes are re-engineered to use it, which is work, not a default.

Governance: where a non-euro central bank sits, and why it matters for change control

Governance sounds like a head-office topic, but it determines how much warning participants get about platform changes that drive reporting reworks. T2S governance has three levels. The decision-making level is the ECB’s Governing Council, comprising the ECB, the 4CB and the other euro-area central banks. The governing level holds the technical and operational management bodies. The provision level is the 4CB that operate the platform. Because Sweden is outside the euro area, the Riksbank does not sit on the Governing Council.

What changes the Riksbank’s seat at the table is a recent amendment to the Market Infrastructure Board, the body responsible for the day-to-day operation of all TARGET platforms and for Eurosystem market-infrastructure projects. The Governing Council adopted a revised MIB mandate on 19 December 2025 through Decision (EU) 2026/77, which was published in the Official Journal on 9 January 2026 and entered into force on the twentieth day following publication. The revised composition gives one MIB member seat to each non-euro area NCB that has signed at least one Currency Participation Agreement, with two of those members having voting rights. Non-euro central banks also coordinate through the Non-Euro Currencies Steering Group, which can escalate issues to the Governing Council where necessary. Euroclear Sweden, for its part, can participate in the T2S CSD Steering Group.

The practitioner reading. MIB membership is the channel through which the Riksbank can follow and influence platform changes, including the operational changes that ripple into participant reporting. It does not give Swedish participants a direct vote, but it is the reason a future T2S release that alters instruction formats or fails data should reach the Swedish market through a governance route rather than as a surprise. Reporting teams should know which domestic forum carries platform-change notices, because that is where the early warning for a reporting rework will surface.

The open legal issues that can still move the design

Several legal questions are settled, and several are not, and the unsettled ones are the ones that can change finality timing or data flows late in the project. The Riksbank treats the legal basis itself as settled. It has the authority to enter agreements to use T2S, the agreements are not of a public-law nature that would trigger the Instrument of Government’s rules on international agreements, and the Public Procurement Act exemption for services performed by central banks applies. Those are not where the risk sits.

The work that remains concerns finality and account-management law. A cluster of questions arises about the relationship between the T2S framework and the Swedish Central Securities Depositories and Accounting of Financial Instruments Act (1998:1479), tied to settlement finality, which the Settlement Act and the Financial Instruments Trading Act (1991:980) implement from the Settlement Finality Directive (Directive 98/26/EC). A government inquiry, the Account Management Inquiry (SOU 2023:102), concluded that the Swedish account-management system can be maintained alongside T2S with only a minor legislative amendment on communication between T2S and the VPC system, and that no legislative change is required for Euroclear Sweden to join the framework agreement. There are also open points on confidentiality under the Public Access to Information and Secrecy Act (2009:400) and on joint data-protection responsibility under the GDPR.

The moving piece worth watching. The Riksbank is explicit that a comprehensive EU legislative package, the Savings and Investment Union, is being negotiated and affects the securities market, including proposals to replace the Settlement Finality Directive with a Regulation and to amend the CSDR. If those EU instruments change finality rules or CSDR requirements during the Swedish T2S build, the settlement and reporting design can shift under the project. The right response is to build with the EU pipeline in view rather than freezing a design against today’s CSDR text alone, and to keep the analysis moving rather than wait for the EU package to land.

Frequently Asked Questions

Did the Riksbank decide to join T2S on 23 June 2026?

No. The 23 June 2026 decision authorises contract negotiations with the Eurosystem and mandates the Head of the Payments Department to conduct them. It is a decision to negotiate, not a decision to join. Accession depends on signing the Currency Participation Agreement and the Collective Agreement, which the Riksbank is targeting for around October 2027, and on a separate Executive Board decision to sign.

When would Swedish krona securities settlement actually move to T2S?

Euroclear Sweden has communicated that it wants to bring the transition forward to September 2030, consolidating it with already-planned harmonisation work. The Riksbank intends to start technical preparations in the second half of 2026 and to decide on the project budget and timetable before the end of 2026. The 2030 date is set by the CSD’s harmonisation schedule, earlier than the around-2035 horizon in the original sequencing.

Does joining T2S create a new reporting obligation for Swedish banks?

It does not create a new return. CSDR already applies to Euroclear Sweden as an authorised CSD, including settlement-discipline monitoring and settlement-fails reporting under Commission Delegated Regulation (EU) 2018/1229. What changes is the settlement venue, the instruction flow and the fails data feeding that existing reporting, so the work is reconciliation and data-mapping rather than a brand-new obligation.

What is a Currency Participation Agreement?

It is the agreement under Article 18 of the ECB T2S Guideline (ECB/2012/13) that a non-euro EEA national central bank must conclude with the Eurosystem to make its currency available for settlement on T2S, subject to Governing Council approval. The Riksbank needs a CPA to provide Swedish kronor in central bank money for settlement on the platform.

Will the cash leg still settle in central bank money?

Yes. The point of the Riksbank’s involvement is to provide central bank money for the cash leg, settling securities on a delivery-versus-payment basis against the central bank rather than a commercial agent. The regulatory category does not change, but the cash-side mechanics, intraday liquidity and collateral functionality such as auto-collateralisation differ from the current domestic arrangement.

How does T2S governance affect Swedish participants?

The Riksbank does not sit on the ECB Governing Council because Sweden is outside the euro area, but the revised Market Infrastructure Board mandate in Decision (EU) 2026/77 gives one MIB member seat to each non-euro area NCB that has signed at least one Currency Participation Agreement, with two of those members having voting rights. That membership is how the Riksbank follows and influences platform changes, which is the route by which operational changes that affect participant reporting reach the Swedish market.

How much will accession cost, and who pays?

The Riksbank’s costs for accession were previously estimated at around SEK 95 million, with the part attributable to RIX charged to RIX Participants under the Riksbank’s full cost recovery principle. The Riksbank has said that assumptions on timetable, organisation and scope have changed, so the previous estimate is uncertain and will be revised.

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Key Takeaways

  • The Riksbank’s 23 June 2026 decision (DNR 2026-01008) authorises contract negotiations with the Eurosystem to settle Swedish krona securities transactions on TARGET2-Securities. It is a decision to negotiate, not to join.
  • As a non-euro EEA central bank, the Riksbank must conclude a Currency Participation Agreement under Article 18 of the ECB T2S Guideline (ECB/2012/13), plus a Collective Agreement on finality, with Governing Council approval. The CPA target is around October 2027.
  • Euroclear Sweden has brought the transition forward to September 2030, earlier than the original around-2035 horizon, and the go-live date is driven by the CSD’s harmonisation schedule, which changes post-trade processes for participants, not only the CSD.
  • Joining T2S does not create a new return. CSDR already applies to Euroclear Sweden, so the change is to the settlement venue, instruction flow and settlement-fails data feeding existing reporting under Commission Delegated Regulation (EU) 2018/1229.
  • The CSDR settlement-discipline data model is itself changing through the CSDR Refit (Regulation (EU) 2023/2845) and ESMA’s 13 October 2025 Final Report on amendments to the RTS on settlement discipline, so Swedish participants face platform and CSDR data changes in overlapping windows.
  • Settlement stays in central bank money, but cash-side mechanics, intraday liquidity and collateral functionality such as auto-collateralisation differ from the current domestic arrangement, and collateral and repo workflows will need rework to capture the mobility benefit.
  • Open legal issues on settlement finality, the Account Management Act (1998:1479), confidentiality and joint GDPR responsibility remain, and the EU Savings and Investment Union package, including a proposed Settlement Finality Regulation and CSDR amendments, may move the design during the build.

Sources and References

  • Sveriges Riksbank, Decision: Contract negotiation for the T2S platform, DNR 2026-01008, 23 June 2026 – riksbank.se (PDF)
  • Sveriges Riksbank, Memorandum: In-depth analysis of the T2S platform, Ref. no. 2026-00818, 23 June 2026 – riksbank.se (PDF)
  • Sveriges Riksbank, notice: The Riksbank starts negotiations on T2S – riksbank.se
  • Guideline of the European Central Bank of 18 July 2012 on TARGET2-Securities (recast) (ECB/2012/13), Article 18 – EUR-Lex (CELEX 32012O0013)
  • Regulation (EU) No 909/2014 on improving securities settlement in the European Union and on central securities depositories (CSDR) – EUR-Lex (CELEX 32014R0909)
  • Commission Delegated Regulation (EU) 2018/1229 of 25 May 2018 (RTS on settlement discipline), supplementing CSDR – EUR-Lex (CELEX 32018R1229)
  • Regulation (EU) 2023/2845 of 13 December 2023 (CSDR Refit) – EUR-Lex (CELEX 32023R2845)
  • ESMA, Final Report – CSDR RTS on Settlement Discipline and tools to improve settlement efficiency (ESMA74-2119945926-3430), 13 October 2025 – esma.europa.eu (PDF)
  • Directive 98/26/EC of 19 May 1998 on settlement finality in payment and securities settlement systems – EUR-Lex (CELEX 31998L0026)
  • Decision (EU) 2026/77 of the European Central Bank of 19 December 2025 amending Decision (EU) 2019/166 on the Market Infrastructure Board (ECB/2019/3) (ECB/2025/43) – EUR-Lex

How Swedish reporting teams should use the negotiation window

The negotiation that opened on 23 June 2026 runs toward a CPA signature around October 2027 and a transition in September 2030, and the gap between those dates is the planning window, not the waiting room. The smart use of it is to scope the platform migration and the CSDR settlement-discipline reporting changes as one programme, because the data, instruction formats and fails picture they both touch are the same data. The institutions that come out of this cleanly will be the ones that mapped, well before the agreements are signed, exactly which reconciliations, settlement instructions and settlement-fails reports change when SEK settlement moves onto a Eurosystem rail.

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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