CSDR Messaging Protocols Guidelines: Oral and Domestic Routes Close

ESMA published its final report on the revised CSDR messaging protocols guidelines on 16 October 2026 (ESMA74-2119945926-3749), two days after Commission Delegated Regulation (EU) 2026/1536 appeared in the Official Journal. The formal title is the guidelines on standardised procedures and messaging protocols used between investment firms and their professional clients. From 7 December 2026, the amended Article 2 of the RTS on settlement discipline requires professional clients, where written allocations and confirmations are sent, to ensure that they reach the investment firm as soon as possible and no later than 23:00 CET on trade date, and requires firms to have them sent through an electronic standardised communication method that software can read, using the international open communication procedures and standards defined in Article 2(1)(34) of CSDR. The revised guidelines apply from the same day and set out how ESMA expects firms and national supervisors to read those requirements.

The edits close three routes the 2019 guidelines left open: settlement information given orally, internal or domestic messaging standards chosen by the client, and the general acceptance of mail, fax or any electronic means as a normal channel. What stays open is wider than the May 2026 consultation draft suggested. Email and graphical user interfaces (GUIs) are named as examples of compliant channels when the content is machine-readable, manual entry into a GUI can serve low-volume clients and smaller firms, and the parties decide for themselves what follows when an allocation arrives late or in the wrong format.

Timing is the pressure point. ESMA cites the EU T+1 Industry Committee’s first readiness survey, in which 56% of respondents could be late in issuing allocations and confirmations on trade date by the end of 2026, and it refused requests for a transition period running to the end of March 2027.

Related reading: ESMA T+1 Settlement: Allocations and Confirmations

Dates that drive the CSDR messaging protocols change

The guidelines sit in a sequence of Level 1, Level 2 and Level 3 texts that the EU co-legislators, the Commission and ESMA have adopted or published since 2019. The operative dates for investment firms and their professional clients are these.

Two clocks in that sequence are easy to merge. ESMA states that the guidelines will be published on its website after translation into all EU languages and will become applicable on 7 December 2026, the date written into their scope section. The comply-or-explain clock runs separately: within two months of that multilingual publication, each national competent authority has to notify ESMA whether it complies, does not comply but intends to, or does not comply and does not intend to, giving reasons in case of non-compliance. Investment firms are not required to report whether they comply.

From Article 6(2) to the RTS: the rules the guidelines interpret

Article 6(2) of CSDR (Regulation (EU) No 909/2014) has three layers. Its first subparagraph requires investment firms authorised under Article 5 of MiFID II to take measures, where applicable, to limit the number of settlement fails. The second requires those measures to include arrangements with professional clients for the prompt communication of an allocation of securities to the transaction, confirmation of that allocation and confirmation of acceptance or rejection of the terms in good time before the intended settlement date. The third tells ESMA, in close cooperation with members of the European System of Central Banks, to issue guidelines under Article 16 of the ESMA Regulation on the standardised procedures and messaging protocols to be used for complying with the second subparagraph.

The detail sits in Articles 2 (professional clients) and 3 (retail clients) of Commission Delegated Regulation (EU) 2018/1229. CSDR Refit, Regulation (EU) 2023/2845, amended Article 6(5) of CSDR and required ESMA to revise those settlement discipline measures. ESMA delivered its draft on 13 October 2025, the Commission adopted Delegated Regulation (EU) 2026/1536 on 6 July 2026, and the deadline changes below apply from 7 December 2026.

The amended Article 2(1) adds the format and standards layer. Written allocations and confirmations have to use an electronic standardised communication method structured so that software applications can easily identify, recognise and extract specific data. Unstructured methods are permitted only during temporary technical unavailability or service disruption that is duly documented and resolved without undue delay. Investment firms have to require their professional clients to use the international open communication procedures and standards referred to in Article 2(1)(34) of CSDR, and to apply the relevant CSD’s cash tolerance levels when reporting the cash amount. Article 2(3) adds that clients provide all reference data needed to settle in a standardised, machine-readable electronic format and keep it updated sufficiently in advance.

The guidelines stay inside those limits. When respondents asked for flexibility for smaller firms, lower-volume relationships or local arrangements, ESMA replied that the guidelines only clarify how to comply with Article 6(2), that the revised Article 2(1) foresees no exception, and that guidelines are therefore not the instrument for obtaining one. It also refused to swap “international open communication procedures and standards” for “industry-recognised” standards, because guidelines cannot amend Level 1 and Level 2 terminology. Requests to define “allocation”, “confirmation” and “trade confirmation” met the same wall: those are Level 1 concepts, and ESMA points to Article 16b(5) of the ESMA Regulation, under which questions requiring interpretation of Union law go to the Commission.

Seven edits to the 2019 guidelines, side by side

ESMA amended only a subset of the original guidelines. Guideline 2, which fixes the instrument scope by reference to Article 5(1) of CSDR, is unchanged. The specific guidelines amended by the final report are repealed when the revised versions take effect, and Annex IV of the report consolidates the full text.

One numbering point catches cross-references. The new paragraph 19 carries the international-standards rule, while paragraph 19 of the 2019 text was the framework-agreement sentence, so an internal procedure that cites “paragraph 19” of the guidelines points to different content after 7 December 2026.

Guideline 1: any legally binding form, with no grandfathering

Guideline 1 keeps its opening rule: investment firms should ensure that the Article 6(2) requirements are complied with by them and their professional clients, considering their roles in each securities transaction. The revised text now ties “professional client” to point (10) of Article 4(1) of MiFID II and adds that the parties should contractually agree the arrangements, which may be documented in any legally binding form.

ESMA’s assessment goes further than the guideline text. The arrangements may be documented under any agreement name, structure or format, provided they are valid and binding under the applicable law. The consultation draft had offered the MiFID II framework agreement (Article 25(5) of MiFID II, specified in Article 58 of Delegated Regulation (EU) 2017/565) as an example. The final guideline drops that reference, and ESMA says that placing the arrangements in the framework agreement would still be consistent with the guidelines; it is one possible home among others.

Respondents wanted more than flexibility of form. They asked ESMA to recognise existing service agreements and service-level agreements as sufficient without dedicated bilateral amendments, to accept platform terms, client notices and general business conditions as valid documentation, and to allow side letters or addenda instead of full renegotiation. ESMA declined to grandfather anything. It is for investment firms and professional clients to assess the impact of the amended RTS and the guidelines on their contracts, decide whether changes are needed and decide how far they go, and ESMA notes that firms may run a risk assessment for that purpose.

The phrase “any legally binding form” leaves the form of the agreement open, while its content has to deliver what the amended RTS now demands, including the 23:00 CET deadline, the machine-readable format and the international open standards. Whether a 2019-era service agreement already does that is a question each firm answers for itself, and the final report gives no presumption either way.

Guideline 3: email and GUIs qualify on structure, with a low-volume opening for manual entry

The revised Guideline 3 asks the investment firm to agree with each professional client on the electronic standardised communication methods and the international open communication procedures and standards for messaging and reference data to be used between them as a regular practice. “Contractually” has gone from this guideline. A new paragraph names emails and GUIs as non-exhaustive examples of electronic standardised methods, provided the content of the allocations and confirmations is structured so that software applications can easily identify, recognise and extract specific data.

The test therefore attaches to the content. ESMA relies on the definition of “machine-readable format” in Article 2(13) of Directive (EU) 2019/1024, which it had already used in the RTS final report and the consultation paper. On file types, the parties may agree any format that meets that definition. ESMA points to Article 7(2) of Commission Implementing Regulation (EU) 2025/1339 for non-exhaustive examples: XML, XBRL, XBRL-csv, XBRL-xml and Inline XBRL are deemed machine-readable where they are structured for software extraction. That implementing regulation deals with collection bodies under Regulation (EU) 2023/2859; ESMA borrows its list as an illustration and sets no format list specific to allocations.

One substantive movement between the consultation and the final text concerns GUIs with manual input. In May 2026, ESMA’s preliminary view was that GUIs based on manual input carried a higher risk of human error and were inconsistent with the aim of discontinuing manual processes as a regular practice. The final report accepts that GUIs involving manual intervention might be an appropriate solution for professional clients with low transaction volumes or for smaller firms, as long as the output is structured in a machine-readable format that the investment firm’s systems can process automatically. Two reasons drove the change: requiring clients to upload machine-readable files into a GUI could put an unreasonable burden on them, and the receiving firm may have no visibility of whether data was typed in or submitted through an automated interface.

ESMA sets expectations on the other side as well. Professional clients engaging in high-volume or frequent transactions are expected to limit manual intervention and base the exchange on automated solutions, and ESMA had already strongly recommended in the consultation that frequent traders use international open communication procedures and standards by default instead of email or GUIs. Technology neutrality is also conditional: ESMA describes the guidelines as technology-neutral provided the technology deployed supports electronic standardised communication methods and international open communication procedures and standards. One respondent asked for GUI data fields to be aligned with the ISO 20022 data dictionary; ESMA did not adopt any specific standard.

An email whose body sets out trade details in free text is a non-machine-readable electronic means, which Guideline 4 lists among the fallback methods for disruption cases. The example ESMA gives is narrower: an email carrying content structured so that software can extract it. Respondents also asked whether SFTP and APIs qualify, and ESMA answered with technology neutrality, without listing channels.

Oral allocations end, and bond, repo and lending desks get no carve-out

Paragraph 17 still lists three ways to organise the prompt communication of settlement information: the professional client sends both a written confirmation and a written allocation; the confirmation is included in the allocation, as Article 2(1) of the RTS permits, either in an additional field or implied by sending the allocation; or neither is sent, where the parties rely on Article 2(3) and the investment firm should ensure it receives the necessary settlement information ahead of the Article 2(2) deadlines. The final text deletes two words from the third route. The firm may still obtain the information through systems that give it access, such as a centralised database, but no longer “orally”.

That reference had a history. ESMA’s 2019 final report recorded feedback that in bond markets voice on a recorded line was widely used to give the initial allocation, followed or not by electronic confirmation. In the 2026 consultation, one respondent asked ESMA not to exclude workflows that currently operate effectively in bond, repo and securities lending markets. ESMA answered that the scope of the guidelines is defined by Article 5(1) of CSDR, which is broader than the T+1 requirement, and that it had received no quantitative evidence or clear specification of any blocking point preventing those markets from operating under the guidelines.

A scope built from the T+1 rule would drop some of these flows. Regulation (EU) 2025/2075 keeps securities financing transactions documented as single transactions consisting of two linked operations, such as buy-sell back and sell-buy back transactions, out of the T+1 rule in Article 5(2) of CSDR. Article 6(2) keeps its own perimeter: Guideline 2 still applies the requirements to transactions in the instruments listed in Article 5(1): transferable securities, money-market instruments, units in collective undertakings and emission allowances. The amended Article 2(1) of the RTS points the same way, adding buy-sell back and sell-buy back transactions to the transaction types a written allocation identifies, alongside repurchase and securities lending operations. Our SFTR reporting guide covers how those transactions are identified for transaction reporting, which is a separate regime.

Voice survives in one place only: as a recorded fallback during a disruption, under Guideline 4.

Guideline 4: what counts as a disruption, and which fallback the parties pick

The old Guideline 4 opened by saying that any communication procedure allowing written communication through mail, faxes or electronic means should be accepted. That sentence is deleted. The new Guideline 4 says the investment firm and its professional client should also agree that, in case of duly documented temporary technical unavailability or service disruption affecting either party, alternative communication methods allowing written communication of the allocations and confirmations should be accepted. Mail, faxes and other non-machine-readable electronic means are non-exhaustive examples, as agreed between the parties. In the same situations, the parties may agree on phone calls, provided they are recorded in accordance with Article 16(7) of MiFID II and Article 76 of Delegated Regulation (EU) 2017/565.

The final text also defines the trigger. A “temporary technical unavailability or service disruption” is a situation that prevents the use of communication methods from which software applications can easily identify, recognise and extract specific data. The definition turns on whether the machine-readable channel can be used; it says nothing about volume spikes or a client running late. Level 2 adds its own conditions, because the amended Article 2(1) permits unstructured methods only where the circumstances are duly documented and resolved without undue delay. The consultation paper had tied these situations to the business continuity obligations firms already carry, citing Article 16(2) of MiFID II, Article 21 of Delegated Regulation (EU) 2017/565 and Articles 10 and 11 of DORA.

Compared with the consultation draft, ESMA made the guideline less prescriptive about the agreement itself. The parties choose which alternative procedures apply, ESMA avoided an exhaustive list, and the phrase “as agreed between the investment firm and its professional client” does not prescribe how that agreement is documented. Consultation respondents asked that fallback channels not become routine alternatives, and that documentation and approval burdens during an incident be kept light. ESMA strongly recommends that the least technologically advanced options, such as postal mail or fax, be the least preferred contingencies because of the errors that manual handling brings.

A fallback clause naming fax as the first alternative is consistent with the text and inconsistent with that recommendation. The guideline itself does not rank the options.

International open standards become mandatory, and the domestic option disappears

Two paragraphs of the old Guideline 4 are deleted. Paragraph 20 required the firm, where electronic means were used, to offer its professional clients the option of international open communication procedures and standards, except where such standards were not available on a fair, open and non-discriminatory basis or did not exist, or where their use did not limit settlement fails and that could be evidenced. Paragraph 21 let the client choose between international and internal or domestic standards when the firm offered both. The replacement, a new paragraph 19, says investment firms should ensure that their professional clients use international open communication procedures and standards for messaging and reference data as defined in Article 2(1)(34) of CSDR.

That definition covers internationally accepted standards for communication procedures, such as standardised messaging formats and data representation, which are available on a fair, open and non-discriminatory basis to any interested party. ESMA leaves the choice of standard to the market. It repeats the view from paragraph 90 of its RTS final report that identifying a specific industry standard for allocations and confirmations does not seem necessary at this stage, accepts any international open standard that meets the definition, and notes that it may reconsider after the transition to T+1. For the market-infrastructure side of the messaging question, see our note on the TARGET Services June 2027 release and Swift ISO 20022.

Four respondents opposed deleting the domestic option. Their arguments ranged from different levels of operational maturity and local standards linked to national obligations to the continued use of ISO 15022, proprietary formats and platform solutions by some counterparties. ESMA held that domestic standards are in inherent conflict with the new Article 2(1) and that only international open standards meeting the Article 2(1)(34) definition comply with the RTS.

One question the report leaves without a direct answer is whether internal systems that map reliably into the required international standards remain usable; ESMA says the remaining requests were addressed elsewhere in the report. In an adjacent provision ESMA has taken a strict line: its CSDR Q&A on Article 35, which governs CSDs’ own communication with participants and market infrastructures, states that, as a principle and subject to two evidenced exceptions, other standards such as internal or domestic ones would not fulfil that article even with a mapping to international ones. That answer concerns CSDs, and the revised guidelines do not import it.

Paragraph 18: late, malformed or missing allocations stay a bilateral matter

Paragraph 18 records that CSDR and the RTS do not address the consequences of three failures: late communication of the written allocation and confirmation, failure to communicate in the agreed format and by the agreed method, and failure to communicate them at all. The consequences could be addressed by the investment firm and the professional client in their agreement. The consultation proposed removing “contractual” from that sentence and the final text does so; it also adds the middle limb on format and method, answering respondents who asked how an allocation sent on time in the wrong format should be treated.

ESMA leaves that answer to the parties. It says it has no mandate to harmonise the handling of delayed or failed communications, and that counterparties should keep the flexibility to deal with a delayed, incorrect or failed communication in the way that suits their business, operating model and operational risk framework.

ESMA reads “could be addressed” as permissive: the revised guideline does not prescribe whether the consequences should be pre-determined or written into a contract, so the parties may include them or leave them out. One respondent argued that requiring every communication failure to be addressed in client agreements would mean amending many contracts; ESMA’s reply was that no such requirement exists. ESMA frames the parties’ flexibility as without prejudice to compliance with the RTS and CSDR, so the 23:00 CET deadline and the prescribed format apply whatever the agreement says about consequences.

The allocation message itself: PSET, matching fields and reference data

The field list for written allocations lives in Article 2(1) of the RTS, and the guidelines do not repeat it. ESMA’s final report on the guidelines reminds market participants that, under the amended Article 2(1), the place of settlement (PSET) and additional transaction details become compulsory fields in written allocations from December 2026, and that the fields required in written allocations will be aligned with the settlement instruction matching fields from the same date.

Three other Level 2 points travel with the format rules. The transaction type in a written allocation now includes buy-sell back and sell-buy back transactions. The cash amount has to reflect the cash tolerance levels set by the relevant CSD under Article 6 of the RTS. Reference data needed to settle has to be provided in a standardised, machine-readable electronic format and kept updated sufficiently in advance to ensure timely settlement.

Teams that scope the 7 December build from the guidelines alone will miss these fields, because the guidelines govern procedures and messaging protocols and leave content to the RTS. The new timing rule for sending settlement instructions to the securities settlement system (as soon as possible and, where feasible, by 23:59 CET on trade date) belongs to a later tranche: ESMA proposed 11 October 2027 for it, and the final report on the guidelines states that the amending regulation introduced a phased timeline in line with ESMA’s proposal.

Why ESMA held 7 December 2026 and refused a transition to March 2027

Thirteen of eighteen respondents to the application-date question agreed with 7 December 2026. Three asked for a transitional period between December 2026 and the end of March 2027, citing contract amendments, IT work and the move to international standards, and pointing to the EU-UK-CH T+1 testing plan published in March 2026, whose first EU testing window opens in April 2027.

ESMA kept the date for three stated reasons. The RTS provisions apply on 7 December 2026 whatever happens to the guidelines, so delaying the guidelines could be read as an implicit delay of the RTS and confuse the market. Any delay to the RTS provisions could indirectly affect the T+1 transition. Neither the amended RTS nor Article 6(2) of CSDR provides for such a period, so granting one is beyond the scope of guidelines. ESMA added that EU institutions and the EU T+1 Industry Committee have communicated the coming requirements since 2024. Our article on EU T+1 settlement deadlines sets the 7 December milestone against the wider 2027 transition.

The status of the two instruments differs. Delegated Regulation (EU) 2026/1536 is directly applicable in all Member States. The guidelines are issued under Article 16 of the ESMA Regulation, so under Article 16(3) competent authorities and financial market participants must make every effort to comply, and competent authorities that comply should incorporate them into their national legal or supervisory frameworks and ensure through supervision that firms follow them. The guidelines address investment firms and the competent authorities that supervise them under MiFID II; UK firms preparing for T+1 work under UK rules, covered in our note on UK T+1 settlement readiness.

Frequently Asked Questions

We categorise a client as an eligible counterparty. Is it inside the Article 6(2) arrangements?

It can be. Paragraph 16 of the guidelines, unchanged in the revision, says an entity on the list in Section I of Annex II to MiFID II should be considered a professional client for Article 6(2) purposes, irrespective of whether the firm has categorised it as an eligible counterparty under Article 30(2) of MiFID II or as a non-professional client, generally or for specific transactions or services. A population filter built only on the MiFID II client category would therefore miss Annex II entities the firm has opted to treat differently.

Two investment firms trade with each other. Which one has to obtain the allocation?

Paragraph 14 assigns the role transaction by transaction: where two entities licensed as investment firms face each other in a transaction in Article 5(1) instruments, their respective roles in that transaction should be analysed to identify which is the investment firm and which is the client for these purposes. The answer can differ from one transaction to the next between the same two firms.

A professional client holds both the securities and the cash at our firm. Do allocations still have to flow?

Article 2(4) of the RTS disapplies paragraphs 1 to 3 of Article 2 for professional clients holding, at the same investment firm, the securities and cash relevant for settlement, and the 2026 amendments rewrite paragraphs 1 to 3 without removing that carve-out. A separate route exists under Article 2(3): where the firm receives the necessary settlement information ahead of the deadlines, the parties may agree in writing that written allocations and confirmations are not sent. Paragraph 17(c) of the guidelines still names systems that give the firm access to the information, such as a centralised database, as one way of receiving it, and its reference to oral provision is deleted.

Is a CSV file or an MT54x message enough?

ESMA answered with two tests and no list of named formats. Respondents asked about CSV and TXT files and SWIFT MT54x messages; the tests are one for the format (the machine-readable definition in Article 2(13) of Directive (EU) 2019/1024) and one for the standard (an international open communication procedure or standard meeting Article 2(1)(34) of CSDR). ESMA declined to identify a specific industry standard for allocations and confirmations and said it may revisit the point after T+1.

Do the guidelines require a standard for standing settlement instructions or an SSI utility?

ESMA left SSIs to industry-led work. Three respondents jointly proposed a minimum-content standard for exchanging SSIs as the basis for a European standard, and others suggested mandatory centralised SSI utilities. ESMA directed those requests to the relevant industry initiatives and gave no guidance of its own. The Level 2 duty that does bite is Article 2(3) of the RTS: reference data necessary to settle has to arrive in a machine-readable format and be kept updated sufficiently in advance.

Do the arrangements extend to our professional client’s own underlying clients?

ESMA says the Article 6(2) requirements apply only to the bilateral relationship between an investment firm and a professional client within the scope of MiFID II, for transactions in Article 5(1) instruments, and do not extend to other contractual relationships. The recent amendments to CSDR and the RTS changed nothing on that personal scope.

Related Articles

• ESMA T+1 Settlement: Allocations and Confirmations: the May 2026 consultation on the revised guidelines and the questions ESMA put to the market.
• EU T+1 Settlement: First Deadline Is 7 December 2026: the wider EU transition calendar to 11 October 2027 and what firms and custodians are readying.
• TARGET Services June 2027 Release: Swift ISO 20022 and the T+1 Squeeze: the infrastructure release timing that sits alongside the EU T+1 timeline.
• SFTR Reporting Explained: how securities financing transactions are identified and reported under a separate regime.
• UK T+1 Settlement: The FCA’s 2027 Readiness Warning: the UK readiness message under UK rules, distinct from the EU framework.

Key Takeaways

• 7 December 2026 is a single go-live for the amended Articles 2 and 3 of RTS 2018/1229 and the revised guidelines; ESMA rejected a grace period to 31 March 2027.
• Where written allocations and confirmations are required, professional clients must ensure they reach the investment firm as soon as possible and no later than 23:00 CET on trade date. Investment firms must require retail clients to send the relevant settlement information by the same deadline unless the client holds the relevant financial instruments and cash at the same investment firm. The professional-client arrangements and exemptions under Article 2(3) and (4) remain available, and the 12:00 CET next-day rule for distant time zones and late executions ends on 6 December 2026.
• ESMA identifies professional clients with low transaction volumes and smaller firms as examples where manual-entry GUIs may be appropriate; this is not a prescribed eligibility threshold. The required test is whether the resulting allocation or confirmation is structured so that the receiving firm’s software can identify, recognise and extract the data, while the applicable international open-standards requirement is met. ESMA expects high-volume or frequent clients to limit manual intervention and favour automated solutions.
• Guideline 4 calls for the investment firm and professional client to agree on alternative communication methods for duly documented temporary technical unavailability or service disruption. The guideline does not prescribe a specific time or documentation form for that agreement. Phone calls may be included where they are recorded in accordance with Article 16(7) of MiFID II and Article 76 of Delegated Regulation (EU) 2017/565.
• The Article 6(2) allocation arrangements can apply to securities financing transactions involving Article 5(1) instruments even where those transactions are exempt from the separate T+1 settlement deadline. Under Article 5(2), as amended by Regulation (EU) 2025/2075, the exemption for specified securities financing transactions applies only where they are documented as single transactions composed of two linked operations.
• PSET, the extended transaction type and CSD cash tolerance levels come from the RTS, so the December build needs the Level 2 field list as well as the guidelines.
• National competent authorities have two months from multilingual publication to notify ESMA; firms file no compliance notification of their own.

Sources and References

• ESMA, Final Report: Revised CSDR Guidelines on standardised procedures and messaging protocols used between investment firms and their professional clients, ESMA74-2119945926-3749 (16 October 2026), including Annexes III (tracked) and IV (clean): esma.europa.eu
• ESMA, One year to go for T+1 settlement: the regulatory framework is complete, now let’s make it happen (16 October 2026): esma.europa.eu
• ESMA, Consultation Paper on amendments to the Guidelines on standardised procedures and messaging protocols under Article 6(2) of CSDR, ESMA74-2119945926-3513 (26 May 2026): esma.europa.eu
• ESMA, Final Report on Amendments to the RTS on Settlement Discipline, ESMA74-2119945926-3430 (13 October 2025): esma.europa.eu
• ESMA, Final Report: Guidelines on standardised procedures and messaging protocols under Article 6(2) of Regulation (EU) No 909/2014, ESMA70-151-2461 (October 2019): esma.europa.eu
• ESMA, Questions and Answers on CSDR, ESMA70-156-4448 (version of 13 March 2023), CSD Answer 4(a) on Article 35: esma.europa.eu
• Commission Delegated Regulation (EU) 2026/1536 of 6 July 2026 amending the regulatory technical standards laid down in Delegated Regulation (EU) 2018/1229 (OJ L, 14.10.2026): EUR-Lex
• Commission Delegated Regulation (EU) 2018/1229 on regulatory technical standards on settlement discipline, consolidated version of 2 September 2024: EUR-Lex
• Regulation (EU) No 909/2014 (CSDR), Articles 2(1)(34), 5 and 6(2): EUR-Lex
• Regulation (EU) 2025/2075 of 8 October 2025 amending Regulation (EU) No 909/2014 as regards a shorter settlement cycle in the Union: EUR-Lex
• Regulation (EU) 2023/2845 (CSDR Refit): EUR-Lex
• Directive (EU) 2019/1024 on open data and the re-use of public sector information, Article 2(13): EUR-Lex
• Commission Implementing Regulation (EU) 2025/1339 of 10 July 2025, Article 7(2): EUR-Lex
• Directive 2014/65/EU (MiFID II), Articles 4(1)(10), 16(2), 16(7), 25(5), 30(2) and Annex II: EUR-Lex
• Commission Delegated Regulation (EU) 2017/565, Articles 21, 58 and 76: EUR-Lex
• Regulation (EU) No 1095/2010 (ESMA Regulation), Articles 16(3) and 16b(5): EUR-Lex
• Regulation (EU) 2022/2554 (DORA), Articles 10 and 11: EUR-Lex

Before 7 December: documenting each professional-client arrangement

The revised CSDR messaging protocols guidelines leave the form of each arrangement to the parties and fix what it has to achieve. For each professional-client relationship within Article 6(2), the investment firm should document the applicable settlement-information arrangements and determine whether written allocations and confirmations are required. Where required, those communications must meet the amended RTS requirements for timing, machine-readable electronic methods and international open standards. Article 2(3) allows the parties to agree in writing not to send allocations and confirmations where the firm receives the necessary settlement information in time. Article 2(4) disapplies paragraphs 1 to 3 for professional clients holding the securities and cash relevant for settlement at the same investment firm.

As an internal implementation control, investment firms may maintain a client-by-client record of the applicable arrangements, agreed communication methods, messaging standards, fallback procedures and supporting evidence. The Article 2(3) no-message arrangement requires a written agreement, whereas the Article 2(4) exclusion depends on the relevant securities and cash being held at the same investment firm and does not require a separate bilateral agreement. The record may also identify clients using a manual-entry GUI. The RTS does not prescribe a standalone client-by-client register.

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.