UK Accelerated Settlement Taskforce Quarterly Review – Q4 2025

Foreword: A word from the FCA

As we enter a new year, I wanted to take a moment to highlight the significance of the UK’s move to T+1 settlement. This isn’t merely a technical change; it marks a major milestone in our effort to support growth and innovation. T+1 will greatly enhance market efficiency, improve liquidity and modernise our markets. Faster settlement cycles will reduce risk and free up capital for faster reinvestment, and align ourselves with other major markets such as the US and Canada.

I am delighted to see the great progress made last year highlighted in the Accelerated Settlement Taskforce’s (AST) End of Year report. The AST published its Implementation Plan outlining the key technical and operational recommendations for the UK’s move to T+1. It has also been encouraging to see the collaborative efforts from the AST and its counterpart group in the EU, which has led to an aligned implementation date of 11 October 2027 across the UK, EU and Switzerland. In November, the Government published its draft Statutory Instrument to cement T+1 as the standard settlement cycle from 11 October 2027. I am also encouraged by the data from the Q3 Value Exchange survey, which highlights that 66% of the industry is now in project mode for UK T+1.

But we can’t be complacent. There is still a lot of work to do!

We expect market participants to already have project plans in place to facilitate the move to T+1 settlement by October 2027. By the end of 2026, we expect participants to have completed the necessary changes to systems and processes and be ready to test those changes. The deadlines for many of the AST’s critical recommendations are at the end of 2026. We echo Andrew’s focus on the automation of current arrangements and engagement with others in the settlement chain. The transition is a joint effort – it is imperative that you engage early and regularly with all parties involved in the settlement cycle. We will continue to support market participants in their preparations, bolstering T+1 awareness through our ongoing supervision, communications and market monitoring. A smooth transition to T+1 with limited market disruption will be key to maintaining market integrity.

I would like to thank Andrew, the AST and everyone else involved in the T+1 preparations for their great work over the last year. We look forward to further supporting your preparations for a smooth transition to T+1 settlement over 2026 and wish you all a successful 2026.

Jamie Bell
Head of Capital Markets, FCA

Chair’s Introduction

We started our shared journey to T+1 in January 2023. It will culminate in October 2027, when, after almost 5 years of investigation, negotiation, recommendation, implementation, and, like all good road trips, a little heartache along the way, UK securities markets will move from a 2-day settlement cycle to a 1-day cycle.

We have collectively achieved much in 2025, as I hope this end-of-year report will confirm. However, I will unashamedly remind everyone that there is still much to do, and the time available to complete your preparations is constantly reducing.

It’s worth noting that whilst the original drivers for T+1, such as reducing counterparty risk, minimising ‘capital lock-up’ and improving efficiency through automation, still hold true, these have been reinforced by two additional and equally compelling reasons:

• Elimination of the costly settlement misalignment between the UK and the US, the single largest non-domestic investment destination for UK investment funds, especially in the growing ETF market.
• A realisation that the impending global digitalisation of capital markets will require the extensive adoption of automation, for which T+1 can be seen as an early entry point.

As is customary on any long journey, there are times when we need to pull over, stretch our legs, consult the map and ensure we are still on target to make our destination on time. So, let’s do that now.

Andrew Douglas
Chair of the Accelerated Settlement Taskforce

2025 Review

What have the Accelerated Settlement Taskforce (AST) and the Market collectively achieved in 2025?

Outreach

Q1 was a busy time setting up the ‘bones’ of the project. The AST website and LinkedIn page were built thanks to Chatsworth Communications and Euroclear UK & International (EUI), and these have become invaluable reference points for global participants. Our website has more than 200 hits per month, and the number of users increased by 20% in Q4. For LinkedIn, we have more than 1,300 followers viewing our regular posts, of which there have been more than 50 this year.

The T+1 Implementation Plan was published on schedule in February with an update in September, which corrected some typographical errors and added learnings from the EU Securities Financing and FX workstreams. This is a live example of how the UK and the EU are collaborating closely together.

“Our website has more than 200 hits per month, and the number of users increased by 20% in Q4.”

On this point of collaboration, the AST has established excellent working relationships with the T+1 project teams in both Switzerland and, especially, the European Union. This helped deliver on the key industry requirement to co-ordinate a single ‘European’ implementation date, with all three jurisdictions committing to the 11th October 2027 live date.

“This helped deliver on the key industry requirement to coordinate a single European implementation date, with all three jurisdictions committing to the 11th October 2027 live date.”

As part of the AST’s continuing commitment to communicate our T+1 plans to UK investors wherever they are located, we have conducted an extensive outreach campaign over the year hosting two major industry events; the Implementation Plan launch in February (sponsored by KPMG) and a mid-year round-up in June (sponsored by EY), both of which attracted several hundred in-person attendees and many more online. T+1 was also a major part of an inaugural EUI market event in September.

Additionally, this year I have presented on T+1 panels at 45+ industry events across the UK, EU, US and APAC, ensuring communication of our plans globally, as well as publishing quarterly newsletters on our progress via LinkedIn and the AST website. Indeed, folks keep telling me they are fed up seeing and hearing me, and I am told, ‘You will go to the opening of an envelope.’ So that is a lot of envelopes this year!

“This year I have presented on T+1 panels at 45+ industry events across the UK, EU, US and APAC, ensuring communication of our plans globally.”

In June, responding to industry demand, we also launched a Quarterly Implementation Forum sponsored by Forvis Mazars. This serves as a collaborative platform for market participants, including buy-side, sell-side, custodians, and FMIs, to engage directly with the AST workstream leads and peers.

“Participation has continued to grow, with approximately 150 attendees representing 78 firms (both in-person and virtual) at our Q3 2025 forum.”

Participation has continued to grow, with approximately 150 attendees representing 78 firms (both in-person and virtual) at our Q3 2025 forum.

Key discussion topics this year have included derivatives scope, stock lending (Stock Lending Open – SLO / Stock Lending Return — SLR) and operational readiness. As well as providing a live Q&A, the Forum has been instrumental in the establishment of two new AST workstreams:

• Testing: working with the EU taskforce to deliver by the end of Q1 2026, a joint UK/EU testing plan for implementation in 2027
• Risk/Compliance: to define ‘what does good look like’ with regard to T+1 implementation. This workstream will have its first meeting in January 2026.

If you want to join the Implementation Forum or either of the new workstreams, please let me know. I would love to see more participation from you at all of these.

Finally, we established an FAQ page on our website where participants can raise any questions they may have in relation to T+1 to be answered by AST experts from within the workstreams.

Recommendation Status

The AST made eight recommendations with a deadline in 2025. All are being worked on, but only 50% have been completed at this point.

1. FMI 02 – Crest modernisation project
   Status: Complete, a CREST confirmation regarding systemic change prior to T+1 was published in June.
2. CoAc 01a – Dividend processing review
   Status: Complete, 100% in scope venues attested compliance.
3. CoAc 02a – Claims policies review
   Status: Incomplete, survey to establish market participant status was issued in Dec, results of the survey to be published in Q1 2026.
4. FMI 01a – Systems and processes review
   Status: Complete: 89% in scope FMIs attested compliance, the remaining 11% are mostly compliant with no blockers identified.
5. SETT 04 – Settlement monitoring definition
   Status: Incomplete. In early 2026, we will agree with the market what the target settlement rate will be for October 2027, post 11th October.
6. SETT 09a – PSET/PSAF review
   Status: Incomplete, AFME and IA are drafting and agreeing on best practices aligned with SMPG. Expect to finalise and publish in Q1 2026.
7. SETT 10a – Hold & Release review
   Status: Incomplete, AFME are drafting and agreeing on best practices. Expect to finalise and publish in Q1 2026.
8. SETT 11a – Debt new issuance review
   Status: Complete, confirmation that the debt new issuance process is exempt from T+1 was published on the AST website earlier this year. This also means that recommendation SETT 11b is no longer necessary.

Readiness of Participants

With help from The Value Exchange supported by EUI and DTCC, we completed readiness surveys in Q1 and Q3. They confirm that the industry is making progress in two critical dimensions.

• Engagement: At the end of Q1, 19% of respondents had yet to start any T+1 activity but by Q3, this figure had dropped to 5%. The direction of travel is clear: the market is engaging more broadly with the project.
• It should be noted, however, that this same survey revealed 61% of respondents had not yet reached the point of securing budget for the required compliance projects. This is far from the expectation conveyed by both the AST and the FCA around the need for budgeting to be completed in 2025.
• Understanding: At the end of Q1, 19% of respondents concluded that they were ready for T+1 (compliant with the requirements or ‘fully prepared’). But by Q3, this had dropped to 11% suggesting that participants now understand better the magnitude of the compliance task their organisations face and are perhaps being more realistic about what still needs to be done.

“At the end of Q1, 19% of respondents had yet to start any T+1 activity but by Q3, this figure had dropped to 5%.”

Readiness of FMIs

At the end of the year, the AST FMI workstream, led by John Worden, launched its own survey of FMIs to establish a benchmark for their level of preparedness for T+1, given that their role in the process is critical.

21 FMIs took part in the questionnaire with a 100% response rate, covering Trading venues, CCPs, CSDs and ICSDs, and four identified Critical 3rd parties.

General themes across FMIs included:

• Assessment efforts: All FMIs have already conducted or are conducting impact assessments, with many leveraging experiences from the US T+1 transition.
• Governance: Steering committees, working groups, and regular board updates are in place as common oversight mechanisms.
• Operating model: Minimal technical changes are required for many FMIs, especially those already supporting T+1 in other jurisdictions. The remainder are updating documentation, processes, and enabling participant communications.
• Risk management: Most FMIs believe their current frameworks are robust, but will be actively monitoring for increased settlement fails and liquidity risks.
• Industry coordination: Regular engagement with market participants, industry taskforces, and regulators is widespread. Testing and readiness surveys are either planned or underway.

Readiness of Corporate Actions

In December, the AST Workstream Corporate Actions lead, Richard Nicholls, launched a market-wide survey in relation to corporate actions post T+1. We expect the results of this to be available in early 2026. If you have received the survey and not yet responded, please do so as soon as possible. If you have not received the survey and would like to, please let me know.

Settlement performance

Statistics provided by EUI from the CREST system are now available on the AST website, as well as on the EUI T+1 page. These figures show that today, more than 86% of all settlement instructions by volume and value are usually received and matched in CREST by the recommended T+1 deadline of 06.00 on T+1.

“Today, more than 86% of all settlement instructions by volume and value are usually received and matched in CREST by the recommended T+1 deadline of 06.00 on T+1.”

In simple terms, this means approximately 14% of instructions are not compliant. Participants should focus their efforts on understanding the reasons why these 14% are delivered after the T+1 proposed deadline.

EUI and AST will continue to publish these statistics on a quarterly basis until the go-live date.

If you want to understand where your organisation sits in relation to the 86% versus the 14%, please contact your CREST Account Manager if you are a direct participant. If you rely on an intermediary such as a global custodian, they should be able to help you.

Readers may recall an early comment I made that ideally nothing will happen on 11th October 2027, as the market will have effectively already implemented T+1 before the deadline. Use the available data to help you understand how you can achieve this, remembering that today, according to CREST settlement data, 5% of transactions already settle on T+1.

Don’t be the weakest link in the settlement chain.

Support from UK Public Authorities

We have seen considerable and very welcome support from the UK authorities with HM Treasury (HMT), FCA and BoE being regular observers at the AST weekly and bi-weekly meetings.

The Economic Secretary to the Treasury kicked off our Implementation Plan launch event in February with FCA and BoE providing senior speakers at both the launch and our mid-year review in June, where the impact of the project and their expectations of participants were clearly defined.

Additionally, the FCA has engaged in its own outreach campaign to participants. The FCA reached out to participants across wholesale markets as well as trade associations, published a dedicated T+1 page on the FCA website, a T+1 blog and in October, the publication of a Dear CCO letter to asset management and alternative firms.

The BoE published its April Financial Policy Committee Record, welcoming plans by HM Treasury, the FCA and the BoE to support an industry recommendation to move to T+1 settlement in UK markets by 11 October 2027, as well as hosting a one-hour informal group discussion with the AST Chair on T+1 and four additional central banks which are users of Vermeg’s Megara system.

And to round off the year, HMT published the Draft Statutory Instrument confirming the T+1 implementation date and scope as recommended in the February T+1 Implementation Plan. This is now out for consultation until Feb 2026, but as it is entirely aligned with the content of the February Implementation plan, I hope there will be no surprises in any responses!

Concerns

As part of our ongoing commitment to the successful implementation of T+1, the AST is constantly reviewing progress and looking for any potential impediments to implementation. As well as ongoing engagement with industry, the Q3 readiness survey is a useful tool for foreshadowing potential future issues.

“At the end of Q3, 61% of participants had not yet secured the necessary budget for implementing their compliance projects in 2026.”

The major concern for us to be aware of is that whilst the general direction of travel supports increasing levels of engagement, at the end of Q3, 61% of participants had not yet secured the necessary budget for implementing their compliance projects in 2026. I would encourage participants to speed this process up to ensure they do not find themselves in the situation experienced by some firms in the US, where they needed to ‘body-shop’ a solution. This is expensive and can only ever be a short-term solution.

“The readiness survey also suggested a majority of participants will fail to meet SETT 01 (allocation and confirmation processing completed by 23.59 on T) by the 31/12/2026 deadline.”

The readiness survey also suggested a majority of participants will fail to meet SETT 01 (allocation and confirmation processing completed by 23.59 on T) by the 31/12/2026 deadline. Again, we must now focus on this to avoid missing this key target deadline. Timely allocation and confirmation put a participant in the best place to execute settlement on T+1, as will be required under UK CSDR.

We also have a number of recommendations that rely on participants adopting new market practices, for example, PSET/PSAT usage, Hold & Release, market cut off for Stock Lending recalls and return settlement deadlines and fund settlement cycles. It is not always clear how we turn the words of market practice into real actions. This will be a key focus of mine in 2026 as I work with the organisations defining these new market practices.

2026 look forward

In 2026, the Implementation Plan identifies many key deadlines. These are listed below, and whilst all are important, the highlighted recommendations are those which the AST identified as ‘critical’ to the success of implementing T+1, and firms MUST comply with them by 31/12/2026. Without implementing these recommendations, in the opinion of your peers working within the AST, firms will struggle to comply with T+1:

• COAC 01b: Standardised dividend process adoption
• COAC 02b: Claims process upgrades
• FMI 01b: FMI systems and processes updates
• FMI 03: FMI rulebook reconciliation
• SETT 01: Allocation and confirmation processing by 23.59 on T
• SETT 03: Allocations and confirmations policies and procedure upgrade
• SETT 06: Contractual review
• SETT 07: Extend/implement use of partial settlement/split
• SETT 08: Extend/implement use of autoshaping
• SETT 09: Extend/implement use of PSET/PSAF
• SETT 10b: Extend/implement use of Hold & Release
• SETT 11b: Debt new issuance implementation
• SFT 01: Automation of Stock Lending recalls and returns
• STAT 01: Implement SSI market practice
• STAT 02: Implement SSI & KYC market practice for UK trading venues
• STAT03: Review/test all static data policies and procedures
• STAT 04: Review stamp duty reserve tax status

Coming Initiatives

The Readiness Register: In early 2026, the AST website will include a ‘Readiness Register.’ This will contain the names of participant firms that have self-certified they already comply with the relevant T+1 recommendations. They are effectively ‘ready for business’ in a post 11/10/2027 T+1 market.

The Broader view: In 2025, we launched an expert video series called ‘The Broader View’ that takes an in-depth look at specific elements of the settlement process. So far have published two videos on FX and SSIs. This series will continue in 2026 with videos planned for ETFs and Corporate Actions.

How did we do in 2025?

It is the beginning of a new year, and time to make a final performance assessment.

The range of achievement revealed by our readiness survey is broad. I will leave you, the reader, to determine into which of the three clear ‘streams’ your firm fits:

• 39% of participants get a straight A. According to our readiness survey, you have worked closely with the recommended actions and behaviours. At the very least, you have a plan and a budget for the work you need to do in 2026. Keep this performance up, and you will breeze through October 2027.
• 56% of participants get a C. You have had a slow start this year, but some hard work in 2026 should allow you to catch up.
• 5% of participants get an F. At this point, the fact that you have not even started the project is an indicator of potential issues in 2026 and 2027. You need to rethink your approach if you want to avoid incurring self-imposed penalties such as increased staffing costs, increased late settlement penalties and the ultimate sanction, being marginalised by peers who will likely look to work with the most efficient and reliable counterparties.

Overall, whilst some of us can allow ourselves a mince pie and a glass of mulled wine as a reward for our efforts in 2025, none of us must fall asleep in front of the TV in 2026 if we are all to be ready in 2027.

I don’t need to remind you that when the SI comes into force on October 11 2027, the UK requirement to settle on T+1 will become law under UK CSDR.

Conclusion

I would reiterate the conclusions drawn from the results of our Q3 readiness survey in relation to what your focus should be in 2026 to make sure you hit the October 2027 deadline.

• Accelerate internal automation: The broad swathe of industry participants all agree that automation is the key. Do not look to rely on manual intervention. Start your automation programs now.
• Engage counterparties and service providers early: Clearing and settlement is a chain. And your settlements are only as timely and efficient as permitted by the least efficient link in the chain. Don’t be the weakest link and work with your counterparties and service providers to ensure they deliver the highest level of service.
• Update fund dealing cycles and processes: Misalignment of fund dealing cycles and the underlying settlement cycles is expensive. Work to adopt the IA/PIMFA/AIMA recommendation to move from T+3 to T+2 on fund dealing.
• Invest in people and process training: With most efforts focused on technology and operational readiness, staff enablement and education must keep pace.

Finally, some folks I would like to thank for their contributions and efforts in 2025.

• EUI for their support, without which this project would not be running as well as it is. In particular, Junayd Azam (EUI Secretariat) and Emma Miles (EUI program management) for their patience with me and for being so much better organised than I am.
• All of the members of the Oversight Committee, especially the workstream leads (See Page 67 for a full list), for their willingness to devote significant time to AST alongside their ‘day job’.
• In the course of writing this report, I have italicised certain institutions that have freely offered support to AST through the hosting of events.
• All participants, especially the 95% already engaged in the project. To the 5% who have not yet engaged, I highly recommend you start as soon as possible!

I would like to thank too Giovanni Sabatini, Independent Chair of the EU T+1 Committee, for his positivity and energy in bringing the EU taskforce online and his openness to building the relationship between the UK and EU taskforces.

I wish everyone a productive 2026.

Regards,

Andrew Douglas
Chair, The UK Accelerated Settlement Taskforce
January 2026