CGI Delay and the Impact on Switzerland

Required knowledge

• In-depth knowledge of the ISO 20022 and Swift FIN standards
• Familiarity with the Swiss Payment Standards 

The Common Global Implementation (CGI) initiative aims to simplify the various implementations in payment transactions between corporates and banks by promoting the acceptance of ISO 20022 XML. Those waiting for the publication of the CGI guidelines for the customer-bank interface of the new ISO 20022 message versions announced for November 2023 have been disappointed. This is because the corresponding guidelines, which were originally due to have been issued in November 2022 but were also postponed due to the delayed start date of the migration to ISO 20022 messages in the Swift network, have not yet been published. This is not surprising, as CGI is a very ambitious project. The goal is to help international companies with a broad market practice to process their payments in a standardized format. So why another delay?

One reason is certainly the lack of demand. The current version is still suitable for all business cases and as long as the majority of banks have not switched to ISO 20022-compliant MX messages in the Swift network, the new version will not add any value. This is in addition to the aforementioned postponement of the changeover start for Swift to March 2023 and the SEPA migration start date to March 2024. In addition, Swift has now decided to introduce a new structured address type – known as a hybrid address – as of November 2025, which is relevant for the parties involved in a payment.

Cross-Border Payments Versus Domestic Payments

Another important issue is still open. There are market participants for whom the CGI primarily covers cross-border payments. For domestic payments, the rules of the home country should apply. Others are of the opinion that CGI should also enable domestic payments in order to make it easier, especially for internationally active companies, to process payment orders in as many countries and networks as possible from a central system. This issue is also very important for the Swiss community. With the QR-bill, we have a payment method that clearly dominates the domestic market and covers around two-thirds of payment orders. But it is clearly a national implementation and the necessary elements are not supported by all markets, so it will depend on whether payment or­ders with QR references will also be possible with CGI. Another aspect is the fact that the Swiss Payment Standards (SPS) already cover the three most important networks: the Swiss RTGS systems SIC/euroSIC, SEPA, and CBPR+. There is therefore no urgent need in Switzerland for an independent practice covering only cross-border payments via Swift, i.e., CBPR+.

What has been described so far relates to place payment instructions, i.e., the CGI guidelines for pain.001 and pain.002. Reporting is equally, if not more, important for the automation of transaction processing. And this is where market participants face a much bigger step in the international context. While the penetration of reporting with camt.05x messages is now very high and many use cases already rely on the more comprehensive data in Switzerland, MT940/942 still dominates in the global context. While in the global multibank approach, market participants can easily and cost-effectively receive account information via Swift FIN, i.e., with Swift's MT940 definitions, various national markets or individual banks have developed sophisticated coding for MT940 together with their software partners, which already allows a high degree of automation. Unlike pain.001/002, there are no SEPA-related specifications for camt.05x either.

Questions About Questions

To ensure a successful transition to ISO 20022 messages for reporting, the international standardization bodies still need to do some preparatory work and clarify what the basis for such implementation guidelines should be. Will they extend the interbank CBPR+ guidelines to include customer aspects? Will the EPC issue new reporting requirements for SEPA? What exactly will be the scope of the future CGI guidelines? Will only incoming and outgoing payments be described, or other transactions as well?

For Swiss market participants, it will be important to know to what extent national specifics can be mapped with CGI messages and how big the difference to the SPS guidelines will be. The SPS already uses schemas that are as open as possible. The challenge is not so much at the message level, but rather in possible differences in element mapping, validations, and stricter rules regarding the mandatory nature of elements that are inherently optional. We are already seeing foreign banks operating in Switzerland struggling to comply with the SPS requirements. And with the extension of the character set in line with developments in the official registers in Switzerland, there is another addition that has not yet been followed internationally. We do not need to include all of this in the CGI guidelines in Switzerland, unless it is absolutely necessary for end-to-end processing, such as the QR reference.

The goal of the Swiss representatives in the CGI working groups is on the one hand to support the CGI guidelines at a national level and on the other hand not to create any contradictions with the proven and, above all, widely implemented SPS guidelines. The parallel phase will end in November 2025 and we will only rely on the new ISO 20022 message versions. Banks will still be able to offer their customers the option of using the traditional message versions. However, we will no longer be able to ensure that all use cases are consistently covered. This also applies to existing CGI offerings. The time to migrate is getting shorter and shorter.

Martin Walder
Head Billing & Payments Standards, SIX