T+1 settlement cycle - CONSOB AND ITS ACTIVITIES
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European financial markets will migrate to a T+1 settlement cycle, from the current T+2 cycle, on 11 October 2027.
In view of the complexity of the migration to T+1, ESMA, the European Commission and the ECB have established a specific governance framework to coordinate the transition.
The governance structure consists of the T+1 Coordination Committee, composed of authorities, a technical structure composed of the Industry Committee, chaired by Dr Giovanni Sabatini, and a number of dedicated specialist working groups operating under the guidance of the Industry Committee.
T+1 Migration Survey
On 12 May 2026, two key surveys were launched to assess market readiness for the migration to T+1:
Industry Committee: General survey on the state of play.
Deadline: 11 June 2026
Consob and the Bank of Italy, with ESMA: Complementary survey to monitor participation in the Industry Committee survey and assess the impact of the regulatory provisions proposed by ESMA.
Deadline: 11 June 2026
ESMA consultation on Guidelines on allocation and confirmation
On 26 May 2026, ESMA launched a consultation on the amendments required to the current ESMA Guidelines on allocation and confirmation (Guidelines on standardised procedures and messaging protocols pursuant to Article 6(2) of Regulation (EU) No 909/2014) in view of the migration to T+1.
Link to participate: ESMA consults on revised guidelines to support smoother allocations and confirmations under T+1
Deadline: 7 July 2026
The widest possible participation in the two surveys is encouraged. Broad participation is essential to provide the authorities with an adequate overview of the market’s level of readiness ahead of the migration, helping to identify any critical issues in a timely manner.
The work carried out at European level by the Industry Committee has led to the definition of the following documents, available here https://eu-t1.eu/resources-2/, which market participants are invited to examine carefully:
- The EU T+1 Industry Committee’s High-Level Roadmap (“Roadmap”), which contains a set of recommendations for the migration;
- The EU T+1 Securities Settlement Handbook, which sets out the content of the Roadmap recommendations in more practical terms;
- The T+1 Corporate Events Harmonised Implementation Guide, which illustrates the changes to the management of corporate actions;
- The T+1 Testing plan, which provides guidance and suggests timelines for testing. In particular, it proposes that internal testing by intermediaries should take place from March 2026 onwards, while end-to-end testing between CSDs and intermediaries should take place from April 2027;
- Certain market practices, on Partial settlement, SSI and Transaction type identifiers. A further market practice, on the Gating event, is expected shortly. It is also envisaged that the market practice relating to Partial settlement will be reviewed before the migration.
In order to ensure a high level of adherence to the recommendations contained in the Roadmap, and with the ultimate objective of facilitating an orderly migration to T+1, ESMA has proposed incorporating the main recommendations contained in the Roadmap into a European regulatory act, so as to make them binding.
The draft measures were submitted to the European Commission on 13 October 2025 (Final Report on Amendments to the RTS on Settlement Discipline) and are expected to be approved by summer 2026.
At national level, Consob and the Bank of Italy have established a National Forum to coordinate the migration to T+1, with the participation of intermediaries, issuers, asset management companies, market infrastructures, IT providers and trade associations.
For further information on T+1 and on the National Forum, please write to Consob’s Post-Trading Office at csdr@consob.it.
Emir Regulatory Fitness and Performance Program (Refit)
REPORTING FORMS RELATING TO THE CLEARING THRESHOLD AND FOR THE NOTIFICATION OF THE EXEMPTION FROM THE REPORTING OBLIGATION OF INTERCOMPANY DERIVATIVE CONTRACTS
CONSOB notification on intragroup exemption from the reporting obligation pursuant to Regulation EU n. 2012/648 (EMIR) art. 9.1, as amended by Regulation EU n. 2019/834 (REFIT)
Refit provides an exemption from the reporting obligation of intragroup derivatives contracts.
The exemption can be applied where at least one counterparty of the group is a Non Financial Counterparty (or would be qualified as a non financial counterparty if it were established in the Union) provided that:
1) both counterparties are included in the same consolidation on a full basis and both are subject to appropriate centralised risk evaluation, measurement and control procedures;
2) the parent undertaking is not a financial counterparty;
3) the counterparty has notified their competent authorities of their intention to apply the exemption;
4) the competent authority has express no denial – within three months from the notification – about the compliance with the condition referred to point 1) and 2).
CONSOB notification should be submitted through the following forms. Filling instructions are included in the forms.
CONSOB notification on clearing threshold pursuant to Regulation EU n. 2012/648 (EMIR) art. 4 (a) and art. 10, as amended by Regulation EU n. 2019/834
EMIR Refit provides for a new regime to determine when Financial counterparties (FC) and Non-Financial counterparties (NFC) are subject to the clearing obligation.
A Financial Counterparty (FC) that enters into position in OTC derivatives contracts may calculate their aggregate month-end average position every 12 months.
Where an FC does not calculate its position or where the aggregate result of the calculation, at group level, exceeds the clearing threshold for at least one asset class, the FC immediately notifies CONSOB and ESMA. From that point onward, the FC becomes subject to the clearing obligation for all the asset classes subject to the clearing obligation.
Non Financial Counterparty (NFC) that enters into position in OTC derivatives contracts may calculate its aggregate month-end average position every 12 months.
Where the aggregate result of the calculation, at group level, exceeds the clearing threshold for at least one asset class, the NFC immediately notifies CONSOB and ESMA. From that point onward, the NFC becomes subject to the clearing obligation for OTC derivative contracts that pertain to the asset classes in respect of with the result of the calculation exceeds the clearing threshold.
Where the NFC does not calculate its position NFC become subject to the clearing obligation for the OTC derivative contracts that pertain to any asset class.
This notification should be submitted using the clearing obligation notification form below.
The form also contains a section to notify that the Counterparty "no longer exceeds the clearing threshold".