While cross border payments have modernised, Exceptions and Investigations (E&I) remain stuck in a slow, manual past. It’s an issue the industry has tolerated for too long, but Swift’s 2027 Case Management mandate seeks to change this by replacing unstructured messages with a standardised framework. To comply with this change, banks will have to automate how investigation cases are created, exchanged and resolved. However, as regulatory demands intensify, the mandate risks being overshadowed by competing deadlines and legacy constraints.
Banks need to treat the next two years as a strategic runway, not an administrative countdown. Those who invest early in native compliance will gain stronger, faster and more resilient payment operations. Those who fall back on quick fixes to mask E&I weaknesses will find themselves unable to keep up with market trends and growing customer expectations. November 2027 will mark a clear split between banks that used the time to modernise and those that did not. The decisions made now will shape their competitiveness for years to come.
E&I is often where payments stop. Whether it’s for sanction or fraud checks, it’s a critical stage in the payment journey that dictates the speed, security and accuracy of the entire process. Most international payments settle within hours, but those that fall into E&I still take an average of five to ten days to resolve. These prolonged investigations create operational strain and financial impact. Research suggests that some institutions face up to $20 million a year in penalties and attrition driven losses.
These delays and costs are caused by banks having to manually identify and resolve problems as they continue to rely on decades-old workflows and unstructured messages that limited visibility. Case Management is designed to address this pain points. By replacing MT199 and MT299 messages with structured ISO 20022 case messages, banks will gain a common framework to automate investigation creation and routing for the first time. Adopting the standard also allows banks to introduce enhanced API connectivity and integrate investigations into existing workflows, rather than defaulting to manual portals. Crucially, Swift estimates this transition could reduce resolution times by up to 80% – eliminating the noise, duplication and lack of transparency that currently slow E&I processes.
When approaching the Case Management deadline, banks face a clear choice: use the time between now and 2027 to modernise gradually and properly, or paper over growing cracks weeks before the deadline. Many will be tempted by short term workarounds like manual portals, translators, emails and even spreadsheets. These approaches may feel convenient, but in reality, they exacerbate the very problems the mandate seeks to solve. Quick fixes add operational debt, introduce new failure points and escalate risk. Above all, they lock banks further into the systems and silos that already hold them back.
