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.
The E&I turning point
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.
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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.
Beyond short term fixes
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.
It can be daunting for banks to even start considering overhauling the systems and workflows they have relied on for decades, and Case Management brings that reality to the surface. Modernisation, however, is both unavoidable and far more manageable with the right technology and partners. Unified payment-messaging orchestration tools can embed Case Management compliance directly into existing processes. This helps to improve visibility, automation and scalability as part of a broader modernisation journey. With this support, banks can focus on long-term transformation, rather than last-minute workarounds. Those that continue to depend on legacy systems and manual processes will remain constrained, while those that plan ahead will be positioned to progress.
From compliance to competitive edge
The commercial advantages of early Case Management adoption cannot be overlooked. Industry modelling suggests that Case Management could save as much as $600 million through reduced operational and liquidity costs. Faster, clearer investigations will translate directly into customer value, with early adopters expected to see a 3-5% uplift in revenue. Corporates have already signaled their preferences, with 35% willingly reroute payment flows to banks offering Case Management-based transparency.
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By GlobalDataThese gains extend beyond the investigation process itself. Modernised case handling strengthens incident detection, enables smarter automation and shortens resolution times across payment operations. It also frees skilled teams to focus on higher-value work. The banks that seize this advantage early won’t just be compliant, they’ll set the standard that others must follow.
A deadline of divergence
E&I has been the weak link in payments for too long, dragging down customer experience and masking operational fragility. Case Management will break a costly industry pattern and set the stage for the next generation of leaders in cross-border payments.
Those that pursue native processing before the November 2027 deadline will strengthen their operational foundations, sharpen their competitive edge and position themselves for the future. Those that wait until the last minute will spend the next decade trying to catch up.
In a rapidly moving industry, now is the moment to act decisively. The leaders will be the banks who move first.
Cian Fernando, CEO, Aqua Global Solutions
