Take Steps now to avoid payment rejection – Address Requirements and Payment Format Decommissioning

New requirements related to counterparty addresses in payment and direct debit instructions will be implemented at ING by November 14 2026. You are strongly advised to take action to avoid payment rejections that could affect your business.
• Check your counterparty data to ensure that at least a town name/city AND a country code are present – see below table for applicability;
• Check your payment and direct debit initiation formats to confirm that these formats support the town name/city AND a country code in dedicated data elements, and make adjustments as required;
• Contact client services in case you need guidance or example files

The following table indicates when a structured address is required to be provided.

Fully Structured address

• Uses up to 14 dedicated data elements for each address component (such as street name, building number, town name, post code and country code) to form a complete address.
• Does NOT use unstructured address lines.

In ISO 20022 pain.001.001.09 format, this would appear as follows:

<Nm>NAME</Nm>
<PstlAdr>
<StrtNm> STREET</StrtNm>
<BldgNb>2468</BldgNb>
<PstCd>97531</PstCd>
<TwnNm> TOWN</TwnNm>
<Ctry>NL</Ctry>
</PstlAdr>
 

Hybrid address

• To be valid, minimum Town Name (city) and Country Code are submitted in their own structured data elements
• the other address elements may be submitted in unstructured address lines
• There should be no duplication of data between address lines and the structured elements.

Clients should aim for the fully strutured address model as this was the original aim of the industry and is the most future-proof model. 

In ISO 20022 pain.001.001.09 format, this would appear as follows:

<Nm> NAME</Nm>
<PstlAdr>
<TwnNm>TOWN</TwnNm>
<Ctry>NL</Ctry>
<AdrLine>UNSTRUCTURED  ADDRESS 1</AdrLine>
<AdrLine>UNSTRUCTURED ADDRESS 2</AdrLine>
</PstlAdr>
 

SWIFT has not set a deadline for corporate-to-bank use of the MT101 message over the FIN service.  However, there is a conflict between the unstructured nature of the MT101 and the requirement of CBPR+ for banks to deliver structured name and addresses to each other for cross-border payments by November 14 2026.  Clients making use of this format will need to upgrade field 59 to the F option, allowing the mapping of the minimum hybrid address structure to the outgoing payment message. 

ING will no longer support the MT101 over the EBICS channel from November 1 2026.

Below example shows the result of such an upgrade
:59F:/<Account Number>
1/<Counterparty Name>
2/<Street name and Building Number>
3/<ISO-2 Country Code>/<Town Name>

For example:
:59F:/NL12INGB012345678
1/JAN SMET
2/PARKLAAN 21
3/NL/AMSTERDAM

Please check with your client service team before implementing changes in the production environment

While the primary focus of the ISO 20022 migration has been on International/Cross-border payments, there are also some changes in the domestic markets related to the requirements for structured or hybrid addresses.   Below, we list exceptions that you need to be aware of with regard to counterparty address formats.

A “mixed batchis described as a single batch (or “order”) which is made up of multiple payment types, typically combining domestic and international payments within a single order—will be treated as international payments by ING from November 2026.

To ensure uninterrupted processing, any address information included must comply with (hybrid) structure requirements (town name and country in dedicated data elements), also for domestic payments within the batch.

To optimise processing, you may choose to submit separate batches by payment type.

From November 2026, SWIFT MT101 (Request for Transfer) messages will be discontinued between banks and replaced by ISO 20022 pain.001.001.09 messages. ING is actively migrating all interbank payment flows to this new standard.

What this means for you:
When initiating payments from accounts held at other banks than ING from an ING channel other than InsideBusiness Payments, you must ensure that Debtor and Creditor address details are provided in at least a hybrid structure (including town name and country code in dedicated fields) to prevent rejection.

This Debtor address requirement applies to all payment product types and all initiation channels except InsideBusiness Payments.

After reviewing our current payment initiation format landscape and considering current usage coupled with requirements of both SEPA and International Credit Transfers, ING has decided to announce decommissioning of formats as listed below, including initiation channel, decommission date and target format.

*MT101 will be supported in InsideBusiness Payments and Swift FIN with changes to beneficiary address (59F) structure