Take Steps now to avoid payment rejection – Address Requirements and Payment Format Decommissioning
17 March 2025
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A critical factor driving the success of ISO 20022 in the cross-border payments market is the implementation of structured address elements, such as street name, building number, town name, postal code, and country code. Financial institutions aim to reduce errors, improve sanctions screening, and accelerate transaction processing by adopting this standard.
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.
| Payment Product Type | Result |
|---|---|
| SEPA Credit Transfer | Invalid counterparty addresses will be removed from the payment instruction and it will be further processed through clearing. This may result in requests for information, delays and possible rejection. |
| SEPA Direct Debit collection from a counterparty in the EEA | Invalid counterparty addresses will be removed from the direct debit instruction and it will be further processed through clearing. This may result in requests for information, delays and possible rejection. |
| SEPA Direct Debit collection from a counterparty outside the EEA | Use of invalid counterparty addresses will result in rejection of the transaction. |
| International Credit Transfers and High-value (Urgent) Transfers | Use of invalid counterparty addresses will result in rejection of the transaction. |
| Payment initiation on 3rd party bank account via ING channel | Use of invalid Debtor or/and Creditor address will result in rejection of the transaction, it is applicable for all payment product types. |
Fully structured vs. hybrid
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>
Mandatory Changes for Swift MT101 Initiation Format
The current implementation of the MT101 may not support the minimum hybrid address structure for international and high-value payments and as such could lead to rejection from November 2026. In order to continue using the MT101 format as an import format into IBP or Swift FIN/FileAct/EBICS/Host-to-Host channels successfully, upgrade your MT101 Field 59 (unstructured option) to 59F (structured). The same rule applies for Field 50.
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
Domestic Payments
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.
“Mixed batch”— Delivery of Payment Instructions
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.
Interbank payment initiation on 3rd party bank account via ING channel
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 requirement applies to all payment product types and all initiation channels except InsideBusiness Payments.