Position Paper Settlement Finality Regulation (SFR)

17 maart 2026

The position paper outlines the Dutch Banking Association’s view on the European Commission’s proposal to convert the current Settlement Finality Directive (SFD) into a Settlement Finality Regulation (SFR). While we support the objective—greater legal certainty and harmonisation across the EU—the proposed SFR introduces unnecessary complexity and additional obligations for both EU systems and third country systems. This paper highlights the key concerns, particularly regarding third country systems, and presents a simpler alternative aligned with Dutch practice, better suited to the SFD/SFR’s core purpose: ensuring certainty about the finality of transactions.