T+1 Is The Deadline, Not The Destination

For employee share plans, the pertinent point is what T+1 exposes: how much manual friction exists in the settlement chain between intermediaries. Those are issues we need to fix not only for October 2027, but for whatever comes next.

Where transactions are in scope, they will have to settle to a shorter timetable. The question for issuers is whether all the processes around those transactions are set up to support that.

Depending on the plan, getting shares into the right place can involve an issuer, trustee, administrator, registrar, broker or custodian. There can be instructions to send, approvals to make, stock to move – and this is where the opportunity lies.

While we could try to squeeze today's processes into a shorter settlement window, this will only solve today’s problem – not tomorrow’s. Instead, we should use the deadline to challenge the steps that slow things down, because this almost certainly won’t be the last time we'll need to do so.

Start with getting the shares where they need to be

For share plans, the practical question is whether the stock needed to complete an in-scope transaction can be in the right place at the right time.

Companies can source shares in different ways. Some use newly issued or treasury shares, while many use Employee Benefit Trusts (EBTs). An EBT may hold shares purchased earlier, receive newly issued shares or purchase shares as part of the sale transaction. The route from source to settlement therefore varies considerably.

For example, an EBT might involve instructions, approvals and stock movements between different parties. If those steps can comfortably happen within the new timetable, fine.

But where they can't, simply asking everybody involved to move faster isn't much of an answer.

Issuers should look at whether stock can be positioned earlier, whether instructions can be sent sooner, whether every approval is still required and where manual intervention can sensibly be removed. Appropriately scoped powers of attorney could reduce delays by authorising another party to sign documents or issue instructions on their behalf,

They need to look at the whole process rather than just their own part of it. A perfectly efficient process inside one organisation doesn't help much if a delay is waiting somewhere else in the chain.

Don't build another legacy process

We need to look beyond October 2027.

There is an obvious temptation with any regulatory or market deadline to solve the requirement directly in front of you. But T+1 is part of a much wider change in market infrastructure.

The work behind the UK's accelerated settlement programme has already considered T+0 and atomic settlement, i.e., the mechanism enabling simultaneous exchange of asset and payment. Dematerialisation is changing how ownership is recorded in the UK, and the industry is also beginning to consider where tokenisation could eventually fit within market infrastructure. Equiniti's existing work is already looking across those developments rather than treating them as entirely separate conversations.

We shouldn't get ahead of ourselves. T+0 is not the UK's current implementation programme, and tokenisation will develop at its own pace, but the direction is clear enough to influence decisions we're making now.

If you are changing a process for T+1, don't design it so narrowly around T+1 that you have to start again at the next change.

That means reducing unnecessary manual intervention, improving the quality of ownership data, making responsibilities between different parties clearer and thinking carefully about how systems connect.

None of that depends on predicting exactly what future market infrastructure will look like. They're sensible improvements now.

Four things I'd do before October 2027

First, follow the transaction from beginning to end.

Look at what actually has to happen from the point a transaction is triggered until settlement completes. Where does somebody have to intervene? Where does an instruction sit waiting? Where does stock have to move? Which approvals are genuinely necessary?

Second, fix the delays you find.

If something only works because T+2 gives everyone additional time, that's a good place to concentrate. Bring activity forward where possible, automate where it makes sense and simplify unnecessary hand-offs.

Third, test the difficult cases as well as the straightforward ones.

The normal process isn't necessarily where problems will emerge. Issuers need to know what happens when an instruction is late, an approval hasn't happened or somebody has to step in manually.

Finally, make each change with the next change in mind.

Ask a simple question: does what we're doing leave us with a better process, or just a T+1-compliant version of the old one?

If it's the latter, I think we're missing an opportunity.

Think beyond the deadline

At Equiniti, we are already working with issuers and other market participants on T+1, looking at settlement chains, operational processes and the areas where closer alignment will be needed.

We're also looking beyond it.

Our work on tokenisation, for example, is already considering a market in which traditional book-entry and tokenised positions could coexist rather than assuming that one replaces the other overnight. Our issuer-readiness work also puts particular emphasis on getting some of the basics right early, including understanding ownership structures and maintaining accurate shareholder data.

That is the mindset I'd bring to T+1.

Get October 2027 right, certainly. But don't treat it as the finishing line.

The infrastructure supporting ownership is becoming faster and more digital. We have T+1 immediately ahead, dematerialisation changing another part of the landscape, and further settlement acceleration and tokenisation being explored beyond that.

We won't have all the answers today, and we don't need them.

What we can do is avoid carrying unnecessary complexity from one generation of market infrastructure into the next.

T+1 gives us a useful deadline to start doing that.