Organisation and governance

Swift’s National Member Groups and National User Groups help to provide a coherent global focus by ensuring a timely and accurate two-way flow of information between Swift and its users. The National Member Groups comprise all Swift shareholders from a nation. They act in a consultative capacity to the Supervisory Board and Management Board, and serve the interests of their nations’ shareholders by coordinating their views. Each National Member Group is chaired by a representative who is elected by the Swift shareholders of that nation. National User Groups comprise all Swift users from a nation and act as a forum for planning and coordinating operational activities. Each National User Group is chaired by a representative who is a prime line of communication between the national user community and Swift.

The Supervisory Board is committed to ensuring that Swift's governance practices remain aligned with the company's purpose, strategy and the interests of its shareholders. It reviews the effectiveness of Swift's governance arrangements on a regular basis to ensure compliance with applicable laws, regulations and evolving stakeholder expectations.

The Supervisory Board is responsible for defining and overseeing Swift's strategy and general policy, approving the company's risk appetite, overseeing management, risk and control, and monitoring the overall effectiveness of the governance framework. It also oversees the performance of the Management Board and helps ensure that Swift is managed in a sound and prudent manner.

The Supervisory Board is supported in carrying out these responsibilities by five specialised committees.

The Supervisory Board is supported by five specialised committees which assist it in fulfilling its governance, oversight and fiduciary responsibilities. The primary role of the committees is to support the Supervisory Board by reviewing matters within their area of responsibility and providing advice and recommendations to the Supervisory Board. Each committee is composed exclusively of Supervisory Board members and operates in accordance with its Terms of Reference.

The Audit and Finance Committee (AFC) assists the Supervisory Board in fulfilling its Company-wide oversight responsibilities for the financial reporting process, the system of internal control, first line of defence control testing, the audit process (internal and external auditors), whistleblowing process and cases, and the Company's process for monitoring compliance with applicable laws, regulatory requirements and the Code of Conduct.

The Risk Committee assists the Supervisory Board in its oversight of the Company’s management of key risks, including strategic and operational risks, as well as the guidelines, policies and processes for monitoring and mitigating such risks.

The Remuneration Committee assists the Supervisory Board in matters relating to remuneration, incentives, succession planning and remuneration governance.

The Technology and Production Committee (TPC) provides advice and guidance on strategic matters associated with the technology, operational and security components related to Swift products and services. This committee also reviews and provides guidance for Swift's operational performance, and technology and security risks related to its products and services.

The Governance and Nomination Committee (GNC) oversees matters related to corporate governance, Supervisory Board composition and Supervisory Board effectiveness. The GNC plays a critical role in ensuring that the Company and the Supervisory Board are well-governed and that Supervisory Board members are able to effectively carry out their fiduciary responsibilities in line with corporate governance best practices.

Swift conducts its business on the principle of ethics, integrity and trust and similar to all Swift employees. Swift Supervisory Board members are bound to the strictest compliance and ethical standards. Swift has also put in place conflict of interest, anti-bribery and corruption, and whistleblower procedures which are in line with best practice.

In accordance with governance best practices, the Supervisory Board has adopted a standalone Conflict of Interest Policy ensuring that Board members are free from commercial and personal ties that could impair his/her ability to exercise proper supervision and guidance. In addition to the Conflict of Interest procedure required by Belgian Company law, Swift has adopted a specific procedure, should a conflict of interest arise on an item listed on the agenda for which the Supervisory Board has to take a decision. The aim is to prevent that the Board member(s)’s own interest prevails over the Company’s interest.

The Supervisory Board also adheres to Swift’s Code of Conduct and related whistleblowing procedure set out the company’s expected legal and ethical standards and is based on the three core principles of ethics, integrity and trust. Following the code is mandatory and applies to everyone in the company, including Supervisory Board members and employees. The code of conduct is available here. 

The Code of Conduct is supplemented with a specific company-wide Anti-Corruption and Anti-Bribery Policy that conforms to the most stringent anti-corruption and anti-bribery laws and practices. Swift has also put in place stringent anti-bribery and corruption and whistleblower procedures which are in line with best practice. 

Swift is also signatory to the United Nations Global Compact and published its statement on Modern Slavery in compliance with the UK Modern Slavery Act.

Swift’s Chief Internal Auditor has a dual reporting line: a direct functional reporting line to the Chair of the AFC and a direct administrative reporting line to the CEO. Given the sensitivity of external auditors performing consultancy work for management, the AFC annually reviews spending and trends related to external audit firms. To ensure objectivity, the mandates of the external auditors, as well as their remuneration, are approved by the AFC.

The Annual General Meeting of June 2024 approved the appointment of PwC as external financial auditor as proposed by the Board of Directors. This was approved by the works’ council for a mandate of three years ending at the Annual General Meeting of 2027, covering 2024, 2025 and 2026. Their financial Audit Reports can be found in the 2025 Statutory and Consolidated Financial Statements.

Further to its appointment as external security auditor in 2020, in 2025 Deloitte reviewed and examined the adequacy and effectiveness of Swift’s controls in accordance with the ISAE 3000 standard. For the 2025 calendar year, Swift provided five standalone ISAE 3000 Type 2 reports for Messaging Services, Interface Products, Swift Managed Interfaces, ESMIG and AU-NPP. Each report includes Deloitte’s view on design adequacy and operating effectiveness of the control activities that help achieve the control objectives in the areas of risk management, security management, technology management, resilience and user communication (in line with Annex F of CPMI IOSCO’s Principles for Financial Market Infrastructures). The mandate ran until March 2026, however on the recommendation of the Audit and Finance Committee, the Board has reappointed Deloitte as Swift’s external security auditor for another three-year period, covering 2026, 2027 and 2028.

Swift is committed to an open and constructive dialogue with its oversight authorities. The National Bank of Belgium (NBB) acts as the lead overseer, as Swift is incorporated in Belgium, and is supported by the G-10 central banks. The oversight primarily focuses on ensuring that Swift has effective controls and processes to avoid posing a risk to the financial stability and the soundness of financial infrastructures.

Other central banks also have a legitimate interest in, or responsibility for, the oversight of Swift, given Swift’s role in their domestic systems. As is generally the case for payment systems oversight, the main instrument for oversight of Swift is moral suasion.

Overseers place great importance on the constructive and open dialogue that is conducted on the basis of mutual trust with the Swift Board and senior management. Through this dialogue, overseers formulate their recommendations to Swift.

A protocol signed between the NBB and Swift lays down the common understanding of overseers and Swift. The protocol covers the oversight objectives and the activities that are undertaken to achieve those objectives. The protocol is revised periodically to reflect evolving oversight arrangements.

In their review, overseers seek assurances that Swift has put in place appropriate governance arrangements, structures, processes, risk management procedures and controls that enable it to effectively manage potential risks to financial stability and to the soundness of financial infrastructures, to the extent that they are under Swift’s control.  

In 2007 the overseers developed specific oversight expectations applicable to Swift, known as the ‘High level expectations for the oversight of Swift’ (HLEs). The High-Level Expectations document the five categories of expectations that overseers have vis-à-vis the services Swift provides to the global financial infrastructure. The five Expectations relate to: risk identification and management, information security, reliability and resilience, technology planning, and communication with users. 

Overseers review Swift’s identification and mitigation of operational risks, including cyber security, and may also review legal risks, transparency of arrangements and customer access policies. The overseers may also discuss Swift’s strategic direction with the Swift Board and senior management. 

This list of oversight fields is indicative, not exhaustive. Overseers will undertake those activities that provide them comfort that Swift is paying proper attention to the objectives described above. Nevertheless, Swift continues to bear the responsibility for the security and reliability of its systems, products and services. The oversight of Swift does not grant Swift any certification, approval or authorisation.

As lead overseer, the NBB conducts the oversight of Swift together with the G-10 central banks: Banca d’Italia, Bank of Canada, Bank of England, Bank of Japan, Banque de France, De Nederlandsche Bank, Deutsche Bundesbank, European Central Bank, Sveriges Riksbank, Swiss National Bank, and the Federal Reserve System (USA), represented by the Federal Reserve Bank of New York and the Board of Governors of the Federal Reserve System.  

In the Swift Oversight Forum, these central banks are joined by other central banks from major economies: Bank of Indonesia, Bank of Korea, Bank of Mexico, Bank of Spain, Central Bank of Brazil, Central Bank of the Argentine Republic, Central Bank of the Republic of Turkey, Central Bank of the Russian Federation, Hong Kong Monetary Authority, Monetary Authority of Singapore, the People’s Bank of China, Reserve Bank of Australia, Reserve Bank of India, Saudi Arabian Monetary Agency, and South African Reserve Bank. The Swift Oversight Forum provides a forum for the G-10 central banks to share information on Swift oversight activities with a wider group of central banks.

The NBB monitors Swift on an ongoing basis. It identifies issues relevant to Swift oversight through the analysis of documents provided by Swift and through discussions with Swift management. The NBB maintains a close relationship with Swift, with regular ad-hoc meetings, and serves as the central banks’ entry point for the cooperative oversight of Swift.

In this capacity, the NBB chairs the senior policy and technical groups that facilitate the cooperative oversight, provides the secretariat and monitors the follow-up of any decisions taken.

In order to achieve their oversight objectives, the overseers need timely access to all information that they consider relevant. Typical sources of information are Swift Board papers, security audit reports, incident reports and incident review reports. Presentations by Swift staff and management represent another important source of information for the overseers.

Finally, Swift assists the overseers in identifying internal Swift documents that might be relevant to address specific oversight questions. Provisions on the confidential treatment of non-public information are included both in the protocol between the NBB and Swift, and in the bilateral Memoranda of Understanding between the NBB and each of the other cooperating central banks. The official description of the NBB’s oversight role can be found in the Financial Market Infrastructures and Payment Services Report published by the National Bank of Belgium and is available on its website nbb.be.