Comparison of global securities settlement discipline regimes: report

How does South Africa’s settlement discipline regime compare with other major global markets?

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Explore how settlement discipline operates across South Africa, the EU, Hong Kong, the UK and the US, and what global practices could mean for South Africa as markets move towards T+1.

Fines remain low

South Africa

Graphic showing ZAR 2.36 million in total annual fines projected for 2025.

Overall market materiality remains exceptionally low.

Despite processing ZAR 167 trillion in annualised settlement value, Strate’s total annual fines pool reached just ZAR 2.36 million in 2025.

Cross-border friction

Foreign Clients

A graphic displaying 82.8% related to equity fines.

Foreign clients represent most of this friction.

Foreign clients drive the majority of settlement friction in South Africa, accounting for 82.8% of equity fines and 66.1% of bond fines.

Millions of penalties

13.88 million cash penalties processed in 2025 with an upward trend arrow.

EU’s micro-penalties often cost more to process than their value.

T2S processed 13.88 million cash penalties in 2025, with an average value of just EUR 38.60 per penalty.

South Africa currently achieves a settlement efficiency rate of 99%, supported by a settlement discipline model that differs significantly from those used across other major markets.

This report compares settlement discipline regimes across South Africa, the European Union, Hong Kong, the United Kingdom and the United States, examining their structure, enforcement, fine materiality and effectiveness.

The report explores:

How settlement discipline frameworks differ across five major markets
How fines and enforcement mechanisms compare in structure and materiality
The role of foreign participation in South Africa’s settlement friction
How different approaches translate into settlement efficiency
What the transition towards T+1 could mean for South Africa’s existing model

With global markets continuing to accelerate settlement cycles, the report considers which elements of South Africa’s current regime should be preserved and where operational enhancements could strengthen its resilience.

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