Preparing Swift CSCF v2026 Assessment: The Checklist for Independent Audits

The course of a Swift assessment is not a product of chance. How smoothly the assessment runs and how quickly it can be completed depends largely on the preparation on the part of the audited organization. Structured preparation creates clarity, reduces frictional losses and forms the basis for an efficientassessment.

Three factors are decisive for an Independent Swift CSCF Assessment

The preparation of an Independent Swift Assessment follows three central themes: understanding the Customer Security Controls Framework (CSCF) and the scope, structured organization and implementation, and consistent follow-up of the results.

Our experts support organizations in the classification and implementation of CSCF requirements with implementation-oriented recommendations.

Customer Security Controls Framework (CSCF): Control 2.4 becomes mandatory

With Control 2.4, the traceable documentation of architecture and data flows becomes the focus of the Swift CSCF assessment.

• Understand CSCF and prepare for the kick-off. Download the latest version of the CSCF from the Swift Knowledge Center.

• Review the new or changed Mandatory Controls. Control 2.4, for example, will be mandatory in 2026.

• Clarify the open questions at the kick-off meeting with the Independent Swift Assessor.
  ▪️Fokus of the assessment (which controls are checked in detail?).
  ▪️Erwartungenon evidence and process.

• A clear assessment of the current Swift architecture; the Service Bureau or assessors can help here if anything is unclear - Swift architecture assessment.
  ▪️HighCreatea level architecture diagram. Swift templates as a basis.
  ▪️Auflistenof all relevant components (Swift infrastructure, firewalls, interfaces).
  ▪️DataFlow diagram (optional, but recommended). Mandatory for SNB SIC assessments and from 2026 for Swift (Control 2.4). Document data flows between back-office systems, Swift and external partners.

• Prepare evidence for the assessment. The Swift "High Level Test Plan" (CSP_controls_matrix_and_high_test_plan_20xx_v1.0.xlsx) contains a list of possible evidence per control in the "Test Plan and Evidence" tab (column "Supporting Evidence"). Electronic evidence is sufficient (no printouts required). Showing a Group Policy (GPO) in Active Directory as evidence is sufficient.

• Policies: IT security policies, password policies such as GPO in Active Directory.

• Technical evidence such as screenshots or live demos of: Malware protection dashboards such as EDR or XDR; vulnerability scan reports, for example Nessus, or Qualys; firewall rules, network segmentation;

• Process documentation: change management, patching, user administration (onboarding/offboarding)

• Live configurations showing a Group Policy (GPO) in Active Directory as evidence are also sufficient. Directly in the system of relevant components (e.g. AD, firewall, scans).

Organization and implementation: How the Independent Swift Assessment succeeds

Even with good preparation, the organization of the implementation determines how efficient and targeted an Independent Swift Assessment is. Clear responsibilities, availability of the relevant specialists and structured implementation contribute significantly to a smooth process.

The following points support the structured implementation of the Independent Swift Assessment:

• Organize swift assessors who have the necessary qualifications (including certifications, experience) and independence - either internal 2nd/3rd Lines of Defense (e.g. internal audit) or external assessors.

• Booking a meeting room with a stable internet connection and projector early on saves a lot of trouble. It may sound trivial, but an assessment is better conducted in a meeting room than in the company cafeteria. Having to change meeting rooms every two hours does not improve the mood of any participant.

• Select a Swift assessor. Check qualifications (certifications, Swift experience) and independence.

• Ensure that the specialists (SMEs) for topics such as network, firewall, awareness are available.

• List of participants: Main contact person (e.g. CISO) for organizational issues with little access to the above-mentioned dashboards and technical data. Technical contact person for live demos with extended access to the systems and technical data.

• All of these subject matter experts should either be available on the day of the assessment or a deputy with identical access authorizations should be available: client management, patching, network, firewall, security administration, risk management, change management, supplier management, IT security awareness campaigns, user administration including onboarding/offboarding, etc.
  

Systematic follow-up: how to master the upcoming assessments

The follow-up of an Independent Swift Assessment goes beyond the individual test cycle and forms the basis for future assessments.

• Check the assessment report for discrepancies.

• Create an action plan for identified gaps.

• Check annually with the assessor whether the architecture and evidence still comply with the CSCF.

Swift assessment: structured support from preparation to implementation

With new mandatory controls such as Control 2.4 "Back Office Data Flow Security", the requirements for transparency, documentation and controllability of Swift architectures are increasing noticeably. What is required is not additional documentation for its own sake, but a reliable basis that clearly shows data flows, dependencies and responsibilities in the assessment.

Structured preparation, clean implementation and consistent follow-up create precisely this basis. They reduce frictional losses in the assessment, increase its informative value and facilitate the sustainable implementation of identified fields of action.

Our experts support organizations in classifying CSCF requirements and conducting Independent Swift CSCF Assessments - with clear results and implementation-oriented recommendations.

The aim is an assessment that not only fulfills formal requirements, but also makes a measurable contribution to strengthening cyber resilience.

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