July 23, 2026
By: Intellect
The challenges facing custodians in 2026 come down to one problem: the cost of running a custody business is rising faster than the fees it earns.
If that matches what your own numbers are telling you, this guide is written for you. It walks through the pressures behind the squeeze, what each one costs you, which dates matter, and where to start.
TL;DR
- The top challenges facing custodians in 2026 are settlement compression, corporate actions risk, regulatory accountability for AI and resilience, and legacy systems, all feeding one margin squeeze.
- The costs are countable: an average regional corporate actions team runs $3 to 5 million a year, and 46 percent of event messaging is still manual, per the ValueExchange.
- The workable response is sequenced: settlement automation first, then the evidence layer, then asset servicing, then AI on exceptions.
What are the top challenges facing custodians in 2026?
If you run custody or post-trade operations, four challenges are competing for your budget this year, and every one of them feeds the same margin squeeze. They are settlement compression under T+1 Settlement, corporate actions and asset servicing risk, regulatory compliance accountability for artificial intelligence (AI) and operational resilience, and the legacy systems beneath them all.
Settlement compression is the one already reshaping your day. Trades that once had two days to settle now have one. The US made that move in May 2024, India already operates this way with an optional same-day cycle beyond it, and European markets follow in October 2027 with cut-offs that apply to any custodian settling there, wherever it is headquartered.
The change sounds small. It is not, because one day means your team loses the overnight window it has always used to catch and fix errors. Anything not automated has to be found and repaired within hours, which is why Straight-Through Processing (STP) now decides whether you settle at all, and why these post-trade challenges and custody operations challenges win budget arguments they used to lose. The US experience shows the fix works, with same-day trade confirmation rising from 73 percent to nearly 95 percent around its transition, per the SIFMA, ICI and DTCC after-action report.
Why do corporate actions remain the costliest asset servicing challenge?
Ask yourself where your operations money actually goes, and corporate actions almost certainly come first. Running them costs an average regional team between $3 million and $5 million a year, with headcounts running into the hundreds, according to the ValueExchange’s Reimagining Corporate Actions research. The same research found 46 percent of notification messaging is still manual.
The reason these asset servicing challenges resist automation is structural, not a failure on your part. Announcements arrive unstructured, across formats and languages, and voluntary events add client elections under tight deadlines. If your team still re-keys event data from PDFs, you are carrying both the cost and the risk, and one missed election can erase a year of fee income on the account.
The known remedy is standardisation before intelligence. The ValueExchange found ISO 20022 adoption can lift STP by more than 30 percent for complex voluntary events, and outsourced data management can bring the average cost below $2 million. Of all the challenges in custody services, this is the one where the fix is proven and the savings are countable, which makes it the strongest internal case you can build this year.
What do regulators expect from you on resilience and AI?
Wherever your custody business operates, your regulators are converging on the same demand. They want proof from production systems, not policies on paper. The pain point is that the proof is being asked for in several jurisdictions at once, and the question you need answered is whether one set of controls can satisfy all of them.
The direction is clearest in India. SEBI’s Intermediaries (Amendment) Regulations 2025, notified 10 February 2025, make every regulated entity solely responsible for the output of the AI and machine learning tools it uses, whether built in-house or procured from a vendor, along with the privacy and security of investor data those tools touch. You cannot outsource accountability with technology. SEBI’s June 2025 consultation on responsible AI goes further, proposing designated senior management accountable for model governance, testing and monitoring. Europe is moving the same way from a different starting point:
DORA has pulled major cloud providers under direct oversight since November 2025 while leaving your own third-party risk accountability untouched, and the EU AI Act’s obligations for high-risk systems apply from 2 August 2026 to systems placed on the EU market wherever the provider sits.
The practical answer to your question is yes, one artifact serves them all. Operational resilience testing, SEBI’s output responsibility and AI oversight each come down to a decision log a named executive can stand behind. Regulatory compliance in custody is becoming an engineering question, and financial institutions that build the evidence layer separately for each regime pay for it several times over. When your board asks whether you are exposed, that log is the one-page answer.
How do the challenges facing custodians differ in India and other fast-growth markets?
If your business spans geographies, the pressures do not arrive in the same order everywhere, and the view from India makes that clear. European custodians are compressing toward a transition date, while Indian custodians already live past it.
India runs T+1 with an optional T+0 cycle alongside it, which SEBI expanded to the top 500 stocks in phases from 31 January 2025, with custodians explicitly tasked with facilitating institutional participation. Broker readiness timelines have been extended twice, most recently on 30 October 2025, which tells you how hard same-day readiness is even in a market that has already moved once.
In these markets the challenge is capacity, not compression. If you are a new entrant, including the NBFCs moving into custody, you need settlement, corporate actions and reporting from day one, because building a settlements back office from scratch at T+1 speed is not a realistic entry path.
Whichever side you operate on, the pressures meet in the middle. The challenges facing custodians differ by market in their dates, and almost not at all in their fixes.
Where should you start?
Your budget cannot fund all four challenges at once, so the practical question is order. Custody modernization works as four layers, funded in deadline order:
- Automate the settlement chain to meet the end-2026 allocation and confirmation cut-offs.
- Instrument the evidence layer with decision logs and provenance for resilience and AI accountability.
- Modernize corporate actions and wider securities services on that governed data.
- Apply AI to exception management once the records underneath it can be trusted.
The order matters because each layer attacks your margin problem from a different side. Settlement automation removes penalty and repair cost. The evidence layer stops you paying for compliance several times over. Corporate actions automation converts your most expensive manual function. An AI agent working an exceptions queue on unreconciled data just fails faster, which is why intelligence comes last.
The stack is also why cloud-native platforms adopted module by module have displaced big-bang replacement among the custody technology trends that survive contact with a budget committee. Your legacy custody systems rarely justify replacement before October 2027, and they do not need it.
eMACH.ai elementalises custody services into discrete business bricks, custody, fund accounting, and transfer agency among them, so you adopt what the deadline requires and nothing else. eMACH.ai Custody has recently secured three wins at non-banking financial institutions across India and South Asia, reflecting the growing demand for digital transformation in custody.
The limits deserve equal weight. No platform fixes issuer data quality at source, and no automation moves accountability for a failed settlement off the executive who owns it.
Conclusion
The challenges facing custodians in 2026 share one root, costs rising faster than fees, and one test, evidence that a supervisor and a client can both inspect. The custodians’ challenges of 2026 will not shorten as a list next year, but one sequenced investment can answer several at once. Fund the settlement chain first, build the evidence layer once, and let asset servicing and AI ride on it. Digital transformation in custody succeeds in deadline order or not at all.
Frequently asked questions
1. Who is liable when an AI tool bought from a vendor makes an error?
The regulated entity, not the vendor, under SEBI’s Intermediaries (Amendment) Regulations 2025. Sole responsibility for AI and machine learning output applies whether the tool was built in-house or procured, which means your vendor contracts need audit rights and model-change notifications, because the regulatory exposure stays on your licence either way.
2. What should an AI decision log actually contain?
Enough for a named executive to reconstruct the decision: the inputs the system saw, the output it produced, the model version that produced it, and who reviewed or overrode it. That single record answers resilience testing and AI accountability at once, which is what keeps the challenges in custody services from each demanding their own separate compliance build.
3. Is India moving to T+0 settlement?
Optionally, alongside T+1. SEBI expanded the optional same-day cycle to the top 500 stocks in phases from 31 January 2025, with custodians facilitating institutional participation, and broker readiness deadlines have been extended twice, most recently in October 2025, reflecting the operational difficulty of same-day readiness.
4. Do custodians need to replace legacy custody systems before October 2027?
No, replacement is not a precondition. Composable platforms adopt custody functions module by module on top of legacy custody systems, which is the approach Intellect’s eMACH.ai Custody takes with its business-brick architecture. The trade-off is that settlement automation and data governance still need investment first, since no layer performs better than the records beneath it.


