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Swift CSP · Customer Security Programme

Swift CSP attestation and requirements support for a Swift footprint your counterparties can trust.

Meet the Customer Security Controls Framework, pass your independent assessment and attest accurately in KYC-SA before 31 December, every year. Sterling's expert and experienced consultants close the control gaps with your teams and assemble the evidence your assessor will test, in 60+ countries. We help our clients put it into practice and prove it.

  • Fixed scope, one proposal: consulting, Effivity software, Sterling Academy access and internal auditor training, as applicable to your framework, in one proposal
  • A team of expert and experienced security consultants, advising on control frameworks across sectors and countries since 2003
  • The Sterling Promise: 100% on-time completion, 100% success, 8,100+ client engagements. Sterling does not attest or assess; you attest, and an independent assessor validates your controls first

8,100+ client engagements in 60+ countries.

Swift CSP client experience
  • Allianz
  • Emirates Flight Catering
  • Etihad Rail
  • Haier
  • Whirlpool
  • Emerson
  • Olam
  • Piramal Pharma Solutions

What it is

What is the Swift Customer Security Programme?

The Customer Security Programme is Swift's mandatory initiative for protecting each user's Swift footprint against cyber threats. Swift, often written SWIFT, owns the programme and its Customer Security Controls Framework (CSCF), which sets the security baseline for the local environment through which an institution connects to Swift. It contains mandatory controls and advisory, good-practice controls.

Each year you implement the controls that apply to your architecture, have them validated by an independent assessment and attest your compliance in Swift's KYC-SA application, where counterparties and supervisors can see it.

Current version. Swift publishes a new CSCF version every July, a year before it comes into effect, and users have up to 18 months to prepare for new or changed controls. Attestations in the 2026 cycle, which closes on 31 December 2026, are made against CSCF v2026. Swift has already published CSCF v2027 for the 2027 cycle, so a first programme started today should plan against both.

Who it is for

Who needs a Swift CSP attestation?

Every Swift user is in scope, whether it runs its own components or connects through a provider; the architecture type decides which controls apply. Institutions come to Sterling from four starting points:

  • Counterparties are checking your attestation. Counterparties review KYC-SA status in third-party risk management. A gap or a missed remediation date prompts difficult questions.
  • A new connection or architecture change is coming. A new provider or connectivity model can change your architecture type and controls in scope.
  • Your supervisor takes an interest. Supervisors can see attestation results. They ask how controls are validated, not only whether a form was filed.
  • Group or shared infrastructure complicates the picture. Shared teams or providers do not change the rule: each attestation must describe the real environment.

Requirements

What are the main Swift CSP requirements?

The CSCF groups its controls under three objectives, inside an annual cycle of assessment and attestation. This is a plain-language map; your implementation is checked against the applicable CSCF version for your architecture type.

  • Architecture type: identify which of Swift's five architecture types describes your set-up, using Swift's architecture decision tree, since it decides which controls apply.
  • Secure your environment: restrict internet access, reduce the attack surface and physically secure the systems in scope.
  • Know and limit access: prevent credential compromise, manage identities and segregate privileges.
  • Detect and respond: detect anomalous activity and plan how you will respond to incidents.
  • Mandatory and advisory controls: meet every mandatory control that applies to you; treat the advisory controls as recommended good practice.
  • Independent assessment: have the design and implementation of your controls validated by a second or third line of defence, such as risk, compliance or internal audit, or by an external independent assessor.
  • Attestation in KYC-SA: record your compliance for each applicable control between 1 July and 31 December; for any control not yet met, give a remediation date and update the attestation once compliant.

What does useful Swift CSP evidence look like?

An architecture diagram matching the decision tree, a component inventory, hardening and patching records, privileged access reviews, monitoring outputs, tested incident plans and the assessment report with findings closed. We build this set once and refresh it each cycle in Effivity.

Attestation route

How does Swift CSP attestation work?

There is no certificate in the Customer Security Programme. Your institution attests its own compliance, and the attestation must rest on an independent assessment of your controls.

  1. 01
    Confirm the architecture type and the controls in scope.Use Swift's decision tree, map in-scope components and agree the applicable controls.
  2. 02
    Gap analysis: compare your environment with the CSCF.Each control is tested against what operates today; gaps get owners and dates.
  3. 03
    Remediate and build the evidence.Technical changes, procedures, training and records, so each control can be demonstrated.
  4. 04
    Complete the independent assessment.Your second or third line, or an external assessor, validates design and implementation; we prepare the evidence and help close findings.
  5. 05
    Attest in KYC-SA and plan the next cycle.Submit before 31 December, give remediation dates for open items and start on the next version.

Check the route before you sign. If you use an external assessor, confirm their independence from the team that built the controls and check Swift's Directory of Swift CSP Certified Assessors. If you use your own second or third line, make sure it is genuinely separate from the first line. After submission, confirm that your attestation shows as published in KYC-SA.

Cost

How much does Swift CSP compliance cost?

No single price fits every Swift user. A user connecting through a provider has fewer controls in scope than one operating its own components across several sites. We promise a proposal with every component visible and an all-inclusive proposal.

Cost componentWhat affects it
Consulting and remediation supportArchitecture type, number of in-scope components and sites, current maturity and how much of the work your team takes on (Design™ or Drive™)
Independent assessmentWhether your own second or third line assesses, or an external assessor, and the scope and locations they must cover
Technology changesAny infrastructure, tooling or configuration changes the gap analysis identifies
Internal resourcesOperator, security, IT and management time
Software and learningIncluded in a Sterling engagement: Effivity for the programme and Sterling Academy access for your people, with users, courses and access period confirmed in the proposal
Continued supportAnnual version changes, re-assessment and attestation under Sustain™

What moves the price

  • Architecture type and the number of components you operate yourself
  • Sites, data centres and entities covered by the attestation
  • Whether previous attestations and assessments are reliable
  • How close the 31 December deadline is
  • Alignment with ISO/IEC 27001, PCI DSS or SOC 2 work already in place

What a Sterling proposal always shows

  • Deliverables, responsibilities, assumptions and exclusions, in writing
  • External assessor fees identified separately, so the full programme cost is comparable
  • Effivity, training and Academy access itemised at no additional cost
  • Payment milestones tied to deliverables, not to the calendar
  • One all-inclusive proposal. No surprises, ever

Timeline

How long does Swift CSP compliance take?

The fixed point is the attestation window, 1 July to 31 December. The pace depends on the gaps, change lead times and the assessor's schedule. As an estimate, a first programme typically takes three to six months; a well-run renewal is quicker because it only has to absorb the new version's changes.

PhaseWhat determines the pace
Architecture review and gap analysisAccess to diagrams, component inventories, previous attestations and the people who run the environment
RemediationThe number and depth of gaps, change windows, procurement and vendor lead times
Independent assessmentAssessor availability, sampling of evidence and the time needed to close findings
AttestationInternal approvals and submission in KYC-SA before 31 December

With each version published about 18 months before its deadline, start next year's changes soon after this year's submission.

Your engagement

What your Swift CSP engagement includes

Sterling does not attest or assess: your institution submits the attestation, and the independent assessment is performed by your second or third line or an external assessor. Under Sterling OS™ you choose one support level: Design™, where we guide and your team does the work, or Drive™, where we manage and carry most of it. Automate™ runs the programme in Effivity, and Sustain™ keeps it current through every later cycle and version change.

  • Architecture review, gap analysis and plan

    Decision tree confirmed, controls in scope agreed, and actions with owners and dates.

  • Procedures and control documentation

    Written for your operators and security team, on Sterling's own templates, mapped to each applicable control.

  • Effivity ISO & GRC software

    Controls, evidence and findings managed in Effivity from day one, included with the engagement at no additional cost.

  • Training for everyone

    Internal auditor training for the people who review your controls, as applicable to your framework, and preferential Sterling Academy access, including complimentary awareness training for your people as part of the engagement.

  • Pre-assessment review

    We test your controls the way an assessor will and close findings with evidence before the independent assessment begins.

  • Assessment and attestation support

    Evidence packs for the assessor, help closing findings and a completeness check before you submit in KYC-SA.

The independent assessment remains with your second or third line or external assessor, and the attestation remains yours.

How Sterling implements ISO and GRC standards

Effivity · GRC software for Swift CSP, included in every engagement

How Effivity helps you fulfil, automate and simplify the requirements of Swift CSP.

Every Sterling Swift CSP engagement includes Effivity, the ISO and GRC automation platform built by the Sterling group and used in 50+ countries. Your consultant configures the workspace within the agreed scope, so documents, risks, audits, nonconformities, training records and management review sit in one place, each control carries its evidence and your assessor reviews a live record rather than a folder. Sterling consulting clients get their Effivity subscription included with the engagement, at no additional cost.

Effivity GRC workspace with controls, owners and evidence status
Effivity GRC · control and evidence dashboard
Scope

Architecture and components

The architecture type, component inventory and diagrams held together and reviewed when the set-up changes.

Governance

Policies, roles and owners

Security policies, responsibilities and control owners recorded where the people who own them work.

Risk

Risks and treatments

A risk register with owners, actions and review dates, followed to closure.

Secure your environment

Hardening and change records

Configuration, patching and change evidence captured as the work is done.

Know and limit access

Access reviews and training

Privileged access reviews and operator training records, each with dates and approvals.

Detect and respond

Incidents and tests

An incident register and response plan tests with lessons recorded.

Assessment

Audits and findings

Pre-assessment and independent assessment findings raised, investigated and closed with evidence.

Across the system

Your own forms and reports

Forms, workflows and reports adapted to how you work, without code, including a control-by-control status view for attestation.

What this means at the assessment

The assessor asks for the architecture evidence, access reviews, hardening records, incident tests and the status of last year's findings. In Effivity each is a screen with owners, dates and attachments, not a pack assembled in December. Sustain™ runs in the same workspace, so next year's version starts from a system that kept running.

In your engagement

  • Subscription included with the engagement, at no additional cost
  • Configured by your Sterling consultant within the agreed scope
  • Your existing documents and records migrated, not retyped
  • Admin and user training for your team
  • Modules for ISMS and other standards when you integrate frameworks

Sterling Academy · e-learning for your people

Build security awareness beyond the Swift operations team.

Sterling Academy delivers e-learning for the whole workforce and for the people who run your controls: video lessons with practice checkpoints, a final exam and a numbered Certificate of Completion for each learner, verifiable online. Sterling consulting clients benefit from preferential course access and special pricing through their Sterling consultant, including complimentary awareness training for their people as part of the engagement.

  • Awareness training for every employee, with records of completion
  • Practitioner learning for control owners and the security lead
  • Internal auditor training for the people who review your controls, as applicable to your framework, as part of the engagement
  • Learner progress by department and a training status report for your assessor
  • New operators trained as they join, so evidence is current each cycle
  • A Sterling consultant reachable when a learner needs one

Why Sterling

Why choose Sterling for Swift CSP compliance?

Whether you run one entity or many, Sterling helps you operate one consistent control programme with local ownership, so each attestation is accurate and each assessment predictable.

Security programmes in 60+ countries since 2003

Control frameworks implemented for financial institutions, service providers and technology firms, with one engagement team accountable across your entities.

All-inclusive proposal

Consulting, Effivity, training and Academy access in one proposal, with external assessor fees identified separately. No surprises, ever.

Evidence built once, reused

Controls mapped across Swift CSP, ISO/IEC 27001, PCI DSS and SOC 2 where you hold them, so your teams answer each question once.

Expert and experienced consultants

Consultants who have advised on security controls across sectors and countries since 2003, and who prepare your environment so the independent assessment confirms what already works.

Sterling vs the rest: the full comparisonExplore Swift CSP client experience

The Sterling Promise

What our Swift CSP success guarantee means

100%on-time completion · success · 8,100+ client engagements

We stay with you until your agreed Swift CSP outcome is achieved, supporting implementation, assessment preparation and the resolution of findings. Clear explanations, practical delivery, included software and employee learning turn the investment into lasting capability rather than a yearly scramble.

The engagement identifies the framework, architecture, scope, outcome and responsibilities. Your institution supplies accurate information and operates the agreed controls. The independent assessment is performed by your second or third line or an external assessor, and the attestation is yours. Our commitment concerns the agreed readiness support, not a promise about any counterparty's or supervisor's view.

FAQs

Frequently asked questions about Swift CSP

Is Swift CSP attestation mandatory?

Yes. Swift describes the Customer Security Programme as mandatory, and users attest their compliance each year in the KYC-SA application. The window runs from 1 July to 31 December, and the attestation must be supported by an independent assessment.

What if we cannot meet a mandatory control by 31 December?

You attest your actual status and give a remediation date for each control not yet met, then update the attestation once it is compliant.

Can our internal audit team do the Swift CSP independent assessment?

Yes. Swift allows the assessment to be performed internally by a second or third line of defence, such as risk, compliance or internal audit, or externally by an independent assessor.

Does ISO/IEC 27001 or PCI DSS cover Swift CSP?

Not on its own. Swift notes that its controls align with ISO/IEC 27002, PCI DSS, SOC 2 and the NIST Cybersecurity Framework, so much of your evidence can be reused, but the attestation is made control by control against the CSCF for your architecture.

Does Sterling attest or perform the independent assessment for us?

No. Sterling provides consulting and readiness support. Your institution submits its own attestation, and the independent assessment is carried out by your second or third line or by an external assessor you appoint.

Keep exploring

More on Swift CSP and related standards

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