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 experienceWhat 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.
- 01Confirm the architecture type and the controls in scope.Use Swift's decision tree, map in-scope components and agree the applicable controls.
- 02Gap analysis: compare your environment with the CSCF.Each control is tested against what operates today; gaps get owners and dates.
- 03Remediate and build the evidence.Technical changes, procedures, training and records, so each control can be demonstrated.
- 04Complete the independent assessment.Your second or third line, or an external assessor, validates design and implementation; we prepare the evidence and help close findings.
- 05Attest 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 component | What affects it |
|---|---|
| Consulting and remediation support | Architecture type, number of in-scope components and sites, current maturity and how much of the work your team takes on (Design™ or Drive™) |
| Independent assessment | Whether your own second or third line assesses, or an external assessor, and the scope and locations they must cover |
| Technology changes | Any infrastructure, tooling or configuration changes the gap analysis identifies |
| Internal resources | Operator, security, IT and management time |
| Software and learning | Included 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 support | Annual 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.
| Phase | What determines the pace |
|---|---|
| Architecture review and gap analysis | Access to diagrams, component inventories, previous attestations and the people who run the environment |
| Remediation | The number and depth of gaps, change windows, procurement and vendor lead times |
| Independent assessment | Assessor availability, sampling of evidence and the time needed to close findings |
| Attestation | Internal 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.
Often combined with
Standards organisations pair with Swift CSP
- ADHICS (Abu Dhabi)ADHICS compliance consulting for DoH-regulated healthcare entities in Abu Dhabi: patient information, systems and devices protected, with audit-ready evidence.
- AML / CFT programme (FATF)AML/CFT compliance programme built on the FATF Recommendations: risk assessment, due diligence, monitoring, reporting, records and training, in one all-inclusive proposal.
- APRA CPS 234 and CPS 230APRA CPS 234 and CPS 230 compliance for banks, insurers and super funds: information security, operational risk, continuity and service providers, all-inclusive proposal.
- Basel and UK operational resilienceOperational resilience compliance for PRA and FCA firms: important business services, impact tolerances, mapping, scenario testing and the Basel principles.
- BSP circulars (Philippines)BSP circulars compliance for Philippine banks and BSFIs: IT risk management, information security, business continuity and outsourcing, in one all-inclusive proposal.
- CBUAE regulationsCBUAE compliance and requirements for licensed institutions: operational risk, cybersecurity, continuity, outsourcing and consumer protection, in practice.
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.

Architecture and components
The architecture type, component inventory and diagrams held together and reviewed when the set-up changes.
Policies, roles and owners
Security policies, responsibilities and control owners recorded where the people who own them work.
Risks and treatments
A risk register with owners, actions and review dates, followed to closure.
Hardening and change records
Configuration, patching and change evidence captured as the work is done.
Access reviews and training
Privileged access reviews and operator training records, each with dates and approvals.
Incidents and tests
An incident register and response plan tests with lessons recorded.
Audits and findings
Pre-assessment and independent assessment findings raised, investigated and closed with evidence.
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
Keep exploring
Explore more about Swift CSP
Swift CSP resources
Services for Swift CSP
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.
The Sterling Promise
What our Swift CSP success guarantee means
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
More in Financial services, payments & AML
Talk to a consultant
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