When markets stop closing: EU readiness for 24/7 trading and instant settlement

RegCORE Client Alert | Capital Markets Union + Savings and Investment Union

QuickTake

The EU is ready to lengthen trading hours—but not yet ready to treat the securities market as a single, continuously operating legal and operational system. This distinction matters. A venue can accept orders overnight even while the CCP, CSD, central-bank money, corporate-action and supervisory layers still run to business-day clocks. The result is not an “always-on market” but a longer front end attached to intermittently available rails.

The immediate question is not whether EU law permits a venue to stay open longer—in most cases it can, provided systems, controls, disclosures and rulebooks remain compliant. The harder question is what happens to the trade when other market functions are closed.

T+1, extended hours and instant settlement are separate projects. The EU’s move to T+1 on 11 October 2027 compresses a batch-based cycle; it does not abolish cut-offs, pre-funding, netting, fails management or the settlement day itself. Tokenisation does not solve the timing problem by definition. DLT may combine trading and settlement, but access to the cash leg, collateral, identity, custody, corporate actions and public-law intervention remains a matter of design and legal choice.

The largest regulatory gap is temporal rather than substantive. MiFID II, MiFIR, MAR, EMIR, CSDR, the Settlement Finality Directive and DORA contain powerful controls—but they do not yet specify the response time, staffing model or cross-border command structure for a market event that can become irreversible within seconds at 03:00 CET. Firms should therefore treat 24/7 trading as a target operating model, not simply a change to opening hours. Product design, client disclosures, best execution, market surveillance, liquidity, treasury, incident response, legal finality and supervisory escalation all need to be mapped to the same clock.

What peers are saying

The policy debate is moving quickly but remains fragmented. The Federation of European Securities Exchanges (FESE) is broadly confident that Europe can support venue-led extensions, provided that reporting, transparency, settlement, corporate-action, staffing and cyber issues are managed.Federation of European Securities Exchanges (FESE), “Note on 24-hour Trading in Europe” (8 May 2025).Show Footnote The International Organization of Securities Commissions (IOSCO) is more cautious: extended sessions may display thinner liquidity, wider spreads and trading conditions that differ materially from the main session.IOSCO, “Extended Trading Hours” (May 2026).Show Footnote The World Federation of Exchanges identifies the practical middle ground. A venue can extend its hours, but asynchronous CCP, CSD and RTGS windows make end-to-end continuity a coordination problem.Kaitao Lin, “Extending Exchange Trading Hours” (World Federation of Exchanges, 20 February 2026).Show Footnote These positions do not necessarily conflict. They test readiness at different points in the transaction chain.

That divergence is useful. It shows that “readiness” depends on the layer being tested. The trading venue may be ready; the market as a legal chain may not be.

How other jurisdictions are approaching the same question

The EU is not acting in isolation. Other jurisdictions are testing extended-hours models, and their experience offers useful reference points:

• United Kingdom. UK authorities and market infrastructures are examining longer payment and settlement windows, while the United Kingdom plans to move to T+1 on 11 October 2027 alongside the EU and Switzerland. The Bank of England has decided to move the start of CHAPS settlement from 06:00 to 01:30,Bank of England, 'Extending RTGS and CHAPS settlement hours: early morning extension' (Policy Statement, 24 February 2026)Show Footnote with implementation targeted for September 2027, while continuing work towards broader availability. These developments may support longer trading sessions, but they do not yet amount to an end-to-end 24/7 securities-market model.
• United States. US equity markets have long offered pre-market and after-hours sessions, although liquidity and price formation may differ materially from the core session. The SEC’s approval of 24X National Exchange and other venue proposals demonstrates regulatory openness to substantially longer securities-trading hours, subject to infrastructure, rulebook and investor-protection conditions. Separately, crypto-assets trade continuously on a mixture of regulated and offshore platforms. Those markets provide evidence of the operational and conduct risks that can arise outside conventional business hours, but they should not be treated as a single regulated-market model.For contrast only: Securities and Exchange Commission, In the Matter of the Application of 24X National Exchange LLC for Registration as a National Securities Exchange, Release No 34-101777, File No 10-242 (27 November 2024) available here.Show Footnote
• Asia-Pacific. A number of Asian derivatives markets already operate evening or night sessions designed to overlap with European or US trading. The relevant lesson is not that the region has achieved end-to-end 24/7 settlement. It is that venues can extend front-end access more quickly than the accompanying CSD, CCP, payment, collateral and central-bank-money infrastructure. Any named example should identify the relevant product and actual session hours and should not describe an existing night session merely as an initiative being explored.

For EU-headquartered firms with global operations, the practical implication is that extended-hours capabilities developed for one jurisdiction may be reusable elsewhere—but the regulatory perimeter, settlement mechanics and supervisory expectations must be mapped market by market.

A longer trading day is not yet a continuously operating market

A venue may accept orders while the CCP, CSD, central-bank money, securities-lending, corporate-action and supervisory layers remain unavailable. The legal and commercial question is therefore not simply whether a venue may stay open. It is what the transaction becomes, who carries the risk and which authority can intervene while the rest of the chain is closed.

The questions firms should now answer

• Target state: Is the project an extended conventional session, continuous trading with deferred post-trade, or genuine continuous delivery-versus-payment?
• Settlement asset: Which security and cash assets are legally transferred, and when does each transfer become final? 
• Operating clocks: Which venue, CCP, CSD, payment, collateral, valuation and corporate-action windows remain discontinuous?
• Market controls: Are surveillance, price collars, circuit breakers and best-execution processes calibrated for overnight liquidity?
• Intervention: Who may halt or constrain activity out of hours, through which technical channel and within what maximum response time?
• Client position: Do disclosures and contracts allocate the basis, funding, custody and operational risks created by asynchronous market functions?