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Supply chain finance in the EU: Part 3 – making SCF transparent: data standards, repositories and servicer governance

27 February 2026 / Author(s): Dr Michael Huertas, LLM, MB
Issue: March 2026 / Categories: Feature

This article operationalises a critical framework for enhancing transparency and resilience in EU supply chain finance (SCF) particularly for non-securitised transactions. It addresses the prevailing opacity by proposing a concrete market architecture comprising proportionate machine-readable data standards an access-controlled repository model and baseline servicer governance aligned with existing EU regulatory regimes such as the Digital Operational Resilience Act (Regulation (EU) 2022/2554) (DORA). The objective is to replace fragmented information with consistent programme data lifecycle traceability and reliable operational safeguards across bank and nonbank sponsors. By advocating for a European Securities and Markets Authority-supervised repository interoperable with e-notice solutions the framework aims to significantly reduce search costs curb double-pledging risks improve price formation and bolster day-to-day servicing resilience. Ultimately these measures will foster a more transparent efficient and robust SCF market directly benefiting small and medium-sized enterprises and advancing the broader...

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