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At the end of 2025, the ICC Banking Commission requested feedback from its members as to whether it was time for a revision of UCP 600 and/or an update to ISBP 821. Members were asked to submit their responses by 12 January. The following are the results of the (limited) responses that were received as well as the suggested next steps.

An analysis has been provided of the comments that accompanied the voting, as well as the questions the ICC Secretariat is now putting to ICC National committees attention regarding next steps on a possible rule revision for UCP 600 and a possible update for ISBP 821. Each ICC National committee, after consultation with its members, is required to provide its answers to the survey by close of business 27 February 2026. 

Discussion Paper (for National Committees)

Subject: ISBP 821 and UCP 600: revision and the role of education

Summary of the ISBP 821 revision consultation paper

The ISBP 821 revision paper captured market feedback on whether the remaining unresolved issues following the last revision justify proceeding with a further formal update to ISBP 821. 

Overall, the responses reveal a clear scepticism about the need for a revision at this stage. Although respondents acknowledge that a number of outstanding issues remain, these are widely characterised as either sporadic, niche, or capable of being addressed through alternative mechanisms such as Technical Advisory Briefings, ICC Opinions, or structured education

A recurring theme is that ISBP is clarified as an interpretative companion to UCP 600 rather than a rulebook in its own right. Concerns are raised that repeated revisions risk making ISBP more complex and less accessible, undermining its primary value as a practical, operational guide for day-to-day examination.

Where there is strong alignment across responses is on objectives, should any revision proceed. Clarity is overwhelmingly identified as the dominant priority, followed closely by consistency with UCP 600 and careful, incremental digital alignment. Respondents are clear that digital developments should be reflected cautiously, avoiding speculation and premature standard-setting in areas where no settled international banking practice yet exists. 

The prevailing conclusion is that education, wider access to ISBP materials, and improved ICC guidance would deliver greater practical benefit than a further revision at this time.

Summary of the UCP 600 Revision consultation paper

The UCP 600 consultation paper presented a broad and nuanced set of views on whether the core rules governing documentary credits, last revised in 2007, now require updating.

Although a minority of respondents argue that the age of the rules alone justifies a review, the majority position is more restrained. Most contributors do not see systemic inadequacy in UCP 600 as it stands, emphasising that the rules continue to function effectively when correctly understood and applied. Where problems arise, they are more often attributed to lack of training, inconsistent application, or unrealistic commercial expectations rather than deficiencies in the text itself 

That said, the paper highlights several areas where respondents believe targeted refinement could be beneficial. Digital alignment dominates the discussion, particularly the growing prevalence of electronic documents and hybrid paper-electronic presentations. Many respondents identify mixed presentations as a genuine operational gap, noting uncertainty around when a presentation is deemed complete, when examination periods begin, and how refusal notices should be handled across formats. There is also some support for updating force majeure provisions to reflect modern disruptions, and for improving coherence between UCP 600 and related ICC frameworks such as eUCP and URDG 758.

At the same time, there is strong resistance to expanding UCP 600 into areas seen as outside its traditional scope, such as sanctions, detailed compliance rules, or speculative treatment of digital assets. A consistent message emerges that UCP should remain technology-neutral, principle-based, and stable, with evolutionary rather than revolutionary change. Many respondents explicitly favour addressing emerging practices through ISBP guidance, education projects, or digital supplements, leaving UCP 600 as the foundation rather than revising the rules further.

Conclusion

The parallel consultations on ISBP 821 and UCP 600 provided a unique, consolidated insight into how the documentary credit community currently perceives change, risk, and reform.

In the case of ISBP 821, respondents consistently challenge the assumption that unresolved issues automatically justify revision. Many observe that ISBP functions most effectively as a practical clarification tool, bridging the gap between the abstract structure of UCP 600 and the realities of document examination. From this perspective, its value lies in interpretative precision rather than breadth. The concern expressed is that repeated revisions, particularly those attempting to address exceptional scenarios or practices that have not yet crystallised into international standard banking practice, risk transforming ISBP into an overly dense technical manual, thereby weakening its practical utility. The strong preference for education projects and guidance notes reflects a belief that most problems in practice arise not from gaps in the text, but from uneven understanding and limited access to existing material.

The UCP 600 consultation surfaces a similar philosophy, albeit applied to a rulebook rather than a practice guide. Although there is recognition that trade finance now operates in a more digital, compliance-heavy, and legally fragmented environment than in 2007, respondents repeatedly emphasise that UCP’s strength lies in its stability and neutrality. Many warn that attempting to absorb fast-moving developments such as sanctions regimes, cryptocurrencies, or immature digital standards, into the rules, risks hard-coding practices that are neither settled nor universally accepted. Instead, there is cautious support for targeted refinements where genuine operational uncertainty exists, most notably in the treatment of mixed paper-electronic presentations and the modernisation of force majeure provisions in light of recent global disruptions

A particularly interesting thread running through both papers is the implicit re-definition of what “modernisation” should mean for ICC rules. Rather than equating modernisation with constant revision, respondents appear to favour a layered approach: stable core rules, supported by flexible interpretative guidance, education, and digital supplements that can evolve more quickly than formal publications. This approach preserves certainty while allowing practice to adapt organically.

For discussion, several questions naturally arise. At what point does reliance on education and guidance become insufficient, and formal revision unavoidable? How should ICC distinguish between emerging practice and international standard banking practice in a digital context? And, perhaps most importantly, how can access to ISBP, Opinions, and educational materials be improved to address the root causes of misapplication without resorting to textual expansion?

Taken together, the consultations suggest that the respondents are not asking the ICC to slow down, but to choose its objectives carefully. Incremental, well-justified change, grounded in demonstrable practice and supported by robust education, is clearly preferred to frequent structural reform.

Next steps for consideration by ICC National Committees and response to ICC HQ Paris by 27 February:

Based on the above:

• Do you, as a National Committee, support a revision of UCP 600? Yes/No
  • If yes, in order to support this view, provide detailed use cases where UCP 600 has proven inadequate, unclear, or inconsistent with current trade practices.
  • If no, do you support further educational guidance?
• Do you, as a National Committee, support a revision of ISBP 821? Yes/No
  • If yes, please explain why you consider the remaining issues sufficient to justify continuation.
  • If no, could the remaining issues be addressed more effectively through means other than a full revision (e.g. Education Project, Technical Advisory Briefings, ICC Opinions, additional guidance notes)?
• Do you, as a National Committee, support continuation of the ISBP Education Project? Yes/No