There will be no revision of the UCP 600 rules undertaken by the ICC Banking Commission at this time. Additionally, the Banking Commission will set aside its advanced draft changes to ISBP and not pursue an update of ISBP 821. In arriving at this outcome announced and discussed at the Banking Commission Meeting in Paris on 19 March 2026, three distinct camps emerged among ICC National Committees as regards UCP.
NCs against UCP Revision
Twenty NCs voted against a revision: Australia; Austria; Belgium; Czech Republic; Denmark; Germany; Italy; Japan; Jordan; Korea; Malaysia; Nigeria; Portugal; Qatar; Russia; Sweden; Switzerland; Thailand; Turkey; and UK.
Based on this majority stance, ICC will pivot away from modifying its existing rules and standards and instead channel its energy towards guidance and education. Commenting on what has become a perennial call for more education, Eleanore Treu of ICC Austria inquired as to the intended target audience. “Do we actually have an idea who we are supposed to educate? Is that the bank saying, ‘We want more education for our clients? We want more education in other financial institutions?’”, asked Treu who suggested that ICC might explore its educational objectives further. As to why ICC Austria voted against UCP revision, Treu said that while the rules are not perfect, the Commission has always tried for simplification with every revision and never quite succeeded. She referenced a past initiative known as “LC Lite” which the Commission may consider revisiting.
Chris Southworth of ICC United Kingdom said that in terms of focusing education where it is most needed, part of the issue is because the Commission does not have enough information on where rules compliance errors are being made and by what constituencies. “If we know where the most mistakes are being made, then we can go into those communities and start to really target [there] with education rather than just doing a broad brush and just hoping everyone is following the rules”, Southworth said. He also questioned whether contemplating a UCP revision was an appropriate proposition to take up in the first place. “Why are we talking about documents when we should be moving to electronic data?”, said Southworth. “We're talking about something that's almost on its way out. We're moving to a completely different system. We need to be thinking much bigger and longer term and be preparing for the future.”
Pavel Andrle of ICC Czech Republic remarked that problems also arise from interpretation of the rules, not technical deficiencies in the rules. He concurred with other comments about the necessity to better analyze the needs for any revision. He also expressed his personal disappointment that the ISBP revision effort has been halted. “We had four drafts of [the anticipated] new ISBP and there was a vote approved by the Banking Commission to go for limited ISBP revision. And now we actually see that it was somehow not properly addressed. … There was alignment of ISBP, ISBP 821, without any vote. [W]e should have done revision instead and it would [have covered] a lot of things.”
NCs in Favor of UCP Revision
During the meeting, it was announced by ICC that seven NCs voted yes to a revision. These were revealed by ICC to be Bangladesh, China, France, Indonesia, Mexico, Poland, and Spain. Soh Chee Seng of Singapore informed that Singapore had also voted for UCP revision.
While respecting the majority vote, Jun Xu of ICC China noted the importance of views from the major LC users. “We need to listen to both parts”, said Xu. “Going forward, we need to collect more business cases from those NCs saying ‘yes’ to the revision of UCP and ISBP because it requires courage and business cases to say ‘yes’.” Contacted by DCW for further comment, Xu pointed out that during the previous UCP revision effort several court cases – most notably Banco Santander SA v. Banque Paribas (1999) and Banque Nationale de Paris v. Credit Agricole Indosuez (2001) – proved instrumental to that revision. In support of its ‘yes’ vote to revise UCP 600, ICC China submitted business cases quoting several court cases and business practices. Xu believes ICC and NCs need to study such contemporary business cases collected and make appropriate decisions based on analysis of them.
China-based legal professional and ICC Technical Adviser Saibo Jin gave a brief overview of domestic LC use in China. In 1997, the People's Bank of China (country’s central bank) published simple rules for domestic LCs. In the first decade of the rules’ existence there was very little volume of domestic transactions, but over the past ten years, LC use within the Chinese market is booming, according to Jin. Most domestic LCs require just an invoice and transport document. “So I think it is time to study the Chinese example of a domestic letter of credit”, said Jin. “Keep everything simple, clear, and very operational.” Xu then echoed Jin’s comments and floated the idea that ICC might consider developing a separate rule set – simple UCP – which could govern LCs only requiring presentation of an invoice and transport document.
Speaking on behalf of Singapore and having conducted training on UCP extensively throughout Asia, Soh Chee Seng pointed out that Asian countries are the heaviest users of LCs. According to past SWIFT statistics, Bangladesh, China, India, and Pakistan have topped the list for import LCs. On the export side, it has been China, Bangladesh, India, Hong Kong, and Singapore. Soh went on to say that Singapore voted for the revision because bankers and other LC parties often face problems.
From seminars held with those in the insurance and transport industries, Soh described one specific area of disconnect: “The BL is required to have onboard notation. But if it is a pre-printed onboard, it could be onboard a truck. So, in that case, under the UCP 600, it is not acceptable. … [Carriers] undertake to deliver the goods from the beginning until the destination. If there are any damages, all is covered by insurance. And not only that, the user or perhaps the one who holds the BL, can still claim possession of the cargo. This is a valid document which is not acceptable by the bank [because in] the UCP, onboard notation means onboard ship, not truck.” For Soh, it is illustrative of UCP’s complexity. Traders also feel that commercial credits are too complicated. They are trending increasingly towards open account and covering non-payment risk by using standbys or demand guarantees. According to Soh, from his training sessions for banks in Indonesia, Malaysia, Hong Kong, Taiwan, and China: “I heard what [bankers] have said. A majority, of course, not all, feel the need to have a revision.”
In a written comment during the meeting, Miguel Angel Bustamante expressed that ICC Mexico agrees that education is a must but still thinks that revision of UCP and ISBP is necessary. Writing in a personal capacity, Bustamante offers views here.
NCs Taking No Position on UCP Revision
Included among this group were dozens of ICC National Committees eligible to vote, but did not do so for unknown reasons. However, one NC – ICC UAE – abstained from voting and explained why, saying it is largely due to chronically high discrepancy rates.
“The reason [ICC UAE members] didn't want to vote was pretty simple”, said ICC UAE Director Vincent O'Brien who went on to reference a past article by ICC Banking Commission Senior Technical Advisor Dave Meynell which lamented that the previous UCP revision completed in 2007 did not, and still has not, reduced discrepancy rates. O’Brien also cited industry estimates placing discrepancy rates between 65% to 80%.
“So we need to take a bigger look at this”, said O’Brien. “[ICC UAE members] didn't want to go ahead, because they just said it’s just going to be more of the same. We're not interested in another change that will follow on the same pattern as it has followed before.”
What’s Next
With the UCP revision question now answered and set aside for the foreseeable future, expect some type of structured emphasis on education from ICC. It could include elevated focus and attention on ICC’s ISBP Education Project.
The Banking Commission may also attempt to gauge whether there is serious commitment to pursue simplification. This would require looking at the LC process in a new light, listening to the voices of LC users, and honestly evaluating what documents are truly necessary for documentary credits. Here’s a blueprint to open the conversation.
