In the second article of this series, we explored how to move your JIBAR to ZARONIA contract remediation programme beyond preparation. Now the clock is ticking.
With fewer than 18 months until JIBAR’s cessation, clients and counterparties are asking questions about transition timing and expected contract remediation approaches
Justin Ridl, MD and Head of Financial Services at Cognia Law
The final phase; client and counterparty outreach, notification, negotiation, and contract remediation – needs to be in motion. If not, regulatory deadlines will be missed, you will frustrate your clients and counterparties, budgets will overrun, and internal stakeholders will lose faith in the remediation programme.
JIBAR transition: where we are now
The South African Reserve Bank (SARB) has completed its contract-mapping exercise across all affected products, helping most market participants define the scope and size of their contract remediation programmes. To support this, Cognia has worked closely with clients, market participants and the SARB to prepare the draft ‘Remediation Pathways Survey’. The final version will be issued by 1 August 2025, with responses due by the end of August 2025.
Through these engagements, it’s become clear that there is no market-wide consensus on how different firms will approach contract remediation across the different product agreements from a legal or regulatory compliance perspective. There are still gaps in timelines, resource estimates, and strategies across institutions. The survey will help identify emerging patterns and facilitate an aligned, market-wide approach.
Findings will be shared anonymously by the SARB’s Legal MPG in an effort to:
- Avoid fragmented approaches in the market across product sets
- Promote alignment on remediation risks and options
- Shape realistic remediation timelines for each product category
- Clarify both the legal and operational impacts of proposed pathways to inform the scope of the remediation programme requirements at both an institutional and market-wide level
The final phase: from planning to execution
Navigating a large-scale contract remediation programme of this scale demands more than legal acumen. It requires a coordinated, cross-functional strategy involving legal, business, client relationship, operational, and regulatory compliance teams, all aligned on timelines and milestones.
We know this because Cognia, has supported many banks and financial institutions through complex global regulatory transitions, including LIBOR, MiFID II, Margin Reform, Brexit, and GDPR. We’re now applying that proven expertise to the JIBAR to ZARONIA transition.
The first part of the programme needs to be a well-planned client/counterparty engagement. Poor coordination will delay execution, cause reputational, legal and client relationship risks, and trigger business disruption.
To meet the JIBAR cessation deadline, remediation must be run as a structured programme, one that bridges strategy with day-to-day delivery across different product lines and contract types to avoid business disruption, all while meeting tight timelines and maintaining regulatory compliance.
Accelerate your contract remediation programme now to avoid the pitfalls of a race to the finish
Our recent conversations with market participants have made one thing clear: many organisations still haven’t finalised and kicked-off a coordinated, organisation-wide legal contract remediation programme. This is understandable, as the legal remediation of affected contractual arrangements, although an essential element of enterprise-wide compliance, is the last step in the process. Key elements like legal budget allocation and a contract remediation resourcing strategy that balances internal and external support, are the last things to be finalised. They may follow the structural, business and commercial imperatives of the transition, but if they are not concluded successfully in the required timeline, the entire programme fails.
Let us take you and your JIBAR remediation programme team through our approach which delivers:
- Certainty of execution through experienced programme leadership
- Reduced risk via full lifecycle delivery, from legal analysis to stakeholder sign-off
- Faster mobilisation and sustained delivery momentum
- AI-driven efficiency gains and reduced cost per contract
- Transparent pricing models for budget control
- Alignment across internal teams and external stakeholders
- A single accountable partner driving delivery success
Explore our dedicated regulatory reform platform Reg Reform Pro to see how we can help.
With Cognia, you don’t just meet the deadline: you meet it with certainty, clarity, and confidence.
If you found this interesting and would like to find out how we can collaborate with you, contact us here
