Lenders Do Not Fear Their Old Systems. They Fear One Weekend.
We reviewed the public record of system replacements in financial services. Here is what we found, what it is costing lenders in growth, the options, and the benchmark we would set.
It is the third year this item has been on the board agenda: replace the loan management system.
Everyone in the room agrees it has to go. It was built twelve years ago. Two people understand it. A small change takes weeks, and the auditor has started asking about software that is no longer supported.
Then someone mentions the bank that moved all its customers to a new platform in one weekend and spent the rest of the year apologising for it. The room goes quiet. The item is carried forward to next year.
The paradox: The system is too risky to keep and too risky to replace. So nothing happens, and both risks grow.
What We Found
Before we suggest anything to a lender, we study its sector. For this article we went through the public record of system replacements and IT enforcement in financial services in India and the UK: regulators’ notices, company statements and press reports from 2018 to 2026.
Four findings stand out.
The costliest moment is the attempt to replace the system. The daily running of an old system came second. In April 2018, TSB Bank in the UK moved its customers to a new IT platform, and the migration failed. The bank received 225,492 complaints. It paid £32.7 million in redress to customers. The regulators fined it £48.65 million, and found it had failed to manage its outsourcing arrangement with a critical supplier. It was December 2018 before the bank was back to business as usual.
Even a replacement that goes to plan has a cost. Fino Payments Bank reported “a temporary moderation in business volumes” in the quarter it changed its core banking system.
Standing still is no longer free. The RBI’s direction on IT governance, in force since April 2024, says regulated entities “shall avoid using outdated and unsupported hardware or software”. In the same month the RBI barred Kotak Mahindra Bank from taking new customers online and issuing new credit cards, citing its IT risk management. The restrictions lasted about ten months.
What has to be carried across is more than anyone can hold in their head. When one group of more than 40 credit unions had to replace a core system its vendor was retiring, the work meant rebuilding more than 200 screens and more than 500 interfaces to other systems.
What our review does not show: Nearly every named case is a bank, and most are large. We found no public case of a mid-size NBFC, broker or insurer with this problem. We use the large cases as lessons. We do not say mid-size firms have had the same events.
The Gap, and What Waits Behind It
Almost every conversation about an old system is about risk. Our reading of the record is that risk is half the story. The other half is what the business cannot do while the decision waits.
Look at what the regulator stopped in the case above: new customers online and new credit cards. Both are growth. When an old system becomes a regulatory problem, growth is the first thing to be held back.
Two more signs point the same way. One industry survey published in September 2026 reported that 52% of financial institutions named legacy technology as an obstacle to modernising real-time payments (the survey did not state its sample size). An RBI survey of regulated entities found that 20.8% were using AI systems, while 67% said they were interested in exploring AI use cases.
The gap we see: many firms want to offer faster payments, new products and new partnerships, and fewer are able to. A lender that can change its systems safely can move on those plans. A lender whose replacement is carried forward every year cannot. The opportunity is to get onto the right side of that gap without betting the firm on a single weekend.
This is our reading of the evidence. It is not a measured market figure.
Four Ways Forward, Weighed
A lender in this position has four real options. Each one is right for somebody.
| Option | When it fits | What it risks |
|---|---|---|
| Keep the system and contain it | The system is stable, changes are rare, and it has a planned end date | The regulator’s direction on unsupported software. Skills keep leaving. Growth plans keep waiting |
| Buy a packaged product and move on one date | The need is standard and a product already covers it | Everything moves at once. Years of custom rules must fit the product or be dropped |
| Rebuild the whole system and switch over | The system is small and well documented | One date carries all the risk, and the new system is specified from memory |
| Replace it in stages, one module at a time | The system was built in-house and has been customised for years | Two systems run side by side for a time. The work takes longer on the calendar |
Our recommendation: for the systems a lender has built around its core (loan origination, collections, agent and branch portals, reporting), replace in stages. For core banking itself, a packaged product is usually the right answer, and implementing one is not work we do.
Whichever option is chosen, the first step is the same: write down what the old system does, from the system itself and not from memory.
Where You Are Now, and Where You Should Be
A recommendation is only useful if you can tell later whether it worked. So before any work begins we set a benchmark: a few measures taken from your own system, each with a target.
For this issue, the benchmark would look like this.
| Measure | Typical starting point | Where it should be | How it is checked |
|---|---|---|---|
| A written record of what the system does | The original specification, years out of date | Every function in scope has its own numbered line | The record is compared with the system |
| The largest single go-live | Every function and every customer, on one weekend | One module | The plan, stage by stage |
| The way back if a go-live fails | A second migration, done under pressure | The old system is still running, so a failed stage never reaches customers | Rehearsed before each stage |
| Evidence that new matches old | A test report against an incomplete list | Each old function linked to its replacement and compared | A traceability matrix for each module |
| The decision in front of the board | One large bet, deferred each year | One stage at a time, each approved on evidence | Board papers |
The starting points above are what the public cases show and what we expect to find. In an engagement they are replaced by your own figures, taken in the first review. The targets are what we would work towards with you. They are not results we have already achieved for a lender.
How We Work With You
- We listen: a free Reliability Review. A first conversation about the system, the decision that keeps being deferred, and what it is holding up in the business. You leave with a short written note of what we found.
- We research. We research your sector, the regulator’s position and what the public record says about firms in your situation. This article is an example of that work.
- We read the system and propose: the Legacy System Specification Assessment. It produces a written specification of what the system does, a risk register, a cost comparison between keeping and replacing the system, and a staged plan with a fixed quote. AI does a first pass, our senior engineers review it and trace it to the code, and your own experts confirm it. Code access is read-only and logged, never used for training, and deleted within 30 days of the evaluation ending unless we engage. You get the options and our recommendation.
- If you approve, we build. We replace a system one module at a time while the old one keeps running. We never do a single cutover. Each module has a traceability matrix. The work is billed by milestone, each milestone tied to a module you accept, and you can pause after any accepted module.
- We review against the benchmark. Before work starts we set the benchmark. After each module we show you where each measure stands, and the filled-in benchmark is yours at the end.
The Review is free. Every paid step is fixed price, agreed at scoping. Stop after any step. The findings are yours. The assessment fee is credited in full against the first build stage if it starts within 90 days of the report.
What changes for the business:
| Role | What they gain |
|---|---|
| CEO | Growth plans that waited on the old system can move. The board approves one stage at a time. |
| CTO or CIO | A system the team can change quickly, on a technology people can be hired for. |
| CFO | Spend released stage by stage, with no single large commitment. |
| COO | The business runs throughout. Staff learn one change at a time. |
| Risk and compliance | A record at every stage to show the board, the auditor and the regulator. |
The cases in this article, and what IOanyT does about that kind of problem:
| The case | What IOanyT does |
|---|---|
| TSB Bank moved every customer in one weekend, and the migration failed. | We replace a system one module at a time while the old one keeps running. We never do a single cutover. |
| The regulators found TSB had not managed its critical supplier. | The client holds the specification, the risk register and a traceability matrix for each module, and accepts every module before it is billed. |
| Fino Payments Bank saw business volumes dip in the quarter it changed its core system. | Staff and customers meet one change at a time, not a whole new system on one day. |
| Kotak Mahindra Bank was restricted for about ten months over IT risk. | Our assessment shows a firm where its system stands, with a staged plan to act on. Taking that plan to the regulator is the firm’s own job. |
IOanyT is a consultancy with its own engineering team: we study the problem, recommend, and prove it by building only what you approve. The specification is yours to keep, whoever does the building.
Sources
In this issue
Fear of a failed system replacement
Research note 2
Before You Ask What a Replacement Costs, Ask What It Is Worth.
Three quotes to replace an old lending system, far apart. Why they differ, what they leave out, the ways to buy, and the benchmark for the budget decision.
Research note 3
"Nothing Will Be Lost" Is a Promise. A Benchmark Is Something You Can Check.
No one can honestly promise a new system does all the old one did. Here is the benchmark we would set before go-live, checked function by function.
Issue study
When Replacing the System Is the Biggest Risk
TSB Bank's 2018 migration from the public record: the decision at stake, a lender's options, what we would advise against, and the benchmark we would set.
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