X9.100-180 ICL Standard

This article describes the specification for electronic exchange of check and image data are defined in in ANSI Standard, X9.100-180.

Although the X9.37 was issued as a Draft Standard for Trial Use (DSTU), it has become the de facto standard for current check image exchange. For example, the Federal Reserve Board (FRB) requires its usage for Image Cash Letters subject to its guidelines.

The X9.37 format has also become the de facto file standard for formatting and transmitting the remote capture of checks. Indeed, this usage has caused many software vendors and financial organizations to "extend" the X9.37 format in nonstandard ways to include deposit slips or Credits that are in the X9.100-180 version. There will be more discussion of current usage and the transition to the new standard later.

However, the standard was issued as a Draft Standard because this was a new concept and there was an expectation of substantive changes before it was finalized.

False X9.100-180 Files

There are many files being referred to as X9.100-180 that are not. In general, these files are X9.37 files with nonstandard modifications taken from preliminary versions of the X9.100-180 specifications. Do you have a vendor who claims X9.100-180 compliance?

At this point the market has multiple file types

  • DSTU X9.37
  • X9.37 with a variety of Record 61 inserts
  • X9.100-180 in name, but really X9.37 with a variety of Record 61 inserts
  • X9.100-180 in name, but who knows what in reality

If you have to convert later to the published standard to exchange with others, what will your conversion cost be?

Here are three simple tests to determine if the ICL file specification you get is conforming to the new official standard:

  1. Look at Record 61 in the definitions section of the specifications or companion document for your Image Cash Letter file. If the length of Record 61 does not match the new standard, it is not X9.100-180.
  2. Look at Record 52. Does the number of fields in the record match the number of fields in the standard?
  3. Finally, look at the header Record 01 and see if the Standard Level is "20". If the Standard Level (field 2) in Record 1 is not a '20', it is not an X9.100-180 file.

Solving Production Image Cash Letter Problems

Image Cash Letter files (ICLs), aka X9.37 files, are becoming bigger and “badder.” As financial institutions continue to ramp up production volume, the issues that were troublesome but relatively rare are now making an impact as multiple daily issues that can overwhelm operations, quality assurance, and customer service personnel. Read about these issues and how they can be resolved at: All My Papers Solving Production Problems with ICLs (X9.37 Files).

Getting the New Standard

To obtain the new standard, you can go directly to the ANSI website and click on the ANSI eStore. Run a search for “X9” you will see X9.100-180 listed as a new standard relatively low on the list. Read about the changes from DSTU X9.3-200 to X9.100-180 here.

Naming Convention Difference Between X9.37 and X9.100-180

The X9.37 DSTU was issued in 2003 as a file format for the exchange of Image Cash Letters. The X9 committee renumbered its subcommittees and the X9B committee standards became X9.100 standards. The X9.37 DSTU when it is finalized will be X9.100-180. The purpose of this document is to describe some of the changes in the format and suggest how the transition from one to the other might take place.


The X9.37 version of the standard is not going away anytime soon. It is the basis for the Federal Reserve Board standard and, if anything, is gaining substantial momentum.

The X9.100-180 version of the standard will take a substantial period of time to implement and then all the retesting starts. Many large financial organizations say they will not start looking at implementing 180 until they have fully deployed their X9.37 systems. That means that for a considerable amount of time there will be two substantially different file formats for Image Cash Letters in use. To facilitate the transition from one standard file format to the other, tools to convert from X9.37 to the new 180 format will be available from All My Papers. Check this section for further updates.

Example of Potential Impact of Changes – ABA Routing Number

To put things in perspective about how substantial these changes will be with the new standard, even the way the ABA Routing number is defined will change. It can be compared to saying we are no longer using street address numbers and names to define where you live so we can deliver packages, but instead we are going to use parcel and lot numbers.

The current definition in the X9.37 standard of a Routing number is 8 digits and a check digit. That definition is not sufficient to accommodate all the different types of checks currently being processed.

There are routing numbers without check digits and some with dashes in the routing number field. Because these nonconforming routing numbers are not common, many check image capture and bank data systems do not account for this. The FRB only accepts X9.37 defined routing numbers (8 digits plus check digit) regardless of the check content.

Tools used to generate X9.37 files should of course provide this conversion as they do in the AMP X9 LIB software tool kits. However, when printing an IRD, the IRD must contain the MICR data exactly as on the check. Software tools used to print IRDs should provide a method to correct the X9.37 file before it is printed; otherwise, under the Check 21 Act, it is not a valid IRD. The good news is that if your system does not already deal with this, the future X9.100-180 will. The bad news is that if your system does not already deal with this, it is producing invalid IRDs.

Another Example of Substantive Changes - Definitions in the New Standard

Item - An Image Cash Letter Item in the paper world would have been a single piece of paper (a paper check). Now it is represented by one or more records in the X9.37 standard. All the associated records needed to represent that single paper item constitute an Item. Unfortunately this concept is used throughout both 9.37 and 180 but it is not included as a definition.

There is a definition of a paper item but not an ICL Item. The reason this is important is that a new Item has been created in 180 called a Credit. This is good addition, but Credits can appear just about anywhere in the file. Since there is no definition of an Item, how to handle these Credits arbitrarily positioned in the file is left up to the user.

Differences between the Standards by the Numbers


Feature   X9.37-2003 DSTU    X9.100-180 Proposed 
Field Definitions 7 14
Pages 144 206
Records 22 29*
Item Types 2 3
Record Length Classes 2 3
Return Reasons 26 72


Some of the Significant Changes for Software Implementers

  1. Record numbers do not imply hierarchy.
  2. The scope or influence of a record is not limited by hierarchy.
  3. All records with variable length data are changed beyond recognition.
  4. Items no longer are limited to item level within a bundle.

Some of the Significant Changes for Users

  • A new Record 61 for Credit/Reconciliation is added to the new standard.
  • Routing number extends the standard to international usage. (e.g. in Canada routing numbers are formatted as XXXX-YYY)
  • Capture of full MICR line and corrected MICR line.
  • Pre-defined user record for Payee Endorsement.
  • Image quality test results.
  • Digital certificates.


There are significant proposed changes to the standard for defining and specifying Image Cash Letters in the new X9.100-180.

It will take time before the new standard is widely implemented.

All My Paper has a suite of tools for the conversion between X9.37 and the new standard now.

In addition, All My Papers tools for creation, editing and sorting of Image Cash Letter files supports the new X9.100-180 standard.

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