Regulatory update: SEC delays Form SHO to 2028

The SEC has issued a new exemptive order, delaying compliance with Rule 13f-2 (Form SHO) and Rule 10c-1a (securities lending reporting). Form SHO reporting will now not begin until January 2028.

Key updates:

• SEC pauses new short-sale disclosure rules and securities-lending reporting rules, including Rule 13f-2, Form SHO, and portions of Rule 10c-1a.
• Rule 13f-2 / Form SHO reporting delayed to January 2, 2028.
• Rule 10c-1a reporting delayed to September 28, 2028.
• Public dissemination of securities-loan data delayed to March 29, 2029.
• The delay follows a Fifth Circuit Court of Appeals ruling that sent the rules back to the SEC for further economic analysis.
• The SEC states the delays are “necessary and appropriate” to avoid unnecessary compliance burdens during its review.

What does this mean?

• No Form SHO filings in 2026 or 2027.
• Firms have additional time to prepare.
• There’s a window to rationalise short position and trade data.
• Closer alignment with securities-lending processes will support future reporting obligations.

What should firms be doing?

• Maintain momentum
  Continue preparations during the extended timeline to ensure readiness for 2028.
• Enhance data quality
  Use this period to clean and standardise data to reduce future remediation work.
• Coordinate short-selling and securities lending workflows
  Integrated processes will help meet both sets of requirements efficiently.
• Monitor regulatory developments
  Stay alert for updates from the SEC, especially as the rules may be revised before they go live.

How can Addition Compliance help?

Regulatory reporting is what we do. Find out more about how we can help you.

Read the full SEC Order granting temporary relief to Form SHO here.