SEC Extends Rule 13f-2 Compliance to 2028: A Strategic Pause for the Industry

The SEC’s decision to push the compliance date for Rule 13f-2 and the associated Form SHO reporting requirements to January 2, 2028, represents more than a scheduling adjustment, it reflects the regulator’s acknowledgment of the operational complexity behind short-sale transparency. The new timeline replaces the earlier 2026 expectation and grants firms an additional two years to prepare.

What the New Timeline Means

• Data collection under Rule 13f-2 begins January 2, 2028.
• The first Form SHO filing is due February 14, 2028, covering activity for January 2028.
• The extension replaces the previous one-year exemption that would have delayed reporting to 2026.
  

Why the Delay

The SEC cited industry feedback, operational strain, and the need for additional time to finalize systems‐level changes to support accurate reporting as core reasons for the delay. Building reliable reporting systems requires coordination across departments and time, since short-sale data can be dispersed, complex and difficult to standardize.

A Moment for Strategic Preparation

The extended timeline should not diminish momentum. Instead, it provides space for firms to:

• Clarify internal data sources and reporting dependencies
• Assess system gaps and integration challenges
• Monitor evolving regulatory guidance

Looking Forward

By resetting the compliance date to 2028, the SEC signals a willingness to align regulatory ambition with operational feasibility. The next few years offer firms an opportunity to build durable, scalable reporting frameworks that can support not only Rule 13f-2 but future transparency initiatives.