SEC Postponed Form SHO Filing Deadline – Now February 2026

The Securities and Exchange Commission (SEC) has postponed the filing deadline until February 2026.
Investment managers should continue preparing for compliance. However, this delay provides an additional year before the first filing is required.  As noted in the press release: “This exemption will provide industry participants sufficient time to work with Commission staff to address any outstanding operational and compliance questions. This exemption will also provide filers sufficient time to complete implementation of system builds and testing.”

 
Under Rule 13f-2 and Form SHO, institutional investment managers must report gross short positions subject to Regulation SHO if they meet either of the following thresholds during any calendar month:

• A monthly average gross short position of at least $10 million or 2.5% of a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), or for which the issuer is subject to reporting requirements under Section 15(d) of the Exchange Act.
• A gross short position of $500,000 or more on any single settlement day for other securities.

Originally, institutional investment managers exceeding these thresholds would have been required to file Form SHO within 14 days after the end of the applicable month, with the first report due by February 14, 2025, based on short positions from January 2025.  However, on February 7, 2025, the SEC issued an exemptive order delaying the initial reporting requirement. The first Form SHO filing is now due by February 17, 2026, based on short positions from January 2026.


Investment managers should remain vigilant in their preparations, as the rule's future remains uncertain. We will continue to monitor developments and provide updates as they become available.


Read more about this in the SEC’s press release:  https://www.sec.gov/newsroom/press-releases/2025-37