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ARTICLE · 11 DECEMBER 2025

SEC Extends Compliance Date For Short Position Reporting Rule

Barnes & Thornburg LLP
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Institutional investment managers now have until Jan. 2, 2028 to begin monthly reporting under Rule 13f-2/Form SHO, and securities lenders also receive an extension for Rule 10c-1a disclosures as specified in the order.

United StatesCorporate/Commercial Law
Scott Budlong
Scott Budlong
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Highlights:

  • Institutional investment managers now have until Jan. 2, 2028 to begin monthly reporting under Rule 13f-2/Form SHO, and securities lenders also receive an extension for Rule 10c-1a disclosures as specified in the order.
  • The extension allows the SEC to address the Fifth Circuit's remand for further economic-impact analysis and gives managers, including hedge funds, additional time to prepare for the new reporting framework.

The SEC has again delayed the deadline for institutional investment managers to begin monthly reporting of their short positions and short activity under Rule 13f-2 and its associated Form SHO. An order issued on Dec. 3, 2025 provides a temporary exemption from short reporting compliance until Jan. 2, 2028 — a delay of two years from the date on which compliance otherwise was scheduled to begin.

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