Policy & rule-making
Securities finance regulatory timeline
US · EU · UK · APAC · Global · curated public sources
Milestones tracked
23
In force
17
Phasing / upcoming
6
Next milestone
Jul 2026 · US
- Jan 2005USIn force
SEC Regulation SHO — short sale framework
Locate requirement, close-out rules and threshold securities list for US short selling.
Reg SHO established the modern US short-selling rulebook: a 'locate' before shorting, mandatory close-out of fails-to-deliver in threshold securities, and order-marking (long / short / short-exempt). Amendments in 2008 (elimination of the options market-maker exception) and 2010 (alternative uptick rule, Rule 201) followed. Foundational to today's US sec-lending demand and recall mechanics.
Broker-dealersPrime brokersSec lendingSEC · Regulation SHO ↗ - Jul 2010USIn force
Dodd-Frank Act signed into law
Title VII swaps clearing, Volcker Rule, and Section 984(b) securities-lending transparency mandate.
Dodd-Frank reshaped post-crisis market structure: Title VII brought OTC derivatives into central clearing and SEF/MAT execution; the Volcker Rule restricted proprietary trading at banking entities; and Section 984(b) tasked the SEC with bringing transparency to the securities-lending market — the eventual statutory basis for Rule 10c-1a sixteen years later.
BanksPrime brokersSec lendingRepoCFTC · Dodd-Frank ↗ - Aug 2012EUIn force
EMIR enters into force
EU framework for OTC derivatives clearing, trade reporting and risk mitigation.
Regulation (EU) 648/2012 introduced mandatory clearing of standardised OTC derivatives at authorised CCPs, dual-sided trade reporting to trade repositories, and risk-mitigation techniques (timely confirmation, portfolio reconciliation, dispute resolution). Drove the structural shift of collateral demand into cleared markets and pre-figured the SFTR template for sec-finance reporting.
BanksCCPsHedge fundsRepo (collateral)ESMA · EMIR ↗ - Jan 2015GlobalIn force
Basel III LCR phase-in begins
Liquidity Coverage Ratio starts at 60% and ramps to 100% by 2019.
BCBS's Liquidity Coverage Ratio required banks to hold HQLA against 30-day stressed outflows, with national implementations (US, EU CRR, UK) phasing the requirement from 60% in 2015 to 100% in 2019. Combined with the Supplementary Leverage Ratio, this is the single largest driver of the post-2014 contraction in dealer repo intermediation and the rise of sponsored / cleared repo.
BanksRepoPrime brokersBIS · LCR standard ↗ - Sep 2016GlobalIn force
Uncleared Margin Rules — Phase 1
Initial-margin exchange begins for the largest derivatives counterparties.
BCBS-IOSCO's UMR framework began phasing in bilateral IM exchange for uncleared OTC derivatives, starting with the top ~20 dealers in 2016 and finishing with Phase 6 (AANA > €8bn) on 1 Sep 2022. Drove explosive growth in tri-party segregation, custodial IM solutions, and demand for HQLA — directly linking sec-finance inventory to derivative-margin pipes.
BanksHedge fundsSec lending (collateral)Tri-partyBIS · WGMR margin ↗ - Oct 2016USIn force
SEC Money Market Fund reform — floating NAV & gates
Institutional prime / muni MMFs move to floating NAV; liquidity fees and redemption gates introduced.
SEC amendments to Rule 2a-7 forced institutional prime and tax-exempt MMFs to a floating NAV and authorised liquidity fees / redemption gates. Triggered a c.$1trn migration from prime to government MMFs, structurally increasing demand for Treasury repo and reshaping front-end funding markets. Further reforms in 2023 added mandatory liquidity fees for institutional prime funds.
MMFsRepoFunding desksSEC · MMF reform ↗ - Jan 2018EUIn force
MiFID II / MiFIR apply
Transparency, best-execution, research unbundling and transaction reporting across EU markets.
MiFID II brought pre/post-trade transparency to non-equity markets, mandated transaction reporting under MiFIR, restructured research payment models, and introduced the SI regime. Knock-on effects for securities finance include data-licensing obligations on tri-party agents and benchmark-administrator requirements relevant to sec-lending fee indices.
BanksBrokersSec lending (research/exec)ESMA · MiFID II ↗ - Jul 2020EUIn force
SFTR reporting goes live (Phase 1 — banks & investment firms)
First wave of EU Securities Financing Transactions Regulation reporting.
Regulation (EU) 2015/2365 mandated dual-sided T+1 reporting of repo, sec-lending, buy/sell-back and margin-lending trades to authorised trade repositories. Phase 1 captured credit institutions and investment firms; subsequent phases added CCPs/CSDs, insurers/UCITS/AIFs, and non-financials. UK's onshored UK-SFTR follows the same scope.
BanksRepoSecurities lendingTrade repositoriesESMA · SFTR ↗ - Feb 2022EUIn force
CSDR Settlement Discipline Regime (cash penalties)
Daily cash penalties for settlement fails across EU CSDs.
Phase 1 of the CSDR settlement discipline regime introduced mandatory cash penalties on settlement fails, calculated daily by CSDs and netted between counterparties. The mandatory buy-in element was suspended and is being re-cast under the CSDR Refit. Has materially tightened sec-lending recall and inventory management.
CSDsCustodiansSec lendingRepoESMA · CSDR ↗ - May 2024USIn force
US T+1 settlement
Standard settlement for US equities, corporate bonds and UITs moves to T+1.
SEC adopted amendments to Rule 15c6-1 shortening the standard settlement cycle from T+2 to T+1. Sec-lending recalls compressed to same-day; FX funding windows for cross-border investors tightened. Catalyst for CHESS/UK/EU follow-on T+1 programmes.
CustodiansAgent lendersPrime brokersSec lendingSEC final rule ↗ - Jun 2024EUIn force
MiCA stablecoin rules apply
ART/EMT issuance and custody requirements take effect.
MiCA's stablecoin titles apply, with full regime live since 30 December 2024. Sets the foundation for tokenised-cash settlement and EU-regulated stablecoin collateral in repo / sec-lending pilots run by major custodians and tri-party agents.
CustodiansTokenised collateral - Nov 2024USIn force
BSBY discontinued — last index publication
Bloomberg ceased publishing BSBY; SOFR / Term SOFR consolidate as USD funding benchmark.
Following SEC and ARRC concerns about credit-sensitive benchmark robustness, Bloomberg ended Bloomberg Short-Term Bank Yield Index. Repo and sec-financing trades referencing BSBY were migrated to SOFR equivalents. Reinforced SOFR as the dominant USD funding benchmark.
RepoFunding desks - Jan 2025USIn force
SEC Rule 13f-2 short-position reporting
Monthly Form SHO short-position reports; aggregated data published with delay.
Institutional managers exceeding monthly short-position thresholds must file Form SHO within 14 calendar days of month-end. SEC publishes aggregated, anonymised data with a one-month delay. Combined with Rule 10c-1a, materially expands the public short-data corpus.
Hedge fundsPrime brokersSec lendingSEC final rule ↗ - Jan 2025EUIn force
DORA — Digital Operational Resilience Act applies
EU financial entities must meet ICT risk management, incident reporting and third-party oversight standards.
Regulation (EU) 2022/2554 brings ICT risk management, third-party register requirements, and TLPT (red-team testing) into scope for sec-finance infrastructure providers — including custodians, agent lenders and tri-party agents — and their critical ICT third parties.
BanksCCPsCSDsVendorsESAs · DORA ↗ - Jun 2025EUIn force
EMIR 3.0 active account requirement enters into force
EU counterparties must hold and use an active account at an EU CCP for certain in-scope derivatives.
EMIR Refit (EMIR 3.0) requires in-scope EU firms to maintain operationally active accounts at EU CCPs for short-term EUR/PLN interest-rate derivatives and STIR products. Phased operational and representativeness thresholds follow. Designed to reduce reliance on UK-based clearing post-Brexit; spillovers into repo clearing flows.
CCPsBanksRepo (linked clearing)European Commission · EMIR Refit ↗ - Oct 2025UKIn force
UK confirms T+1 implementation date
UK Accelerated Settlement Taskforce confirms 11 October 2027 as Go-Live for T+1.
HM Treasury and the Accelerated Settlement Taskforce confirmed 11 October 2027 as UK T+1 Go-Live, coordinated with the EU and Switzerland. Industry implementation playbook published; ESMA committed to align EU T+1 on the same date.
LSE / Cboe EuropeCustodiansSec lendingRepoAST · UK Implementation Plan ↗ - Jan 2026USIn force
SEC Rule 10c-1a — securities-lending transaction reporting
Lenders must report loan terms to a registered NMS securities-lending data aggregator (FINRA).
Adopted in October 2023, Rule 10c-1a requires covered persons to report securities-loan transactions and modifications to FINRA on a T+0 basis. FINRA publishes aggregated loan-level data the following morning. First full reporting day in early 2026 following FINRA's revised compliance dates; brings unprecedented transparency to a market historically dominated by IHS Markit / DataLend datasets.
Agent lendersPrime brokersBeneficial ownersFINRASEC final rule ↗ - Jul 2026USPhasing in
Basel III endgame — phased start (US re-proposal)
Revised market-risk, CVA and operational-risk frameworks for large US banks begin to phase in.
Federal banking agencies' 2025 re-proposal of Basel III endgame targets a phased start in mid-2026 with full implementation by 2029. Key impacts for securities finance: revised SA-CCR exposures, tighter G-SIB surcharge mechanics, and the standardised output floor. Drives continued migration of repo to sponsored/peer-to-peer and CCP-cleared models.
BanksPrime brokersRepo balance sheetFederal Reserve · Basel III re-proposal ↗ - Sep 2026EUUpcoming
CSDR Refit — mandatory buy-in framework finalised
ESMA RTS on a two-step penalty + buy-in mechanism take effect.
Regulation (EU) 2023/2845 (CSDR Refit) kept mandatory buy-ins as a last-resort tool. ESMA's level-2 RTS introduce a progressive penalty regime followed by a buy-in trigger for persistent fails, with carve-outs for sec-lending recalls. Targeted application from H2 2026 once RTS are adopted.
CSDsCustodiansSec lendingRepoESMA · CSDR Refit ↗ - Dec 2026USUpcoming
SEC mandatory clearing of US Treasury cash trades
Eligible cash UST secondary-market trades must clear at a covered clearing agency.
SEC Rule 17ad-22(e)(18)(iv) requires covered clearing agencies to mandate central clearing of eligible UST cash transactions (Dec 2026) and UST repo transactions (Jun 2027). Re-shapes sponsored-repo economics; DTCC/FICC is the only currently designated venue, with CME and ICE pursuing competing services.
FICCBanksHedge fundsRepoSEC · UST clearing rule ↗ - Jun 2027USUpcoming
SEC mandatory clearing of US Treasury repo
Eligible UST repo and reverse-repo must clear at a covered clearing agency.
Second leg of the SEC UST clearing mandate. Expected to materially expand FICC's sponsored and agent-clearing programmes, with CME and ICE preparing competing services. Will reduce bilateral repo capacity for hedge-fund clients and reshape balance-sheet allocation across major dealers.
FICCBanksHedge fundsMoney market funds - Oct 2027EUUpcoming
EU & EEA move to T+1
ESMA-coordinated EU T+1 Go-Live, aligned with UK and Switzerland.
ESMA's T+1 Industry Committee targets 11 October 2027 for the EU to move to T+1, aligning with the UK and Switzerland to avoid CSDR mismatches and FX funding fragmentation across European trading day. Expected to compress sec-lending recall windows further and accelerate same-day allocation workflows.
CSDsCustodiansAgent lendersRepoESMA · T+1 plan ↗ - 2027–28GlobalUpcoming
FSB NBFI policy package — leverage & liquidity
Implementation of FSB recommendations on NBFI leverage, MMF resilience and margining practices.
FSB's NBFI workstream (post-LDI, post-Archegos) is producing recommendations on hedge-fund leverage transparency, MMF reform, margin preparedness, and securities-financing/short-selling data. National implementation in 2026-2028. Expect tighter repo disclosure, additional margin pre-funding, and harmonised securities-lending transparency.
Hedge fundsMMFsSec lendingRepoFSB · NBFI ↗
Curated from primary regulator sources (SEC, ESMA, FCA, Federal Reserve, FSB, European Commission). Effective dates reflect the latest public guidance and may shift as rule-making evolves. Not legal advice.