Article
SEC extends compliance dates for certain rule amendments
Nov. 18, 2025 · Authored by Alan Hartmann, Muhammad Hammad
On Sep. 10, 2025, the Securities and Exchange Commission (SEC or the Commission) extended the compliance dates by 12 months for certain rule amendments it adopted on Dec. 16, 2024, regarding the electronic submission of certain materials under the Securities Exchange Act of 1934 and amendments to the Financial and Operational Combined Uniform Single (FOCUS) reports (Form X-17A-5) that are filed by broker-dealers and security-based swap dealers.
About the extension
On Dec. 16, 2024, the SEC adopted rule amendments that required electronic filing or submission, using structured data where appropriate, of certain forms and other filings or submissions that are required to be filed with the SEC. In the period since the adoption, industry representatives and market participants have expressed concerns about the Electronic Data Gathering, Analysis and Retrieval (EDGAR) filing or submission and structured data requirements and have requested additional time to comply. The stakeholders stated that the SEC has yet to produce any structured data taxonomies, and filers and submitters and their technology vendors cannot begin meaningful work on the technology builds required to convert their documents into a structured data format until the SEC finalizes the relevant taxonomies.
Rule | Compliance date |
• 17 CFR 240.15fk-1(c) | New requirements apply to submissions due on or after Jan. 1, 2027 (extended from Jan. 1, 2026) |
• 17 CFR 232.101's requirements relating to § 249.1 (Form 1) • 17 CFR 232.405's requirements relating to § 249.1 (Form 1) • 17 CFR 240.6a-1, 6a-2, and 6a-3 | New requirements apply to filings due on or after March 2, 2027 (extended from March 2, 2026) |
• 17 CFR 232.101's requirements relating to § 249.200 (Form CA-1) • 17 CFR 232.405's requirements relating to § 249.200 (Form CA-1) • 17 CFR 240.17ab2-1's requirements relating to § 249.200 (Form CA-1) | New requirements apply to filings due on or after April 30, 2027 (extended from April 30, 2026) |
• 17 CFR 232.101's requirements relating to § 249.10 (Form 1-N) • 17 CFR 232.101's requirements relating to § 249.801 (Form 15A) • 17 CFR 240.6a-4 • 17 CFR 240.15aa-1 and 15aa-2 | New requirements apply to filings due on or after July 1, 2027 (extended from July 1, 2026) |
• 17 CFR 232.405's requirements relating to 17 CFR 240.17a-5, 17a-12, and 18a-7 • 17 CFR 240.17a-5(d)(6) and (k)'s requirements to file as an Interactive Data File • 17 CFR 240.17a-12(b)(6), (k), (l)(1), and (m)(1)'s requirements to file as an Interactive Data File • 17 CFR 240.18a-7(c)(6)'s requirement to file as an Interactive Data File | For firms with a minimum fixed dollar net capital requirement greater than or equal to $250,000 as of Dec. 31, 2025 (extended from Dec. 31, 2024): New requirements apply to filings due on or after June 30, 2027 (extended from June 30, 2026) For all other firms: New requirements apply to filings due on or after June 30, 2029 (extended from June 30, 2028) |
• 17 CFR 232.405's requirements relating to 17 CFR 240.17h-2T • 17 CFR 240.17h-2T's requirement to file as an Interactive Data File | New requirements apply to filings due on or after March 31, 2027 (extended from March 31, 2026) |
• 17 CFR 232.101's requirements relating to 17 CFR 240.17a-19 • 17 CFR 240.17a-19 | New requirements apply to filings due on or after Dec. 31, 2027 (extended from Dec. 31, 2026) |
• Form X-17A-5 Part II • Form X-17A-5 Part IIC. | New requirements apply to filings due on or after March 1, 2027 (extended from March 1, 2026) |
• Form X-17A-5 Part IIA • 17 CFR 232's amendments relating to 17 CFR 240.3a71-3(d)(1)(vi) • 17 CFR 240.3a71-3(d)(1)(vi) requirements for filing of notices and withdrawals | New requirements apply beginning Jan. 1, 2027 (extended from Jan. 1, 2026) |
• 17 CFR 232's amendments relating to 17 CFR 240.15fi-3(c) • 17 CFR 240.15fi-3(c) requirements for submission of notices of valuation disputes | New requirements apply to notices submitted on or after Jan. 1, 2027 (extended from Jan. 1, 2026) |
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