Policy Briefing — October 2, 2025
The SEC moved the Rule 605 order execution disclosure compliance date to August 1, 2026, giving brokers, dealers, and market centers seven extra months to finish their reporting systems.
Executive briefing: The Securities and Exchange Commission extended the compliance date for the Regulation NMS Rule 605 amendments from December 14, 2025 to August 1, 2026 so market centers, brokers, and dealers can finish technology and governance updates before the new order execution reports go live.1 Participants must still collect execution quality data beginning August 1, 2026 and publish the expanded monthly reports on the same cadence, meaning testing must conclude ahead of the new month-start go-live.1
Key compliance checkpoints
- Calendar realignment. Rebaseline implementation plans so data collection begins on August 1, 2026, ensuring July trades are still handled under the legacy framework and that the first enhanced report covers the full month of August.1
- Round lot integration. Keep the November 2025 deadline for round lot definition updates in scope because the SEC did not defer those Market Data Infrastructure rules; reporting teams should reconcile share categorization changes before the Rule 605 go-live.1
- Odd-lot data coordination. Coordinate with SIP providers so odd-lot information scheduled for release by May 2026 feeds directly into the new price-improvement metrics without triggering a second remediation wave.1
Operational priorities
- Implementation runbooks. Update milestone charts, budget phasing, and vendor SOWs to reflect the 7.5-month extension while preserving development velocity and UAT coverage.
- Control evidence. Refresh governance documentation that demonstrates how data lineage, reconciliations, and publication checks will satisfy the expanded Rule 605 disclosures.
- Stakeholder communications. Brief trading desks, compliance, and investor-relations teams on the revised reporting schedule so client messaging aligns with the month-start activation.
Enablement moves
- Pair FINRA fractional-share reporting enhancements and the round lot definition workstreams with the Rule 605 conversion so all execution quality metrics reflect the same reference data set.
- Use the extension to stress-test public reporting portals and archival processes that will host the expanded execution quality reports.
Sources
Zeph Tech monitors SEC market-structure rulemakings, surfaces new deadlines, and links reporting teams to the artifacts they need to prove execution-quality compliance.