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SECURITIES AND EXCHANGE COMMISSION

17 CFR Parts 202, 232, 240, 249, and 249b

[Release Nos. 33-11386; 34-103877; IC-35738; File No. S7-08-23]

RIN 3235-AL85

Extension of Compliance Dates for Electronic Submission of Certain Materials Under the

Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report

AGENCY: Securities and Exchange Commission.

ACTION: Final rule; extension of compliance dates.

SUMMARY: The Securities and Exchange Commission (“Commission”) is extending by

twelve months the compliance dates for certain of the rule amendments the Commission adopted

on December 16, 2024, regarding the electronic submission of certain materials under the

Securities Exchange Act of 1934 (“Exchange Act”) and amendments to the FOCUS Report

(Form X-17A-5), a periodic financial and operational report filed by broker-dealers and securitybased swap dealers.

DATES: Effective Date: This release is effective September 10, 2025. The effective date for

the Commission release adopted on December 16, 2024, which is entitled “Electronic

Submission of Certain Material Under the Securities Exchange Act of 1934; Amendments

Regarding the FOCUS Report”, remains March 24, 2025.

Compliance Date: The compliance dates for certain amendments adopted on December 16,

2024, and published on January 21, 2025 at 90 FR 7250, are extended by twelve months, as

discussed in more detail below.

FOR FURTHER INFORMATION CONTACT: For Forms 1 and 15A– Justin Pica, Assistant

Director, and David Michehl, Special Counsel; for Form 1-N – David Dimitrious, Senior Special

Counsel, and Michou Nguyen, Special Counsel; for Form CA-1 – Matthew Lee, Assistant

Director, and Claire Noakes, Senior Special Counsel; for Form 19b-4(e) and technical

amendment to Form 19b-4 – Cristie March, Senior Special Counsel, and Edward Cho, Special

Counsel; for Rule 17a-22 – Matthew Lee, Assistant Director, and Susan Petersen, Special

Counsel; for Rule 17a-5, Rule 17a-12, Rule 18a-7, Form X-17A-5 Part III and related annual

filings, Form X-17A-5 Parts II, IIA, and IIC, Form 17-H, and Form X-17A-19 – Raymond A.

Lombardo, Assistant Director, and Valentina Minak Deng, Special Counsel; for notices provided

pursuant to Rule 3a71-3(d)(1)(vi) and Rule 15fi-3(c) –John Guidroz, Assistant Director, and

Israel Goodman, Senior Counsel; and for reports submitted pursuant to Rule 15fk-1(c)(2)(ii)(A),

Kelly Shoop, Branch Chief, and Patrick Bloomstine, Attorney-Adviser, Division of Trading and

Markets, at (202) 551-5500, Securities and Exchange Commission, 100 F Street NE,

Washington, DC 20549.

SUPPLEMENTARY INFORMATION: The Commission is extending by twelve months the

compliance dates for all of the rule amendments the Commission adopted on December 16, 2024

regarding the electronic submission of certain materials under the Exchange Act, except for the

following rule amendments which continue to have the same compliance date stated in the

Commission’s December 16, 2024 release: rule amendments that originally had a compliance

date of March 24, 2025; rule amendments relating to the filing requirements for new derivative

securities products; 1 and rule amendments requiring Form 17-H and broker-dealer and security-

See 17 CFR 240.19b-4(e).

based swap entity annual reports be filed electronically on the Electronic Data Gathering,

Analysis, and Retrieval (“EDGAR”) system. 2

DISCUSSION

On December 16, 2024, the Commission adopted rule amendments that require, among

other things, electronic filing or submission, using structured data where appropriate, of certain

forms and other filings or submissions that are required to be filed with or submitted to the

Commission under the Exchange Act and the rules and regulations thereunder. 3 The

Commission addressed the compliance dates for these rule amendments in the Adopting Release,

intending to give regulated entities time to incorporate these changes into their policies,

procedures, systems, and practices. 4

In the period since the Commission adopted the rule amendments, industry

representatives and market participants have expressed concerns about the EDGAR filing or

submission and structured data requirements, and have requested additional time to comply. 5 For

example, an industry group 6 requested that the Commission extend by twelve months the

compliance date for the requirement to file or submit the following forms and submissions on

EDGAR in structured data format: Form X-17A-5 Part III pursuant to Exchange Act Rules 17a-

See 17 CFR 232.101’s requirements relating to 17 CFR 240.17a-5, 17 CFR 240.17a-12, 17 CFR 240.17h2T, and 17 CFR 240.18a-7; 17 CFR 240.17a-5(d)(6) and (k)’s requirements to file electronically; 17 CFR

240.17a-12(a)(2); 17 CFR 240.17a-12(b)(6), (k), (l)(1), and (m)(1)’s requirements to file electronically; 17

CFR 240.17h-2T’s requirement to file electronically; 17 CFR 240.18a-7(c)(6)’s requirement to file

electronically.

See Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments

Regarding the FOCUS Report, Exchange Act Release No. 101925 (Dec. 16, 2024), 90 FR 7250 (Jan. 21,

2025), available at https://www.govinfo.gov/content/pkg/FR-2025-01-21/pdf/2024-30433.pdf (“Adopting

Release”).

See section VIII of Adopting Release at 7304.

See, e.g., Letter from Kyle Brandon, Managing Director, Securities Industry and Financial Markets

Association (“SIFMA”) (May 13, 2025), available at https://www.sec.gov/comments/s7-08-23/s70823600675-1751083.pdf (“SIFMA 2025 Letter”).

See SIFMA 2025 Letter.

5, 17a-12, and 18a-7, 7 Form 17-H pursuant to Exchange Act Rule 17h-2T, 8 valuation dispute

notices pursuant to Exchange Act Rule 15fi-3(c), 9 and compliance reports pursuant to Exchange

Act Rule 15fk-1(c)(2)(ii)(A). 10 SIFMA also asked to extend the compliance date to file notices

(and any withdrawals of notices) pursuant to Exchange Act Rule 3a71-3(d)(1)(vi) (also known as

“ANE Exception Notices”) on EDGAR. 11 SIFMA stated that the Commission 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

structured data format until the Commission finalizes the relevant taxonomies. 12

After consideration of these requests, the Commission is extending by twelve months the

compliance dates for the following rule amendments (hereinafter, the “Twelve Month Rules”):

Rule

• 17 CFR 240.15fk-1(c)

•

Compliance Date

New requirements apply to submissions due

on or after January 1, 2027 (extended from

January 1, 2026)

17 CFR 232.101’s requirements relating to New requirements apply to filings due on or

after March 2, 2027 (extended from March 2,

§ 249.1 (Form 1)

17 CFR 232.405’s requirements relating to 2026)

§ 249.1 (Form 1)

17 CFR 240.6a-1, 6a-2, and 6a-3

17 CFR 232.101’s requirements relating to New requirements apply to filings due on or

after April 30, 2027 (extended from April 30,

§ 249.200 (Form CA-1)

17 CFR 232.405’s requirements relating to 2026)

§ 249.200 (Form CA-1)

17 CFR 240.17ab2-1’s requirements

relating to § 249.200 (Form CA-1)

17 CFR 232.101’s requirements relating to New requirements apply to filings due on or

after July 1, 2027 (extended from July 1,

§ 249.10 (Form 1-N)

17 CFR 232.101’s requirements relating to 2026)

§ 249.801 (Form 15A)

17 CFR 240.6a-4

17 CFR 240.17a-5; 17 CFR 240.17a-12; 17 CFR 240.18a-7.

17 CFR 240.17h-2T.

17 CFR 240.15fi-3(c).

17 CFR 240.15fk-1(c)(2)(ii)(A).

17 CFR 240.3a71-3(d)(1)(vi).

See SIFMA 2025 Letter.

Rule

• 17 CFR 240.15aa-1 and 15aa-2

• 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

• 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

• 17 CFR 232.101’s requirements relating to

17 CFR 240.17a-19

• 17 CFR 240.17a-19

• Form X-17A-5 Part II

• Form X-17A-5 Part IIC

• 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

• 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

Compliance Date

For firms with a minimum fixed dollar net

capital requirement greater than or equal to

$250,000 as of December 31, 2025 (extended

from December 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)

New requirements apply to filings due on or

after March 31, 2027 (extended from March

31, 2026)

New requirements apply to filings due on or

after December 31, 2027 (extended from

December 31, 2026)

New requirements apply to filings due on or

after March 1, 2027 (extended from March 1,

2026)

New requirements apply beginning January 1,

2027 (extended from January 1, 2026)

New requirements apply to notices submitted

on or after January 1, 2027 (extended from

January 1, 2026)

These twelve-month extensions will give firms more time to develop compliant systems

and will give Commission staff more time to build and finalize taxonomies with respect to

structured data requirements, as well as work with FINRA to update the eFOCUS systems with

respect to FOCUS Report amendments. Once taxonomies are finalized, these extensions will

also facilitate an orderly transition by giving registrants submitting filings, forms, and other

submissions additional time to test new technology infrastructure and update internal systems, as

well as to develop policies and procedures that will help ensure compliance with the filing or

submission requirements. 13

For the sake of clarity, the rule amendments that have the same compliance dates as in the

Adopting Release, and are not being extended, are listed below:

Rule

• 17 CFR 240.19b-4(e)

•

II.

Compliance Date

New requirements apply to filings due on or

after September 1, 2025 (same compliance

date as in Adopting Release)

17 CFR 232.101’s requirements relating to New requirements apply to filings due on or

after June 30, 2025 (same compliance date as

17 CFR 240.17a-5, 17 CFR 240.17a-12,

in Adopting Release)

17 CFR 240.17h-2T, and 17 CFR

240.18a-7

17 CFR 240.17a-5(d)(6) and (k)’s

requirements to file electronically

17 CFR 240.17a-12(a)(2)

17 CFR 240.17a-12(b)(6), (k), (l)(1), and

(m)(1)’s requirements to file electronically

17 CFR 240.17h-2T’s requirement to file

electronically

17 CFR 240.18a-7(c)(6)’s requirement to

file electronically

All other rule amendments not already

March 24, 2025 (same compliance date as in

referenced in either of this release’s charts Adopting Release)

Economic Analysis

The Commission is mindful of the economic effects, including the costs and benefits, of

the compliance date extension. Exchange Act section 3(f) requires the Commission, when it is

engaged in rulemaking pursuant to the Exchange Act and is required to consider or determine

whether an action is necessary or appropriate in the public interest, to consider, in addition to the

The Commission is not extending compliance dates for the rule amendments with a compliance date of

March 24, 2025, because these rule amendments are ministerial, non-substantive, or deregulatory and

require little, if any, action on behalf of registrants to prepare for compliance. The Commission is also not

extending the compliance date for the requirement for a self-regulatory organization to publicly post the

information required under Rule 19b-4(e) on its website, because such information is the same as that

currently required on Form 19b-4(e). Finally, the Commission is not extending the compliance date for the

rule amendments requiring Form 17-H and broker-dealer and security-based swap entity annual reports be

filed electronically on EDGAR, and notes that many firms have already been filing these on EDGAR.

protection of investors, whether the action will promote efficiency, competition, and capital

formation. 14 In addition, Exchange Act section 23(a)(2) requires the Commission, when making

rules pursuant to the Exchange Act, to consider among other matters the impact that any such

rule would have on competition and not to adopt any rule that would impose a burden on

competition that is not necessary or appropriate in furtherance of the purposes of the Exchange

Act. 15

The baseline against which the costs, benefits, and the effects on efficiency, competition,

and capital formation of the compliance date extension are measured consists of the current

requirements for filing or submitting the documents affected by the Twelve Month Rules, and the

current filing or submission practices of firms subject to the Twelve Month Rules. As discussed

above, 16 pursuant to the Adopting Release, the current compliance dates for the Twelve Month

Rules spanned from January 1, 2026 to June 30, 2028, and industry representatives have reached

out to Commission staff to request additional time to comply.

The Commission is extending the compliance date for the Twelve Month Rules by twelve

months, to help facilitate an orderly compliance with the Twelve Month Rules. This extension

will give firms additional time to update, test, and develop technological infrastructure needed to

comply with structured data requirements, and to develop policies and procedures that help

ensure compliance in relation to the filing or submission requirements (including through

engagement with the Commission and Commission staff on compliance and operational

challenges). 17 For those affected firms that are subject to other recently adopted rules with new

See 15 U.S.C. 78(c)(f).

See 15 U.S.C. 78w(a)(2).

See supra section I.

Two forms, Form X-17A-5 Part III and Form 17-H, are affected by the Twelve Month Rules with respect to

only structured data requirements, not with respect to electronic filing requirements. The remaining

submissions affected by the Twelve Month Rules are affected with respect to both electronic filing or

submission requirements and with respect to structured data requirements.

compliance obligations, the extension will provide them with additional time for developing

necessary technological capabilities and appropriate policies and procedures with fewer

conflicting priorities on internal resources. 18

The extension of the compliance dates by twelve months will delay the realization of

economic benefits associated with the Twelve Month Rules. The delayed benefits include the

streamlining of the filing or submission process for documents affected by the electronic filing or

submission requirements of the Twelve Month Rules, which can reduce errors and result in cost

savings over time, and an increase in the accessibility and usability of affected information by

the public and the Commission, which would increase transparency and insight into the

operations, governance, management, financial condition, and other characteristics of the

affected entities. 19

The extension of the compliance dates by twelve months will also delay the cost

associated with the Twelve Month Rules. As discussed in the Adopting Release, affected firms

that do not have experience structuring in Inline XBRL may need to hire additional personnel

proficient in XBRL, train existing personnel, or otherwise outsource compliance with the

structured data requirements to a third-party service provider. 20 Extending the compliance date

will give firms more time to adjust their processes during which they may find or develop less

Extending the compliance date will also mitigate the potential costs associated with overlap of the

compliance dates of the Twelve Month Rules and rules that were adopted prior to the Twelve Month Rules.

See Adopting Release at section X.B and X.C.2.c. As explained in the Adopting Release, where overlap in

compliance periods exists, the Commission acknowledges that there may be additional costs on those

entities subject to one or more other rules, but spreading the compliance dates out over an extended period

limits the number of implementation activities occurring simultaneously. Id. In addition, extending the

compliance date will likely mitigate the potential costs associated with overlap of the compliance date and

the compliance dates of rules that have been adopted since the Twelve Month Rules. Specifically, the

Commission has adopted one rule since the Twelve Month Rules in which it considered the overlap of

compliance dates with those established in the Adopting Release, including for the Twelve Month Rules.

See Daily Computation of Customer and Broker-Dealer Reserve Requirements Under the Broker-Dealer

Customer Protection Rule, Release No. 34-102022 (Dec. 20, 2024), 90 FR 2790 (Jan. 13, 2025).

See Adopting Release, sections X.A and X.C.

See Adopting Release, section X.C.2.

costly implementation methods to meet their filing or submission deadlines. The extension of

the compliance date will also delay the accrual of the relevant per filing and per submission costs

and burdens described in the Adopting Release.

The extension of the compliance dates will delay the effects on efficiency, competition,

and capital formation of the Twelve Month Rules. The delayed benefits include an increase in

the timeliness of public access to information electronically filed. Improving the speed of

disclosure to the public improves the price efficiency of markets by improving the timeliness of

information available to market participants. These benefits may be delayed or reduced because

structured data requirements augment these effects by allowing the Commission—and, where

applicable, the public—to draw upon comparable information from other reporting periods and

from other disclosing entities in assessing the reported disclosures. 21 The extension of the

compliance dates may benefit smaller entities affected by the Twelve Month Rules. As discussed

in the Adopting Release, to the extent that the EDGAR cost has a fixed component, smaller

entities that do not have experience with EDGAR may be at a relative competitive disadvantage

to larger entities. 22 The extension of the compliance dates may provide these smaller entities

with more flexibility to implement cost-effective compliance strategies, thereby reducing any

competitive effects of the Twelve Month Rules.

The Commission considered reasonable alternatives to the new compliance date, namely

a shorter or longer extension. The Commission believes, however, that, consistent with industry

requests, a twelve-month extension is appropriate to help facilitate the successful implementation

of the rule amendments. 23 A shorter extension would likely provide insufficient time for firms to

See Adopting Release, sections X.A and X.D.

See Adopting Release, section X.D.

See supra note 5.

fully implement the technical and procedural changes necessary to comply with the rule

amendments. Furthermore, with respect to filings and submissions that are tied to a firm’s fiscalyear end, an extension of less than twelve months might not provide a meaningful extension if

the original compliance date falls shortly after a firm’s annual filing or submission is due and the

extended compliance date falls before the firm’s next annual filing or submission is due.

Conversely, because a twelve-month extension should be sufficient to facilitate successful

compliance, a longer extension would unnecessarily delay the benefits arising from the rule

amendments.

III.

Procedural and Other Matters

The Administrative Procedure Act (“APA”) generally requires an agency to publish

notice of a rulemaking in the Federal Register and provide an opportunity for public comment.

This requirement does not apply, however, if the agency “for good cause finds…that notice and

public procedure are impracticable, unnecessary, or contrary to the public interest.” 24

For the reasons discussed below, the Commission, for good cause, finds that notice and

solicitation of comment regarding the extension of the compliance dates set forth herein are

impracticable, unnecessary, or contrary to the public interest. 25 This rule does not impose any

new substantive regulatory requirements on any person and merely reflects the extension of the

compliance dates for certain rule amendments in the Adopting Release. An extension of the

compliance dates is needed to give firms additional time to update internal systems, develop

policies and procedures, and develop technological infrastructure needed to comply with the

Commission’s requirements. Firms must begin preparing for these changes well in advance of

5 U.S.C. 553(b)(B).

See id. (stating that an agency may dispense with prior notice and comment when it finds, for good cause,

that notice and comment are “impracticable, unnecessary, or contrary to the public interest”).

the applicable compliance date in order to be fully in compliance by that date. As a result, some

firms may incur operational costs in order to meet the compliance dates in the Adopting Release,

including purchasing software and making staffing changes or entering contracts with third-party

service providers. 26 Providing immediate certainty that these compliance dates are extended is

therefore needed to allow firms to avoid incurring unnecessary burdens and other challenges

associated with meeting the initial compliance dates of the Twelve Months Rules in the Adopting

Release. 27

For similar reasons, although the APA generally requires publication of a rule at least 30

days before its effective date, the requirements of 5 U.S.C. 808(2) are satisfied (notwithstanding

the requirement of 5 U.S.C. 801), 28 and the Commission finds that there is good cause for this

extension to take effect on [INSERT DATE OF PUBLICATION IN THE FEDERAL

The Office of Management and Budget has determined that this action is not a significant

regulatory action as defined in Executive Order 12866, as amended, and therefore it was not

subject to Executive Order 12866 review. Pursuant to the Congressional Review Act, the Office

of Information and Regulatory Affairs has designated the extension of the compliance dates not a

“major rule,” as defined by 5 U.S.C. 804(2).

See Adopting Release, section X.C.2.b (discussing the applicability and variability of structured data costs).

The compliance date extension set forth in this release is effective upon publication in the Federal Register.

Section 553(d)(1) of the APA allows effective dates that are less than 30 days after publication for a

“substantive rule which grants or recognizes an exemption or relieves a restriction.” 5 U.S.C. 553(d)(1).

See 5 U.S.C. 808(2) (if a Federal agency finds that notice and public comment are impracticable,

unnecessary or contrary to the public interest, a rule shall take effect at such time as the Federal agency

promulgating the rule determines). This rule also does not require analysis under the Regulatory Flexibility

Act. See 5 U.S.C. 604(a) (requiring a final regulatory flexibility analysis only for rules required by the APA

or other law to undergo notice and comment). Finally, this rule does not contain any collection of

information requirements as defined by the Paperwork Reduction Act of 1995 (“PRA”). 44 U.S.C. 3501 et

seq. Accordingly, the PRA is not applicable.

IV.

Conclusion

The Commission extends by twelve months the compliance dates for certain of the rule

amendments in the Adopting Release as specified above.

By the Commission.

Dated: September 8, 2025.

Sherry R. Haywood,

Assistant Secretary.

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.