On December 3, 2025, the SEC issued an order providing an exemption from compliance with the short position and short activity reporting rules. According to the order, compliance with Rule 13f-2 and Form SHO is now delayed until January 2, 2028.
The first Form SHO filing was set to be due on Valentine’s Day 2025, but the SEC pushed back the deadline to February 17, 2026. Now, as large entities finalize Reg S-P preparations, and as all compliance programs complete annual IARD renewals, the question for 2026 is: will Form SHO be delayed again?
The compliance deadline for larger advisers (those with $1.5B or more in AUM) is less than two weeks away (Dec. 3, 2025). While much of what the previous administration proposed has been tossed or postponed, the SEC has made it clear that Amended Reg S-P is not only here to stay, but it’s also a key focus area.