Countdown to Clearing: Preparing for the Shift to U.S. Treasury Central Clearing

• The Securities and Exchange Commission’s (SEC) clearing rule for U.S. Treasury securities requires eligible cash trades to be centrally cleared by December 31, 2026, and eligible repurchase agreement (repo) trades by June 30, 2027.
• SIFMA has led the industry’s preparation, publishing market-standard clearing documentation, preparing operational playbooks, surveying readiness, and seeking targeted regulatory relief and clarity from the SEC.
• The industry is broadly ready for the cash deadline, but significant work remains on repo.  SIFMA, working with both our membership and the official sector, is focused on closing those gaps before June.

Central clearing of U.S. Treasury securities is one of the most significant structural changes in decades to the world’s most important securities market. With the cash clearing compliance date just over one month away, here is a look at industry preparedness for the December deadline, and what SIFMA is doing to support a smooth transition for market participants.

A Historic Shift in Treasury Market Structure

In December 2023, the SEC adopted rules requiring secondary market trades for in-scope U.S. Treasury securities and repos to be cleared through a covered clearing agency (CCA) when one of the parties is a member of that CCA. Today, most Treasury trades settle bilaterally while some clear through the Fixed Income Clearing Corporation (FICC), so the mandate will bring a significant volume of new activity into central clearing.

Following urging from the industry due to concerns over operational, legal, and technological complexities, the SEC later extended the compliance dates, phasing in the requirement over two stages:

• December 31, 2026: eligible Treasury cash transactions
• June 30, 2027: eligible Treasury repo transactions

The rule will reshape how broker-dealers, institutional investors, interdealer brokers, principal trading firms, and clearing agencies operate in this market. Getting the transition right matters, given the central role Treasuries play in the global financial system.

Getting Ready for December: The Cash Deadline

SIFMA has spent the past three years building the legal, operational, and regulatory foundation the industry needs to meet the cash deadline. That work has centered on four areas:

1. Market-standard documentation. SIFMA convened buy- and sell-side working groups to develop standardized clearing agreements, including optional standard terms that could be applied based on the commercial relationship between the parties, so firms would not have to negotiate bespoke terms addressing the same issues. The SIFMA Master Treasury Securities Clearing Agreement: Done-With, covering trades executed and cleared by the same broker, was first issued in 2024 and updated in 2026 to incorporate triparty arrangements, including the BNY and FICC Collateral-in-Lieu (CIL) service. On July 30, 2026, SIFMA published the 2026 Master Treasury Securities Clearing Agreement: Done-Away, along with its Schedule and Modules. The done-away model lets firms trade with multiple executing brokers while clearing through a single designated clearing provider. The agreement reflects eighteen months of work by broker-dealers and asset managers, and includes standard options to facilitate individual negotiations.
2. Operational and accounting groundwork. In 2024, SIFMA published an Industry Considerations report on Treasury clearing. In late 2025, SIFMA followed this report with a new report on done-away model design implementation across central limit order book, request-for-quote, and voice execution. SIFMA also completed a review of FICC’s Agent Clearing Service and worked with the SEC’s Office of the Chief Accountant to resolve related accounting questions, making the working group’s conclusions
3. Measuring readiness. Together with BNY, Broadridge, and the Depository Trust & Clearing Corporation (DTCC), SIFMA sponsored the S. Treasury Central Clearing Pulse Survey, conducted by The ValueExchange. The latest edition, released September 22 and drawing on 340 experts, shows broad industry readiness for the cash go-live date in December, while also demonstrating that significant hurdles remain to navigate between now and the June repo deadline.
4. Education and outreach. SIFMA has and continues to host industry briefings on the new documentation and implementation considerations, including a November 10 Documentation Training Seminar with Cleary Gottlieb. SIFMA and ISDA are collaborating with S&P Global Market Intelligence to support market participants as they prepare for the transition to central clearing of U.S. Treasury securities. Through this initiative, MTSCA Done-With and Done-Away agreements will be available digitally through Create, now part of S&P Global’s Counterparty Manager, combining industry-standard documentation with a technology-enabled workflow for drafting, negotiating and managing Treasury Clearing agreements. Together, the organizations aim to promote greater standardization, efficiency and transparency across the Treasury clearing documentation process. Several SIFMA podcasts have also walked listeners through industry readiness and documentation to provide a roadmap to compliance and implementation.

Looking Ahead to June: The Repo Deadline

The repo deadline presents a steep climb. The repo mandate is broader in scope than the cash mandate, and the survey makes clear where firms are struggling. More than half of respondents have funded repo-clearing projects underway, up from 38% in 2025. But among delayed programs, 88% cite legal and contract negotiation as the cause, 72% of firms say they need more clarity on key rules, and readiness outside North America lags significantly.

SIFMA’s repo work is aimed squarely at those pressure points.

Putting the documentation to work. SIFMA’s standardized clearing agreements give repo participants both standard terms as well as optional provisions that can be used based on the parties’ commercial relationship. With the done-away agreement now available, firms have the runway they need to choose clearing models, onboard with clearing providers, and complete negotiations before June. Because contract negotiation is the leading cause of delays, standardized terms are one of the most practical tools the industry has developed to accelerate compliance.

Seeking practical regulatory relief. Many institutions rely on inter-affiliate repo for internal liquidity, treasury, and collateral management, particularly across time zones. On April 10, 2026, SIFMA asked the SEC for targeted exemptive relief to make the rule’s inter-affiliate exemption workable, including extending it to all affiliates other than investment companies and adjusting the condition that affiliates clear all outward-facing repo. The SEC granted this relief in late October 2026 incorporating within that relief additional clarity with respect to certain cross-border transactions. SIFMA AMG also supported relief, since granted by the SEC, that allows private funds to access repo clearing through captive clearing subsidiaries. The SEC is considering SIFMA AMG’s request to extend such relief to mortgage REITs.

Addressing broker-dealer capital and customer protection rules. On June 24, 2026, SIFMA asked the SEC for relief and clarity under Rule 15c3-3, including the reserve formula for proprietary accounts of broker-dealers (PAB) and a related note to the customer reserve formula. Resolving these questions will help clearing members serve clients efficiently as repo volumes move into clearing.

Continuing to track readiness. SIFMA will keep using its survey work and member working groups to identify where the industry stands and where targeted help is needed, from technology integration to contingency planning.

The Road Ahead

The industry has moved firmly from preparation to execution and is on track for the December deadline. The months between the cash and repo deadlines give firms a chance to build on that momentum. SIFMA will continue working alongside our members, market infrastructure providers, and the SEC to support a smooth, coordinated transition that enhances resiliency while preserving the depth and liquidity that define the U.S. Treasury market.

More resources are available in SIFMA’s Treasury Clearing Resource Center.