The SEC's T+1 Rules: What Release 34-96930 Changed and Where Each Part Stands Now
Updated October 2026, after T+1 took effect. First published January 2024.
The SEC adopted T+1 on February 15, 2023, in Release No. 34-96930 (Advisers Act Release No. IA-6239). It appeared in the Federal Register on March 6, 2023 at 88 FR 13872. The rules took effect May 5, 2023, and every part had the same compliance date: Tuesday, May 28, 2024, chosen because it followed the Memorial Day weekend.
This is a reference to each part of the release, what it requires, and where it stands as of October 2026. For why the SEC did it, see The Case for T+1.
The Parts at a Glance
| Rule | What the release did | Who it binds |
|---|---|---|
| Exchange Act Rule 15c6-1(a) | Shortened the standard settlement cycle from T+2 to T+1 | Broker-dealers |
| Rule 15c6-1(b) | Added security-based swaps to the exclusions | Broker-dealers |
| Rule 15c6-1(c) | Cut the cycle for firm commitment offerings priced after 4:30 p.m. ET from T+4 to T+2 | Broker-dealers in those offerings |
| New Rule 15c6-2 | Required written agreements or policies and procedures for same-day allocation, confirmation, and affirmation | Broker-dealers in the institutional trade process |
| Advisers Act Rule 204-2(a)(7)(iii) | Required time-stamped records of allocations, confirmations, and affirmations | Registered investment advisers |
| New Rule 17Ad-27 | Required policies for straight-through processing and an annual public report | Clearing agencies that provide central matching |
| Regulation S-T | Required the 17Ad-27 report on EDGAR in Inline XBRL | The same clearing agencies |
Rule 15c6-1: The Settlement Cycle
Paragraph (a) bars a broker-dealer from entering a contract for a security that settles later than "the first business day after the date of the contract," unless the parties expressly agree otherwise at the time of the transaction. It excludes exempted securities, government securities, municipal securities, commercial paper, bankers' acceptances, and commercial bills. Paragraph (b) also excludes unlisted limited partnership interests, security-based swaps (new in 2023), and anything the SEC exempts by order. The SEC's 1995 orders for certain foreign securities and insurance products stayed in effect without changes.
Paragraph (c) now gives firm commitment offerings priced after 4:30 p.m. ET until T+2, down from T+4. The SEC had proposed deleting (c) and kept it. Paragraph (d), which lets the managing underwriter and the issuer agree on another settlement date for a firm commitment offering, didn't change.
Rule 15c6-2: Same-Day Affirmation
A broker-dealer that takes part in allocation, confirmation, or affirmation with another party, for a trade subject to Rule 15c6-1(a), has two options. It can enter written agreements with the relevant parties, or it can establish, maintain, and enforce written policies and procedures. Either way, the goal is to finish the process "as soon as technologically practicable and no later than the end of the day on trade date." The policies and procedures option has five required elements in paragraph (b), including target time frames on trade date and measured, documented completion rates.
The SEC proposed only the written-agreement option. It added policies and procedures after commenters said new agreements would be hard to negotiate, and it acknowledged that nearly all broker-dealers without existing agreements might choose that route. Rule 15c6-2 in Practice covers how to choose and what each element means.
Rule 204-2: Adviser Records
For any trade subject to Rule 15c6-2(a), a registered investment adviser has to make and keep each confirmation it receives and each allocation and affirmation it sends or receives. Each allocation and affirmation needs a date and time stamp showing when it was sent or received. SEC staff added in a March 27, 2024 FAQ that the requirement applies whatever the source or form of the record, including email and paper, and whenever it arrives. Our post on what investment advisers need to know about T+1 covers the adviser side.
Rule 17Ad-27: Central Matching Services
A clearing agency that provides a central matching service has to keep policies and procedures reasonably designed to facilitate straight-through processing. Every year it files a report with the SEC covering those policies, its progress, and monthly data: trades, allocations, and confirmations submitted, the share of confirmations affirmed on trade date, the share matched and confirmed automatically, and measures of manual processing. The report covers the calendar year and is due within 60 days of year-end, on EDGAR in Inline XBRL. The release set March 1, 2025 as the deadline for the first one.
When the SEC adopted the rule, three matching services held exemptions from clearing agency registration: DTCC ITP Matching (US), Bloomberg STP, and SS&C Technologies. The release noted that only one was active.
What the SEC Decided Not to Change
Part VI of the release answered comments about other rules that refer to settlement date. The SEC left them alone, and their deadlines moved with the cycle.
- Regulation SHO Rule 204's close-out deadlines are tied to settlement date, so they shortened automatically: T+2 for short sales, T+4 for long sales and bona fide market making. The SEC declined to reevaluate them. Regulation SHO Rule 204 Under T+1 has the details.
- Under Rule 10b-10, the broker still has to give or send the customer confirmation at or before completion of the transaction. The SEC declined to make electronic delivery the default.
- Among the financial responsibility rules, Rule 15c3-3(m) still requires a broker to buy in a customer's long sale if it hasn't received the securities within ten business days after settlement date, which now comes a day sooner. The SEC said staff would keep watching how Rule 15c3-3(d) works under T+1.
- The SEC expected SRO rules tied to T+2 to need changes, and it named FINRA Rule 11860, which allowed affirmation as late as the day after trade date.
Regulation T moved on its own, because 12 CFR 220.2 defines the payment period as the standard settlement cycle plus two business days. It's now T+3.
Where It Stands in October 2026
All of it is in force. The current text of Rule 15c6-1, Rule 15c6-2, and Rule 17Ad-27 on Cornell's Legal Information Institute still carries only the March 6, 2023 source note, so none of them has been amended since adoption. The main interpretive document is the staff FAQ of March 27, 2024. Its most quoted answer is that a 90% same-day affirmation rate doesn't satisfy Rule 15c6-2 on its own, because the rule applies to each transaction.
The SEC also considered T+0 in 2023 and declined to adopt it. The September 2024 industry after-action report argued that T+0 "is not simply the next step" and would need a full independent review first.
This post is for informational purposes only and does not constitute legal advice. For guidance on specific regulatory obligations, consult your counsel or compliance advisor.