Key issues require quick resolution for US Treasury clearing mandate go-live
11 November 2025 US
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A collection of firms, in collaboration with The ValueExchange,have released findings from the , which draws on key insights regarding the upcoming regulation.
Conducted by The ValueExchange, the survey reviews the current position of US firms that are yet to face the cash implementation deadline for the US Treasury clearing mandate, which is to be enforced on 31 December 2026.
Led by the 厙惇勛圖 Industry and Financial Markets Association (SIFMA), BNY, Broadridge, and The Depository Trust & Clearing Corporation (DTCC), the survey includes responses from buy side and sell side firms, custodians, and covered clearing agencies (CCAs) in the US, Europe, and Asia.
While a majority of US respondents are very familiar with regulatory changes, providing a net positive outlook from a US domestic readiness perspective, clarity is required relating to inter-affiliate flows and with respect to the final rules for the new CCAs.
If these and other issues are not resolved by early 2026, the survey indicates that firms' abilities to build and be ready on time may be impacted.
Steve Byron, managing director and head of technology, operations, and business continuity at SIFMA, notes: The move to centralised Treasury clearing is a complex and significant lift for our
member firms.
Given the key role that US Treasuries play within the global markets, ensuring global awareness of the implementation process is critically important.
SIFMA continues to build out resources for our members, such as standardised documentation and implementation guides, which are available to assist all market participants.
Europe and Asia firms trail the US in their preparations for central clearing, with 82 per cent and 80 per cent of respondents respectively, reporting they have not progressed beyond scoping.
The findings from the 330 global market participants suggest that clarity remains a key barrier to readiness, highlighting the need for further regulatory lucidity in addition to system changes to support mandatory clearing.
54 per cent of firms are confident they will be ready by the cash deadline, while 40 per cent of respondents say they are very confident they will be ready by the repo deadline (30 June 2027).
Nate Wuerffel, global head of market structure and product leader for the Global Collateral Platform at BNY, states: Firms are making meaningful progress, but as the survey highlights, success requires diving into the details to get this right.
The urgency is clear not just to meet compliance deadlines, but for participants to strategically position themselves for success in a rapidly evolving market structure.
US Treasury central clearing is expected to have a negative impact on operating and Treasury costs, with 38 per cent of firms anticipating an increase in margins by more than 25 per cent, the survey says. While 55 per cent of respondents predict a rise in regulatory capital costs.
Key operational impacts identified by survey respondents included contract repapering (cited by 55 per cent of firms) and back-office changes (cited by 66 per cent of firms).
For buy side firms, this impact is concentrated at the repo desk, whereas for sell side
firms, it affects the entire organisation including systems, IT, settlement, and
compliance.
Laura Klimpel, managing director, head of DTCCs fixed income and financing solutions, comments: FICC remains focused on providing optimal clearing services that meet the needs of all firms that are impacted by the expanded US Treasury clearing requirements.
These findings illustrate the need for firms to advance preparations as soon as possible, and we stand ready to lead the industry with education, access models and solutions that enable compliance.
The responses from the survey discovered that the implementation timeline remains a challenge, with 29 per cent of buy side firms not expecting to complete preparations before the end of 2027.
The majority of firms state they expect the operational and technology workloads to be the last to complete, indicating that a heavy lift across systems and integration layers is still to come.
Discussing the survey responses, Quentin Limouzi, global head of post-trade at Broadridge, notes: Driving transformation across long-established clearing workflows requires a disciplined and coordinated effort across firms.
With the deadlines fast approaching, firms have little time to move from planning to
execution.
Were working closely with clients to help them meet these milestones accelerating automation, innovating operational and technology workflows, and ensuring seamless integration with their clearing venues.
Conducted by The ValueExchange, the survey reviews the current position of US firms that are yet to face the cash implementation deadline for the US Treasury clearing mandate, which is to be enforced on 31 December 2026.
Led by the 厙惇勛圖 Industry and Financial Markets Association (SIFMA), BNY, Broadridge, and The Depository Trust & Clearing Corporation (DTCC), the survey includes responses from buy side and sell side firms, custodians, and covered clearing agencies (CCAs) in the US, Europe, and Asia.
While a majority of US respondents are very familiar with regulatory changes, providing a net positive outlook from a US domestic readiness perspective, clarity is required relating to inter-affiliate flows and with respect to the final rules for the new CCAs.
If these and other issues are not resolved by early 2026, the survey indicates that firms' abilities to build and be ready on time may be impacted.
Steve Byron, managing director and head of technology, operations, and business continuity at SIFMA, notes: The move to centralised Treasury clearing is a complex and significant lift for our
member firms.
Given the key role that US Treasuries play within the global markets, ensuring global awareness of the implementation process is critically important.
SIFMA continues to build out resources for our members, such as standardised documentation and implementation guides, which are available to assist all market participants.
Europe and Asia firms trail the US in their preparations for central clearing, with 82 per cent and 80 per cent of respondents respectively, reporting they have not progressed beyond scoping.
The findings from the 330 global market participants suggest that clarity remains a key barrier to readiness, highlighting the need for further regulatory lucidity in addition to system changes to support mandatory clearing.
54 per cent of firms are confident they will be ready by the cash deadline, while 40 per cent of respondents say they are very confident they will be ready by the repo deadline (30 June 2027).
Nate Wuerffel, global head of market structure and product leader for the Global Collateral Platform at BNY, states: Firms are making meaningful progress, but as the survey highlights, success requires diving into the details to get this right.
The urgency is clear not just to meet compliance deadlines, but for participants to strategically position themselves for success in a rapidly evolving market structure.
US Treasury central clearing is expected to have a negative impact on operating and Treasury costs, with 38 per cent of firms anticipating an increase in margins by more than 25 per cent, the survey says. While 55 per cent of respondents predict a rise in regulatory capital costs.
Key operational impacts identified by survey respondents included contract repapering (cited by 55 per cent of firms) and back-office changes (cited by 66 per cent of firms).
For buy side firms, this impact is concentrated at the repo desk, whereas for sell side
firms, it affects the entire organisation including systems, IT, settlement, and
compliance.
Laura Klimpel, managing director, head of DTCCs fixed income and financing solutions, comments: FICC remains focused on providing optimal clearing services that meet the needs of all firms that are impacted by the expanded US Treasury clearing requirements.
These findings illustrate the need for firms to advance preparations as soon as possible, and we stand ready to lead the industry with education, access models and solutions that enable compliance.
The responses from the survey discovered that the implementation timeline remains a challenge, with 29 per cent of buy side firms not expecting to complete preparations before the end of 2027.
The majority of firms state they expect the operational and technology workloads to be the last to complete, indicating that a heavy lift across systems and integration layers is still to come.
Discussing the survey responses, Quentin Limouzi, global head of post-trade at Broadridge, notes: Driving transformation across long-established clearing workflows requires a disciplined and coordinated effort across firms.
With the deadlines fast approaching, firms have little time to move from planning to
execution.
Were working closely with clients to help them meet these milestones accelerating automation, innovating operational and technology workflows, and ensuring seamless integration with their clearing venues.
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