U.S. SECURITIES AND EXCHANGE COMMISSION·RULE 17AD‑22(E)(18)

U.S. Treasury Central Clearing Mandate (USTC)

Q: What access model do buy-side firms need before the repo compliance date?

There is no hedge-fund carve-out for repo, so most levered repo users need an access model - sponsored, agent, or direct - in place before June 30, 2027.

Q: Which clearing agencies does the mandate apply to?

SEC Rule 17Ad-22(e)(18) applies to any covered clearing agency (CCA) providing central counterparty services for U.S. Treasury securities. Today that CCA framework spans FICC's Government Securities Division, CME, and ICE.

USTC stands for U.S. Treasury Clearing. This page is a working reference on which cash and repo Treasury trades must be submitted for central clearing, and under what exemptions — for trading and operations teams tracking the phase-in.

Adopted Dec 13, 2023 Compliance dates extended Feb 25, 2025 Reference 17 CFR 240.17ad‑22(e)(18)

Action: Covered clearing agencies (FICC) must require direct participants to submit eligible U.S. Treasury cash and repo trades for clearing.
Key dates: Dec 31, 2026 — mandatory clearing begins for eligible cash outright trades
Jun 30, 2027 — mandatory clearing begins for eligible repo & reverse repo trades
Status: FICC's margin‑segregation requirement (Rule 17ad‑22(e)(6)(i)) — separating margin held for a direct participant's own Treasury positions from margin held for its indirect‑participant customers — reached its enforced compliance date on Sep 30, 2025. Both Dec 31, 2026 and Jun 30, 2027 compliance dates confirmed unchanged as of the SEC's August 2026 update.

Implementation roadmap

Three dates on the path to full clearing

The SEC extended both original compliance dates by one year on February 25, 2025. As of this writing, the runway to Phase 1 is short.

Sep 30, 2025

FICC access & rulebook — compliance date

Dec 31, 2026

Phase 1 — cash clearing begins

Jun 30, 2027

Phase 2 — repo clearing begins

Today · Sep 15, 2026

Sep 30, 2025 FICC access & rulebook — compliance date
Sep 15, 2026 Today — 107 days to Phase 1
Dec 31, 2026 Phase 1 — cash clearing begins
Jun 30, 2027 Phase 2 — repo clearing begins

107 days remain to the Phase 1 (cash) deadline · 288 days to Phase 2 (repo), measured from Sep 15, 2026.

Eligibility by phase

Cash outrights vs. repo & reverse repo

Both phases share two common gates — the trade must be a CCA‑eligible instrument and not a securities loan — then branch on counterparty type and participant status.

Phase 1

Cash (Outright Buy/Sell)

Compliance date · December 31, 2026

Narrower scope than repo — centered on interdealer and dealer‑to‑dealer activity.

✓ Direct participant acting as an interdealer broker (IDB)
✓ Direct participant trading with another registered broker‑dealer
✓ Direct participant trading with a government securities broker or dealer

✕ Central bank, sovereign entity, or international financial institution
✕ State or local government, or a natural person
✕ Hedge fund or other leveraged account — currently excluded for cash
✕ Qualifying inter‑affiliate transactions, subject to conditions

Most buy‑side‑to‑dealer cash trades fall outside these counterparty types and are not yet captured.

Phase 2

Repo & Reverse Repo

Compliance date · June 30, 2027

Much broader — captures most repo activity intermediated through direct participants.

✓ Virtually all repo/reverse repo of a direct participant — bilateral or triparty
✓ Sponsored / "done‑with" repo submitted through a sponsoring member
✓ Hedge fund, asset manager, or corporate repo executed through a direct participant

✕ Counterparty is a state or local government
✕ Counterparty is itself a CCP or derivatives clearing organization
✕ Qualifying inter‑affiliate repo — if the affiliate clears all its other UST repo
✕ Central bank, sovereign entity, or natural person

Unlike cash, repo has no hedge‑fund carve‑out — the main reason Phase 2 is expected to have materially larger buy‑side impact.

Trade-level check

USTC trade flowchart: is this trade clearing-eligible?

An animated, step-by-step walkthrough of the common gates and the separate cash / repo decision chains lives on its own page.

View the USTC trade flowchart →

Side-by-side

How the two phases differ

All dates and scope details current as of the SEC's August 2026 implementation update.
	Phase 1 — Cash Outrights	Phase 2 — Repo / Reverse Repo
Compliance date	December 31, 2026	June 30, 2027
Scope breadth	Narrow — IDB & dealer‑to‑dealer trades	Broad — nearly all in‑scope repo activity
Hedge fund / leveraged accounts	Currently excluded	In scope — no carve‑out
Inter‑affiliate treatment	Exempt, subject to conditions	Exempt if affiliate clears all its other UST repo
Government / sovereign counterparties	Exempt	Exempt (state/local government)
Expected market impact	Sell‑side / interdealer focused	Significant buy‑side impact

Key takeaways

What this means for trading & operations teams

Counterparties

Map counterparties now

Identify which counterparties are, or will become, CCA direct participants — eligibility hinges on that status.

Deadline

Cash trades face the earlier date

Dealer‑to‑dealer and IDB desks face the earlier deadline of December 31, 2026.

Scope

Repo has the widest reach

No hedge‑fund carve‑out means most levered repo users need an access model — sponsored, agent, or direct — before June 30, 2027.

Evidence

Document the exemptions

Inter‑affiliate, sovereign, and government carve‑outs require conditions to be met and evidenced, not assumed.

As of September 2026

Open items at the SEC

SEC

Exemptive relief still moving

The SEC has granted conditional relief for private funds to clear repo through captive clearing subsidiaries. Two industry requests remain under review, with a reopened comment period:

Institute of International Bankers (IIB) relief for non‑U.S. transactions
SIFMA's request to soften the inter‑affiliate "outward‑facing" clearing condition

A separate request to allow net (rather than gross, customer‑by‑customer) omnibus margin calculations is also pending. Comments on both tracks were due August 31, 2026.

Reader Q&A

Questions readers ask about the mandate

What changed when the SEC extended the original Treasury clearing compliance dates?

The SEC extended both original compliance dates by one year on February 25, 2025. As part of that extension, FICC's margin‑segregation requirement (Rule 17ad‑22(e)(6)(i)) — separating margin held for a direct participant's own Treasury positions from margin held for its indirect‑participant customers — reached its own enforced compliance date on September 30, 2025 — ahead of the two trade‑clearing dates above.

What access model do buy‑side firms need before the repo compliance date?

There is no hedge‑fund carve‑out for repo, so most levered repo users need an access model — sponsored, agent, or direct — in place before June 30, 2027. See "How the two phases differ" and "What this means for trading & operations teams" above for the detail.

Which clearing agencies does the mandate apply to?

SEC Rule 17Ad‑22(e)(18) applies to any covered clearing agency (CCA) providing central counterparty services for U.S. Treasury securities. Today that CCA framework spans FICC's Government Securities Division, CME, and ICE.

What trades and counterparties are exempt from Treasury clearing?

Trades where a counterparty is a central bank, sovereign entity, international financial institution (IFI), or natural person are exempt from the clearing requirement, alongside additional repo‑specific exclusions. See the exemptions detail above, and the interactive flowchart for a step‑by‑step determination.

Is my firm's repo or cash Treasury trade required to clear?

Use the USTC trade flowchart to work through the eligibility checks that apply to your specific trade — instrument scope, counterparty exemptions, and (for repo) additional exclusions — in order.

Assessing your firm's Treasury clearing exposure?

AKONCEPT Consulting Americas LLC helps trading, operations, and compliance teams work through USTC readiness — from eligibility mapping to sponsor and custodian model selection.

Talk to AKONCEPT