Background
On March 6 2024, the Securities and Exchange Commission adopted amendments to the disclosure requirements of Rule 605 of Regulation NMS for executions on covered orders in NMS stocks (those listed on a national securities exchange). The amendments expand who must report, redefine order‑information categories, and mandate a machine‑readable summary of execution quality.
Rule 605 was adopted in 2000 to help investors compare execution quality across exchanges, associations, market makers, and ATSs. Yet its disclosure content hasn’t been meaningfully updated since then—falling behind today’s high‑speed, data‑driven markets.
Who is required to report?
- Exchanges, ATSs, market makers
- New → Broker‑dealers with ≥ 100 k accounts
- New → Single‑dealer platforms
Compliance Date
December 15 2025
Key Changes at a Glance
Broader Coverage
Expands “covered orders” to include trades outside regular market hours, stop‑price, and non‑exempt short‑sale orders.
Notional Size Buckets
Order size now combines dollar value plus lot type.
New Order Types
Marketable IOC, stop‑market/limit (marketable & non‑marketable).
Microsecond Metrics
Execution speed & spreads in ms; horizons <100 µs → 5 min.
Price & Size PI
%‑based PI stats and size‑improvement benchmarks.
Public CSV/PDF
Machine‑readable summary file in SEC schema.
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