Key milestones this year

NYSE Arca extended hours approved – The SEC granted accelerated approval to lengthen NYSE Arca’s pre and post market so the exchange can operate 22 hours a day, Monday to Thursday (1:30am – 11:30pm ET) and 1:30am – 8:00pm ET on Fridays, subject to industry dependencies. NYSE targets launch in late 2026 pending SIP and DTCC readiness.^[1]

Securities Information Processors (SIPs) propose near 24×5 – Within the Consolidated Tape Association Plan/Consolidated Quotation Plan (CTA/CQ Plans) and UTP Plan, the SIPs flagged they would seek 8:00pm ET Sunday to 8:00pm ET Friday operations with a brief nightly pause, contingent on DTCC clearing availability and TRF coverage. The SEC has up to 300 days to act on the amendment.^[2]

FINRA Trade Facility Reporting (TFR) expansion filing – FINRA filed to open TRFs at 4:00am ET (currently 8:00am) with implementation in Q1 2026, an incremental step toward aligning off exchange reporting to extended market data hours. ^[3]

Nasdaq & Cboe timelines – Nasdaq publicly signaled a 24×5 capability as early as H2 2026, subject to approvals and infrastructure alignment. Cboe announced plans to enable 24×5 equities on EDGX, likewise contingent on SIP and SEC approvals.[^4]

DTCC (NSCC) extended trade capture – DTCC’s Universal Trade Capture (UTC) will support 24×5 trade processing with client testing from Jan 2026 and production targeted for June 2026. A new FIX Tag 715 (Clearing Business Date) becomes mandatory on UTC real-time output.^[6]

Off-hours volumes are already material – NYSE research shows off-hours trading accounted for ~11.5% of US equities activity in Q2 2025, with several single day premarket volume records.^[7]

SIFMA/DTCC working groups are pivoting from advocacy to playbook drafting – Agendas now focus on settlement cycle exceptions, corporate actions cutoffs and cyber resiliency for 24 × 5.

Outside the US, similar initiatives are also emerging. LSEG is publicly exploring 24-hour trading. HKEX leaders have discussed a gradual extension to establish systems capable of near 24-hour derivatives trading later in the decade. This article focuses on US implementation, but global alignment will be important for liquidity and client coverage.^[8],[9]

Significant changes since our February 2025 update

Regulatory green lights & dependencies clarified
Extended exchange hours (NYSE Arca), SIP near continuous operations, and FINRA’s TRF expansion filings establish the key prerequisites: public price dissemination, off exchange reporting, and central clearing during extended windows. Together these steps reduce “overnight blind spots” and normalize trading outside 9:30–4:00.[10]

Clearing and post trade modernization is on a dated program plan
DTCC’s roadmap calls out Extended Trading Hours (ETH) on UTC (24×5 submission windows), with ETH connectivity testing beginning in 2025-26 and a go live sequence aligned to other clearing simplifications. Importantly, UTC real-time output will add Tag 715 to support next day trades and unique identification across “two clearing business dates” overnight.

CAT and surveillance readiness
CAT already accepts files 24×7, with 8:00 a.m. ET T+1 deadlines. As sessions extend, firms must align capture, clock sync, and exception management coverage to the additional trading hours.[11]

Venue landscape diversifies
Alongside incumbent venues’ plans, 24X introduces a lit venue designed around near continuous sessions. Expect nuanced differences in opening auctions, halt protocols, and disclosure frameworks as each venue phases in overnight sessions.[12]

ATS Overnight trading perception shifted positively in recent months in the APAC region, specifically in Korea. Aiming to provide increased accessibility with regulatory support. This would essentially improve market competitiveness and anticipates increasing liquidity in both US and Korean markets.

Planning for key market impacts

Buy‑side & asset owners

Price discovery & event risk: Earnings releases, macro prints, and geopolitics will increasingly be priced into US equities before the 9:30am ET open. Execution strategies need overnight liquidity analytics and conditional/limit first discipline. Off-hours volatility and spreads remain structurally wider. [13]

ETF specifics: With ETFs eligible on extended sessions (NYSE Arca), market maker obligations and basket price discovery must operate across more time zones; portfolio managers should refresh iNAV/hedging practices and AP connectivity, especially for global baskets.[14]

Governance & oversight: Investment risk committees should update mandates (e.g. when a fund may trade, what order types are allowed overnight, and how to monitor fair treatment of investors across time zones).

Broker dealers & market makers

Front office microstructure: Smart Order Routers must be venue aware across expanded sessions (including distinct overnight schedules), adapt to SIP/plan halts, and incorporate venue specific risk checks and kill switches for low liquidity regimes. (SEC approval of NYSE Arca’s rule filing contemplates investor protection measures in these sessions.)[15]

Post trade & clearing:

- UTC 24×5 enables trade capture from 8:00pm ET Sunday to 8:00pm ET Friday, with “Good Night”/recycle requirements and sequencing resets. ll firms receiving UTC real-time output must support FIX Tag 715 (Clearing Business Date) and successfully test in PSE starting Jan 2026.

- Risk & liquidity at NSCC – DTCC indicates no change to margin framework; NSCC’s VaR recalculates every 15 minutes, with intraday mark-to‑market and liquidity programs covering overnight flow. Expect monitoring of volumes to inform any future adjustments.

- Institutional confirmations/affirmations – TradeSuite affirmation cutoff remains 9:00pm ET (S-1); support for future dated trade date confirms will arrive shortly after the cutoff as part of the 2026 changes. Corporate action cutoffs remain unchanged for now.

Transparency & reporting:

-TRF hours will open at 4:00am ET (target Q1 2026), eliminating the early morning reporting lag when SIPs are open but TRFs are closed.[16]

- SIPs intend near 24×5 operation with a nightly technical pause, subject to SEC approval and DTCC/TRF conditions – key for public dissemination and NBBO integrity overnight.[17]

Surveillance & controls – Extend market abuse surveillance (spoofing, layering, momentum ignition) and AML/fraud controls into new sessions; recalibrate thresholds for thin liquidity periods (FINRA’s 2025 Oversight Report highlights extended hours risk themes). [18]

Client disclosures & suitability – Refresh extended hours risk disclosures (volatility, wider spreads, partial fills, outages during nightly pauses), aligning to exchange rules and Reg BI obligations as venues widen their hours.[19]

US Equities Extended Trading Hours: October 2025 Implementation Update

Determining a realistic implementation timeline

Based on current public milestones, most firms should plan for a phased convergence through 2026.

Q4 2025 to Q1 2026 – TRF opening time moves to 4:00am ET; SIP Plan amendment under SEC review; firms complete gap assessments and begin controls/testing build.^[20]
Q2 2026 – DTCC UTC PSE testing for ETH (Tag 715) in flight; production cut targeted June 2026 for extended trade capture.
Late 2026 – NYSE Arca aims to launch 22×5, assuming SIP+DTCC readiness; Nasdaq targets 24×5 capability in H2 2026; Cboe continues toward 24×5 on EDGX pending approvals.^[21]

DTCC’s client roadmap reinforces these dates, showing ETH connectivity/testing in 2025-26, UTC output changes, and related clearing enhancements such as mark‑to‑market optimization and ETF options clearing – all converging toward Q4 2026 go‑lives for the modernized platforms.

Operating model playbook: what leading firms are doing now

We are already seeing harmonized firmwide programs being created across large firms with investment banks and wealth management arms. Common elements span the following areas.

1. Strategy & governance

- Define where and why you’ll participate in off-hours (client coverage, APAC franchise, hedging, ETF creation/redemption) and codify desk mandates and risk appetite for overnight liquidity.

- Conducting client offering and competitor analysis to drive offering for extended hours.

2. Conducting impact analysis

- Front to back analysis across systems, process & stakeholders.

3. Front office microstructure

- Expand liquidity analytics (spread/impact models) calibrated to premarket/post market and overnight regimes; integrate NYSE research benchmarks on off-hours participation to set expectations with clients.[22]

4. Post trade & DTCC connectivity

- Mandatory incorporation of UTC Tag 715 into real-time output processing; plan PSE testing (Jan 2026), production cut (target June 2026), and ensure FIX session recycle/“Good Night” handling.

5. Data & market data ops

- Corporate actions processes and product reference data process analysis.

6. Surveillance & compliance

- Extend market surveillance models and case management staffing; review CAT completeness SLAs across all sessions; ensure clock sync and venue specific fields are captured in off-hours.[23]

7. Client experience & disclosures

- Refresh extended‑hours disclosures, margin policies, and best‑ex statements; educate clients on order types, fills, and nightly pause mechanics; ensure 24×5 support coverage SLAs.

8. Cyber & resilience

- Rehearse incident response with a drastically smaller nightly maintenance window; confirm Reg SCI coverage and BCP failover for overnight trading.

9. People & shifts

- Build a follow-the-sun model across trading, supervision, tech ops, and control functions; revisit location strategy to balance cost, skill, and regulatory presence.

How Capco can help

Readiness assessment – four‑week sprint covering connectivity, risk, ops and client disclosure gaps.

Industry Intelligence and partnerships - We already partner across the sector - including tier-one banks - to deliver end-to-end solutions, supported by a strong network spanning industry working groups, exchanges (NYSE/24X etc) /ATSs (BOATS/BRUCE etc), and key institutional contacts.

Target Operating Model blueprint – leveraging our playbooks from prior T+1 and crypto 24/7 projects.

Execution support / RFP response – full implementation team aligned to the DTCC timetable; accelerators for FIX Tag 715 and overnight surveillance rules.

We have an RFP response pack and point of view deck ready to share under NDA.

Contact us to schedule a deep dive aligned to your SIFMA/DTCC working group commitments.