***UPDATED DEC 2025***

As of December 3, 2025, the SEC has announced another temporary exception from compliance for Rule 13f-2 and Form SHO reporting, effective January 2, 2026 and ending on January 2, 2028.  The first filing will be due no later than February 14, 2028.

On January 2, 2024, the SEC adopted Rule 13f-2 to provide greater transparency to investors and other market participants by increasing the public availability of short sale related data. This change affects many 13F institutional investment managers who will now be required to report to EDGAR their short sales positions on a monthly basis, with the requirement starting on January 2, 2025, on the new Form SHO form type.

Form SHO must be filed by 14 calendar days after the end of each month, therefore the first filing will be required by no later than February 14, 2028.

Institutional investment managers will be required to report their short positions if they exceed either of the following thresholds:

1. A monthly average gross short position at the close of regular trading hours in the equity security with a U.S. dollar value of $10 million or more.
2. A monthly average gross short position at the close of regular trading hours as a percentage of shares outstanding in the equity security of 2.5 percent or more.

If a manager determines, or is made aware, that it has filed a Form SHO with errors that affect the accuracy of the information reported, they must file an amended Form SHO within 10 calendar days of discovery of the error, and must restate the Form SHO in its entirety.

The SEC will aggregate and publish monthly data collected via Form SHO, after a one month delay, beginning in April 2028.

Workiva’s Implementation

In Workiva, the data for this form type is provided by a specially formatted Spreadsheet, similar to 13F-HR, Form 144, N-PX, and SCHEDULE 13.  The format of this spreadsheet follows the rule’s column order for Table 1.

Table 1 consists of one security per row, with all fields required except for LEI, CUSIP, and FIGI, and reports the monthly short positions. This sheet name must start with the text “Table 1” but otherwise is the user’s choice.  A maximum of 1,000 issuers are allowed per filing.  While CUSIP and FIGI are optional, you may wish to provide one or both of these to help with Table 2 reporting.

Table 2 reports the daily net change in short positions for the securities listed in Table 1.  You have several options for specifying the securities on Table 2:

1. You may supply the full Issuer Name and Title of Security
2. Supply only the CUSIP value, if and only if you provided it in Table 1 / Column E
3. Supply only the FIGI value, if and only if you provided it in Table 1 / Column F
4. Provide all of the above

You need only provide the security identifier (name & title, CUSIP, or FIGI) once per security, and the value will be retained for subsequent rows.  For example, if you provide the Name and Title “Issuer One” and “Class A” on row 2, these values will be used for rows 3 through 26, or until there are new identifiers provided.

EDGAR allows a maximum of 25 daily net change reports for each security in Table 2.  

Table 2 spreadsheet data can be provided in three different ways:

1. In a single sheet with a name starting with “Table 2” (you can add additional text afterwards).
   
   
2. If a CUSIP securities identifier was provided in Table 1 / Column E, you can have an individual spreadsheet for this security by using the CUSIP value as the first portion of the sheet name (you can add additional text afterward). 
   Using this method, the only required information is Settlement Date and Net Change, and the remaining data will be automatically incorporated from Table 1.  An example sheet name in this case would be “98139A105 - Workiva, Inc. Class A”.
   
3. If a FIGI securities identifier was provided in Table 1 / Colume F, you can have an individual spreadsheet for this security by using the FIGI value as the first portion of the sheet name (you can add additional text afterward).
   
   Using this method, the only required information is Settlement Date and Net Change, and the remaining data will be automatically incorporated from Table 1.  An example sheet name in this case would be “BBG001S5S399 - IBM Common Stock Sheet 2”.

For Notice and Combination Reports, entries reported by other reporting Manager(s) are entered on the “Other Managers” sheet, with a maximum of 10 other managers.

In Form SHO, there are no exhibits permitted, so only the spreadsheet data and filing wizard values are transmitted to the SEC in XML format.  Filers will be able to preview their filing as HTML in the Review step and in the Test Filing Preview, but this HTML is merely a representation of the XML (spreadsheet data and filing wizard values), and may appear different once live filed.  

There are no cover pages or other text documents associated with Form SHO, and there is no provision to add arbitrary text comment or footnotes.

Report Types 

There are three types of Form SHO reports, which are very similar to the Form 13F-HR report types:

• ENTRIES REPORT - all entries of this reporting Manager are reported and included in the spreadsheet.  The spreadsheet should include Table 1, and one or more Table 2 sheets, but no entries on the “Other Managers” sheet, which can be empty or omitted.
• NOTICE - no entries are reported and all entries are reported by other reporting Manager(s).  This will not require Table 1 or Table 2 sheets in the spreadsheet but will require the other manager reported on the “Other Managers” sheet (maximum of 10 managers).
• COMBINATION REPORT - a portion of the entries for this reporting Manager is reported via the spreadsheet and a portion is reported by other reporting Manager(s).  In this case, list the other reporting managers on the spreadsheet’s “Other Managers” sheet (maximum of 10 managers).

Additional Information

• SEC Adopts Rule to Increase Transparency Into Short Selling and Amendment to CAT
  NMS Plan for Purposes of Short Sale Data Collection
  
• Final Rules: Enhancing Short Sale Disclosure
  
• Final rule: Short Position and Short Activity Reporting by Institutional Investment Managers
  
• Form SHO Spreadsheet Template