Rule 605 of Regulation NMS requires market centers and (as of August 1, 2026) large broker-dealers to publish monthly execution quality reports. These reports show how well orders were executed — price improvement, fill rates, execution speed, and effective spreads.
Who must report: Exchanges, ATSs, OTC market makers, and broker-dealers with 100,000+ customer accounts.
Frequency: Monthly reports, published publicly.
Coverage: NMS stocks only — exchange-listed equities.
Rule 606 requires all broker-dealers routing customer orders to publish quarterly reports disclosing where orders were sent for execution and the nature of any financial relationships with those venues.
Who must report: All broker-dealers routing customer orders in NMS stocks and options.
Frequency: Quarterly reports.
Coverage: NMS stocks and listed options.
Additional: Upon customer request, broker-dealers must disclose where a specific order was routed.
The SEC extended the original December 14, 2025 compliance date to August 1, 2026 to give firms additional time to build reporting systems. The extension does not change what is required — only when.
Rule 605 now covers LARGER BROKER-DEALERS — any broker-dealer that introduces or carries 100,000 or more customer accounts must now file monthly execution quality reports. Previously only market centers (exchanges, ATSs, OTC market makers) were required to report. This brings major retail brokers — Fidelity, Schwab, Robinhood, Interactive Brokers — into scope for the first time.
Four new order types now required in reports: marketable immediate-or-cancel (IOC) orders, market orders with stop prices, marketable limit orders with stop prices, nonmarketable limit orders with stop prices. Order size categories now based on notional dollar value AND share count — not just share count as before. Extended hours orders now included as covered orders.
All reporting entities must now produce a SUMMARY EXECUTION QUALITY REPORT in addition to the existing detailed symbol-by-symbol report. The summary report aggregates execution quality across all NMS stocks — giving investors a simple top-line view without parsing thousands of rows of symbol data.
OTC market makers operating single-dealer platforms must now prepare SEPARATE Rule 605 reports for single-dealer platform activity vs. standard OTC market making activity. This is a new disclosure requirement with interpretive questions still being resolved by the SEC.
| Field | Description | New in 2026? |
|---|---|---|
| Security identifier | Ticker and CUSIP | No |
| Order type | Market, limit, IOC, stop | Expanded |
| Order size category | By notional value and share count | Changed |
| Number of covered orders | Count of orders received | No |
| Shares covered | Total shares in covered orders | No |
| Shares executed at quote | Filled at NBBO | No |
| Shares executed with price improvement | Better than NBBO | No |
| Shares executed outside quote | Worse than NBBO | No |
| Average effective spread | Actual cost of execution | No |
| Average realized spread | Market impact measure | No |
| Average speed of execution | Time to fill in seconds | No |
| Extended hours orders | Pre/post market | NEW |
| Stop price orders | Market and limit with stops | NEW |
| Summary report | Top-line aggregated view | NEW |
| Section | Content |
|---|---|
| S&P 500 stocks | Venues receiving routed orders, % of shares, payment for order flow received |
| Non-S&P 500 stocks | Same as above for smaller cap stocks |
| Listed options | Venues for options orders, financial relationships |
| Per-request disclosure | Specific order routing on customer request |
| Financial relationships | Any payment for order flow, revenue sharing, profit sharing arrangements with venues |
There is no central SEC repository for Rule 605 and 606 reports — each firm publishes on their own website. The Rule 605 NMS Plan requires each reporting entity to designate a Designated Participant (an SRO) which maintains a Link Site with hyperlinks to all reports.
| Firm | Rule 605 | Rule 606 |
|---|---|---|
| Virtu Americas | virtu.com/transparency | virtu.com/transparency |
| Citadel Securities | citadelsecurities.com | citadelsecurities.com |
| Jane Street | janestreet.com | janestreet.com |
| NYSE (as market center) | nyse.com/market-data | nyse.com/market-data |
| Nasdaq (as market center) | nasdaq.com/solutions | nasdaq.com/solutions |
| Cboe (as market center) | cboe.com/us/equities | cboe.com/us/equities |
| Fidelity | clearingcustody.fidelity.com | clearingcustody.fidelity.com |
| Schwab | schwab.com/legal | schwab.com/legal |
As of August 1, 2026 large retail brokers will begin filing Rule 605 reports for the first time. Check each firm's legal or compliance section.
Rule 605 execution quality metrics depend on SIP data — the NBBO from the CTA SIP (Tape A/B) and UTP SIP (Tape C) is the benchmark for measuring price improvement. Firms calculating Rule 605 statistics must have reliable, timestamped SIP data. Competing consolidators now also provide NBBO — firms must decide which NBBO source to use for compliance calculations.
Rule 605 execution speed calculations require microsecond-precision timestamps. Order receipt time and execution time must be recorded to microsecond granularity. Firms without proper timestamp infrastructure will struggle with compliance. This creates demand for time synchronization services and low-latency order management systems with proper clock discipline.
Rule 605 requires symbol-by-symbol monthly reports. A large broker-dealer routing orders in thousands of NMS stocks across multiple order types and size categories can generate hundreds of thousands of data records per month. Firms need robust data pipelines to aggregate, calculate, and publish this data in the required electronic format by the monthly deadline.
The expansion of Rule 605 to large broker-dealers creates demand for third-party Rule 605 calculation and reporting vendors. Firms without the infrastructure to calculate execution quality statistics in-house will outsource to vendors like FINRA's TRACE reporting infrastructure or specialized compliance vendors. This is a significant market data infrastructure business opportunity.