Recent surveys from DTCC and SIFMA, BNY, Broadridge, and The ValueExchange indicate substantial progress in the financial industry's readiness for mandatory central clearing of U.S. Treasury transactions. For the December 31, 2026, cash clearing deadline, most respondents reported being prepared or in final readiness stages. DTCC noted that over $1.2 trillion in Treasury cash activity is already centrally cleared at FICC, with an estimated $300-$400 billion remaining to be migrated. Nearly 80% of respondents already have necessary account setups with FICC, and almost all firms requiring an FICC account have either established one or are in the onboarding pipeline. Approximately one-third of dealers anticipate offering clearing services for clients' Treasury cash activity.
The broader "U.S. Treasury Central Clearing Pulse Survey" involving 340 experts worldwide reinforced this positive outlook for cash clearing, with 86% of respondents expressing at least some confidence in meeting the overall mandate, and 44% being "very confident." However, the survey highlighted that considerable work remains for the June 30, 2027, repo clearing deadline. While 87% of buy-side and 84% of sell-side firms are in execution mode for repo trades, delays are being caused by legal/contract negotiation (88% of delayed programs, with 44% calling it "very challenging") and technology integration issues (67% of respondents). Concerns also exist regarding ongoing costs, with 50% expecting them to rise, and margin costs projected to increase by an average of 37%. Many firms (57%) have not yet quantified these ongoing cost impacts.
Despite the challenges, the industry is seeing significant growth in central clearing. FICC currently clears over $12 trillion in average daily transactions across all its cash and repo clearing activities, marking a 165% increase since the SEC first proposed the Treasury clearing mandate. Volume in FICC's Sponsored Service has surged by 771% since the SEC's September 2022 proposal, now supporting over 2,850 Sponsored Members and processing more than $2.5 trillion in average daily volume. The SEC's December 2023 rule changes aim to enhance investor protection, reduce risk, and improve operational efficiency by mandating central clearing for specific secondary market transactions in U.S. Treasury securities.
Looking ahead, critical issues still need resolution, including exemptions for inter-affiliates and extraterritorial issues for non-U.S. participants, although the SEC is actively engaged with the industry on these. Cash activity subject to clearing has grown, with average daily ATS + interdealer volume reaching approximately $550 billion in 2025, a 20% increase from 2024. For repo, the Office of Financial Research (OFR) estimated that 45% of average daily Treasury repo volume was already centrally cleared in the first 8 months of 2025, and under the mandate, 77% of volumes would require clearing. Industry experts emphasize the need for disciplined execution, prioritizing technology readiness, operational resiliency, and clear fallback plans to ensure a smooth transition, especially as up to 59% of project activity is expected to complete after the cash deadline, and 51% of firms lack formal contingency plans for missed readiness.
