Annual CAT Clock Synchronization Certification Reminder
Summary
Cboe Exchanges issued Regulatory Circular 26-002 reminding Industry Members of the annual Business Clock Synchronization Certification deadline of March 16, 2026 (extended from March 15, which falls on a Sunday). Under the Exchanges' Consolidated Audit Trail (CAT) Compliance Rules, affected members must maintain certification records internally and make them available to regulators upon request. Members belonging to multiple exchanges or FINRA need only complete a single certification.
What changed
Cboe Exchanges issued a regulatory reminder that Industry Members subject to CAT Compliance Rules must complete their annual Business Clock Synchronization Certification by March 16, 2026. The standard deadline of March 15 is extended because it falls on a Sunday. Industry Members are not required to submit certifications to the Exchanges; instead, originals must be retained as part of books and records and produced for regulators upon request. Members of multiple exchanges or FINRA satisfy the requirement with a single certification.
Trading permit holders and broker-dealers operating on Cboe-affiliated options and equities markets should ensure their clock synchronization processes and certification documentation are current and retrievable. Compliance teams should verify their CAT clock synchronization procedures align with CAT Alert 2020-02 standards and Section R of the CAT FAQs. Internal records should be organized and accessible for regulatory review.
What to do next
- Complete annual Business Clock Synchronization Certification by March 16, 2026
- Retain clock synchronization certification records internally as part of books and records
- Make certification records available to regulators upon request
Archived snapshot
Apr 16, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
Regulatory Circular 26-002 Date: January 27, 2026 Exchanges: Cboe Options, C2 Options, BYX, BZX, EDGA and EDGX Markets: Equities and Options To: Trading Permit Holders and Members Re: Annual CAT Clock Synchronization Certification Reminder - Complete Form by March 16th As previously communicated, under the Exchanges' Consolidated Audit Trail ("CAT") Compliance Rules, Industry Members must complete an annual certification for Business Clock Synchronization by March 15th of each year. Please note that because March 15, 2026 falls on a Sunday, the due date is Monday,
March 16th.
Please note that Industry Members are not required to submit their certifications to the Cboe-affiliated Exchanges. Instead, originals of certifications must be maintained by Industry Members as part of their books and records and be available to regulators upon request. Industry Members who are members of multiple exchanges and/or FINRA need only make a single clock synchronization certification. Additional Information For the current version of the clock synchronization certification form and more information on clock synchronization, see the Clock Synchronization page of the CAT website and Section R of the FAQs. Also see CAT Alert 2020-02, available here, which provides information regarding the current clock synchronization standards and the standards for self-reporting of deviations. Please contact the FINRA CAT Helpdesk at help@finracat.com or 888.696.3348 with any questions related to this content. In addition, refer to Cboe Options/C2 Options Rule 7.21 and BYX/BZX/EDGA/EDGX Rule 4.6. For any other 1 questions, please contact Cboe Regulatory Interpretations at RegInterps@cboe.com or 312.786.8141.
Rule 7.21 of the Cboe Options Rulebook is incorporated by reference into Chapter 7, Section B of the C2 Options 1 Rulebook.
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