What is Form SHO? SEC short position reporting
Form SHO is the monthly short position report the SEC adopted under Rule 13f-2 on 13 October 2023. Institutional investment managers whose short positions cross set thresholds must file it on EDGAR within 14 calendar days of month end, reporting gross short positions and daily activity that changed them. The SEC then publishes data aggregated across managers for each security. Almost nothing written about Form SHO since 2024 carries the right date, because the compliance deadline has moved twice: the first filings are now due 14 February 2028. This guide explains what Form SHO is, who files it, and where the rule actually stands. It is not investment advice.
Definition
Form SHO
is the monthly report filed on EDGAR by institutional investment managers whose gross short positions cross the thresholds in SEC Rule 13f-2, disclosing those positions and the daily activity behind them. The SEC publishes aggregated data per security, not per manager. Adopted 13 October 2023. Source: SEC.
Who has to file Form SHO?
Rule 13f-2 applies to institutional investment managers, and it uses two thresholds that turn on whether the issuer is a reporting company:
| Threshold | Applies to | Trigger |
|---|---|---|
| Threshold A | Issuers that are reporting companies | Monthly average gross short position of $10 million or more, or 2.5 percent or more of shares outstanding |
| Threshold B | Issuers that are not reporting companies | Gross short position of $500,000 or more at the close of any settlement date in the month |
Threshold A is measured as a monthly average of the gross short position at the close of each settlement date in the calendar month. Threshold B is measured on any single settlement date, so one day above the line pulls a manager into the report.
Note the size of these figures against the $100 million that triggers a Form 13F. Rule 13f-2 reaches far smaller positions than the long-side regime does, which is one reason it drew the objections it did.
$10 million or 2.5%
Threshold A for Form SHO: a monthly average gross short position at or above either figure in a reporting company issuer triggers the filing; Threshold B for non-reporting issuers is $500,000 on any settlement date
Source: SEC, Rule 13f-2
Why the first Form SHO is not due until 2028
The compliance date has moved twice, and the reason is litigation rather than administrative drift.
In National Association of Private Fund Managers v. SEC, decided 25 August 2025, the Fifth Circuit remanded both Rule 13f-2 and the securities lending rule, Rule 10c-1a, without vacating them. The court held that the SEC's failure to consider the cumulative economic impact of the two rules together was arbitrary and capricious. Remand without vacatur left the rules on the books while requiring the SEC to redo the analysis.
The SEC then issued an order on 3 December 2025, Release No. 34-104303, granting temporary exemptive relief:
| Requirement | New compliance date |
|---|---|
| Rule 13f-2 and Form SHO | First reporting period January 2028; first filings due 14 February 2028 |
| Rule 10c-1a securities lending reporting | 28 September 2028 |
| Public dissemination of securities lending data | 29 March 2029 |
The exemption runs from 2 January 2026 to 2 January 2028. The earlier dates that circulated widely, first filings in February 2025 and then February 2026, are both superseded. Any page still citing them is stale.
What Form SHO will and will not reveal
When filings do begin, the public output is aggregated. Managers file individually, but the SEC publishes figures per security combined across managers. Nobody gets named against a short position.
So the gain is granularity and frequency, not attribution. Compared with the twice-monthly compiled totals in short interest reporting, Form SHO adds monthly position data plus the daily activity that moved it, drawn from managers directly rather than from the broker-dealers carrying the positions. For the full comparison, see Form SHO vs short interest report.
Until February 2028 there is no Form SHO data to read. FINRA's short interest figures remain the only regular public window on the short side, and the long side stays with 13F, Forms 3, 4 and 5 and, in India, the quarterly shareholding pattern. Flock reads disclosure filings and keeps each one dated and linked to its source. What any of it means for your money is your call to make.
Frequently asked questions
What is Form SHO?
Form SHO is the monthly report institutional investment managers must file on EDGAR disclosing gross short positions and daily short activity in equity securities that cross set thresholds. It was adopted under SEC Rule 13f-2 on 13 October 2023. The SEC publishes aggregated data derived from it. Source: SEC.
What are the Form SHO reporting thresholds?
Two. For a reporting company issuer, a monthly average gross short position worth $10 million or more, or 2.5 percent or more of shares outstanding. For a non-reporting company issuer, a gross short position worth $500,000 or more at the close of any settlement date in the month. Source: SEC.
When is the first Form SHO due?
14 February 2028. An SEC order dated 3 December 2025, Release No. 34-104303, granted a temporary exemption running from 2 January 2026 to 2 January 2028, making January 2028 the first Rule 13f-2 reporting period. Earlier dates of February 2025 and February 2026 were both superseded. Source: SEC.
Will Form SHO name which manager is short a stock?
No. Rule 13f-2 requires managers to file individually, but the SEC publishes data aggregated across managers for each security rather than manager-level positions. The gain over existing short interest data is granularity and frequency, not attribution. Source: SEC.
Flock tracks these filings, sourced, dated, and linked back to the original. See what smart-money entities disclosed, without the guesswork about what it means.
Disclosures shown are public regulatory filings. Data may be delayed or incomplete. Smart-money entities may no longer hold positions shown. Not investment advice.