The Financial Data Transparency Act joint data standards final rule was published in the Federal Register on June 25, 2026, as FR Doc. 2026-12787, Release No. 33-11420. The effective date is October 1, 2026. Nine agencies signed it: the OCC, Federal Reserve Board, FDIC, NCUA, CFPB, FHFA, CFTC, SEC, and Department of the Treasury.
The first thing to understand is what the rule does not do. It does not change any current reporting requirement. The rule is explicit on this: at the effective date, the joint rule will not change any reporting requirements without further action by the agencies. What it does is establish a set of common identifiers and principles-based data format standards that the SEC and the other implementing agencies will incorporate into specific reporting requirements through subsequent agency-specific rulemakings, which is Phase 2.
For public companies, SEC filers, financial institutions, and municipal issuers, the practical questions are not about the joint rule itself. They are about what comes next: which specific reporting requirements will change, when the SEC will propose its agency-specific rules, and what the compliance implications are for existing systems and processes.
This post covers what the joint rule actually establishes, why each element was chosen, what the rule did not adopt (and why), what the two-phase structure means for compliance planning, and when the agency-specific rules affecting public company and financial institution reporting are expected.
What Is the FDTA and Why Did Congress Pass It?
The Financial Data Transparency Act of 2022 was enacted on December 23, 2022, as Title LVIII of the National Defense Authorization Act for Fiscal Year 2023 (Public Law 117-263). Congress passed it with strong bipartisan support.
The problem it is designed to solve is fragmentation. Federal financial regulators collect broadly similar data from many of the same entities, but in different formats, with different identifiers, and using different definitions. A bank holding company reports financial data to the Federal Reserve in one format, to the FDIC in another, and to the SEC in a third. When regulators need to aggregate exposure data across the system, as they needed urgently during the 2008 financial crisis, the inconsistency of identifiers and formats makes the aggregation slow, expensive, and error-prone.
The FDTA's mandate is to move financial reporting from static, document-based formats toward structured, standardised, open data formats without imposing new substantive disclosure requirements. The law makes clear that the agencies are standardising the format and structure of information already required, not requiring new information.
The FDTA covers nine federal financial regulators as covered agencies: the OCC, Federal Reserve Board, FDIC, NCUA, CFPB, FHFA, SEC, and Department of the Treasury (all named in the statute), plus the CFTC, which the Secretary of the Treasury designated as a covered agency on May 3, 2024, pursuant to authority granted by the statute. The CFTC designation brings the derivatives markets under the FDTA framework.
The joint rule is Phase 1 of a two-phase implementation. The joint rule establishes the common standards. Phase 2 is the set of agency-specific rulemakings in which each implementing agency (OCC, Federal Reserve, FDIC, NCUA, CFPB, FHFA, and SEC) incorporates those standards into the specific reporting requirements under its own jurisdiction.
What Does the FDTA Joint Data Standards Final Rule Actually Establish?
The joint rule establishes three things. Each is worth understanding precisely, because commentary on the rule has sometimes conflated what was established with what comes later.
First: Seven common identifiers.
The rule establishes seven common identifiers that the agencies will use across their respective reporting systems in Phase 2. Each identifier is required by the FDTA to be common (the same across agencies), nonproprietary (not owned by a private vendor), and available under an open licence.
The seven identifiers established in the final rule are:
ISO 17442, the Legal Entity Identifier (LEI): a 20-character alphanumeric code that uniquely identifies legal entities participating in financial transactions. The LEI was developed in the aftermath of the 2008 financial crisis specifically because regulators discovered they could not quickly aggregate counterparty exposure data across failing institutions. The LEI is maintained by the Global Legal Entity Identifier Foundation (GLEIF) under a non-proprietary, open-licence framework and is free to use.
ISO 4914, the Unique Product Identifier (UPI): for the identification of swaps and security-based swaps.
ISO 10962, the Classification of Financial Instruments (CFI): for the classification of financial instruments other than swaps.
ISO 8601: for dates and times.
U.S. Postal Service abbreviations for states, possessions, and military states.
GENC (Geopolitical Entities, Names, and Codes): for countries and subdivisions.
ISO 4217: for currencies.
Second: A principles-based standard for data transmission schema and taxonomy formats.
Rather than naming a specific structured data format such as XBRL, JSON, or XML, the final rule establishes four properties that the data transmission schema and taxonomy format should have, to the extent practicable. These properties, derived from the FDTA's requirements, are that the format be machine-readable, non-proprietary, available under an open licence, and based on open standards. The choice between specific formats (XBRL or JSON-LD or another open format) is left to the agency-specific rulemakings in Phase 2.
This principles-based approach was a deliberate change from the proposed rule. The agencies concluded that specifying a particular schema and taxonomy format at the joint rule stage would be premature, given the range of reporting systems across nine agencies and the different technical architectures of their existing collections of information.
Third: A definition of "collections of information."
The rule defines the term "collections of information" by reference to the Paperwork Reduction Act of 1995, which governs the federal government's information collection activities. This definition determines the scope of reporting requirements to which the joint standards will eventually apply through Phase 2 agency-specific rulemakings.
What Did the Final Rule Not Adopt and Why?
Two proposals from the August 2024 Notice of Proposed Rulemaking were not included in the final rule. Understanding what was dropped and why matters for Phase 2 planning.
The Financial Instruments Global Identifier (FIGI) was not adopted as a common securities identifier.
The proposed joint rule had recommended FIGI as the common financial instrument or securities identifier for FDTA compliance purposes. The final rule did not adopt this recommendation. The agencies cited concerns raised by issuers and market participants about FIGI's interoperability with CUSIP, which is the existing, widely-used securities identifier in US markets. CUSIP is proprietary and not available under an open licence, which means it cannot satisfy the FDTA's nonproprietary, open-licence requirements on its own. However, replacing CUSIP with FIGI would impose transition costs and market disruption that the agencies concluded were not justified at this stage.
The final rule instead provides the covered agencies with flexibility to consider whether to utilise FIGI or any other securities identifier standards in Phase 2. This means the SEC will decide in its own agency-specific rulemaking whether to mandate a particular securities identifier, if any at all. For SEC filers, this means the securities identifier question remains open and is a key area to monitor in the SEC's Phase 2 proposal, which is expected in mid to late 2026.
The Basic format option for ISO 8601 was not specified.
The proposed rule had specified the Basic format (no hyphens) for ISO 8601 date representations. The final rule does not specify the Basic format option, leaving agencies flexibility in how they implement the ISO 8601 date standard in their specific collections of information.
The joint rule does not mandate that agencies adopt the LEI.
While the joint rule establishes the LEI as the common nonproprietary legal entity identifier that satisfies the FDTA's requirements, it does not mandate that the agencies adopt LEIs in their specific reporting systems. The mandate to adopt the LEI standard, and the scope of entities required to obtain or maintain LEIs, will be determined in Phase 2 through agency-specific rulemakings. For municipal issuers specifically, applying LEIs comprehensively could result in significant costs and market consequences, which the Government Finance Officers Association has flagged as a concern requiring careful cost-benefit analysis in the SEC's specific rulemaking.
What Is the Two-Phase Structure and What Happens in Phase 2?
The FDTA's implementation has an explicit two-phase structure that the joint rule preserves and describes.
Phase 1 is the joint rule. The nine agencies jointly establish the common identifiers and principles-based data format standards that will apply across all covered regulatory reporting. The joint rule does not change any reporting requirement. It establishes the framework that the Phase 2 rules will use. The effective date of the joint rule is October 1, 2026.
Phase 2 is the set of agency-specific rulemakings. Each implementing agency, which for SEC reporting purposes is the SEC itself, will separately propose and finalise rules that incorporate the joint standards into the specific collections of information under its jurisdiction. The agency-specific rulemakings will be subject to their own public comment processes. The public will have an opportunity to comment on the specific uses of the joint standards, including the associated benefits, costs, and implementation timelines, during Phase 2.
For the SEC specifically, Phase 2 has two distinct streams.
The first stream is SEC reporting by registered companies: the 10-K, 10-Q, 8-K, proxy statements, registration statements, and other collections of information that public companies file with the SEC under the Securities Act and the Exchange Act. The SEC's agency-specific rulemaking for these collections will determine which of the seven identifiers must be incorporated, which data format requirements apply, and what the compliance timeline is.
The second stream is municipal securities disclosure on EMMA (the Electronic Municipal Market Access system operated by the MSRB). The FDTA specifically directs the SEC to establish data standards for financial information submitted to EMMA by municipal issuers and other market participants. The Chapman and Cutler analysis of the FDTA noted that the SEC is expected to publish its proposed data standards for this stream in mid to late 2026, with a compliance date in early 2027.
The FDTA requires that the data standards established by the implementing agencies take effect not more than two years after promulgation of the final joint rule. With the joint rule published June 25, 2026, this means agency-specific standards must take effect by approximately June 2028 at the latest.
What Does the FDTA Final Rule Mean for Public Company SEC Filers?
For public companies that file periodic and current reports with the SEC, the immediate answer is that the joint rule itself changes nothing today. No 10-K, 10-Q, or other SEC filing has new requirements as a result of the joint rule's October 1, 2026 effective date. Changes to specific SEC filing requirements will come only through the SEC's Phase 2 agency-specific rulemaking, which has not yet been proposed.
The planning implication is nonetheless real. Companies that currently have XBRL tagging programmes, data governance structures, and system architectures built around their SEC reporting workflows need to understand that the FDTA creates a trajectory toward more structured, machine-readable financial reporting. The specific format requirements will be determined in Phase 2, but the direction is clear.
Three specific areas deserve compliance team attention now.
Legal Entity Identifier status. If the SEC's Phase 2 rulemaking requires LEI adoption for certain filings or certain entity types, companies that do not currently have an LEI will need to obtain one through a Local Operating Unit in the GLEIF network. The LEI is free to use and the ISO 17442 standard is open-licensed, but the issuance process requires registration and annual renewal. Companies subject to CFTC derivatives reporting or EU regulatory reporting under EMIR may already have an LEI. Companies that do not should confirm their status now rather than discovering a gap when the SEC's Phase 2 proposal drops.
Securities identifier systems. The joint rule left the securities identifier question open, with FIGI and CUSIP interoperability to be resolved in Phase 2. Companies should monitor the SEC's Phase 2 proposal for its position on securities identifiers, because any change from CUSIP to an alternative identifier affects EDGAR XBRL tagging, investor relations data feeds, and downstream analytics platforms that rely on CUSIP-based security identification.
Data format readiness assessment. The joint rule establishes principles for data transmission schema and taxonomy formats (machine-readable, non-proprietary, open-licensed, based on open standards) but does not specify whether XBRL, JSON-LD, or another format is required. The SEC's existing Inline XBRL requirements for periodic filings are already machine-readable, non-proprietary, and open-standard, which means the SEC's current tagging requirements are broadly consistent with the FDTA's principles. The extent to which the SEC's Phase 2 rulemaking requires additional changes to XBRL tagging practices or introduces new format requirements is the open question. Monitoring the Phase 2 proposal is the specific action.
What Does the FDTA Mean for Municipal Issuers Filing on EMMA?
Municipal issuers, including state and local governments and conduit borrowers, face a more direct and near-term compliance question than public companies because the FDTA specifically directs the SEC to establish data standards for EMMA submissions.
Currently, municipal financial disclosure on EMMA (annual financial reports, official statements, and continuing disclosure notices) is filed in PDF or HTML format without structured data requirements. The FDTA's mandate is to move these submissions toward machine-readable, structured formats using the common identifiers and data format standards established in the joint rule.
The SEC's Phase 2 rulemaking for EMMA is expected in mid to late 2026. The compliance date for the SEC's EMMA rule is expected to be in early 2027, according to the Chapman and Cutler analysis. The scale of the effort and cost required for municipal issuers to comply with the SEC's EMMA rule is not currently known, but it will require analysing the new rule, creating new compliance policies and procedures, and potentially updating or replacing the systems used to prepare and submit EMMA filings.
The Government Finance Officers Association has been actively engaged with regulators since 2022 to ensure that implementation is practical, cost-effective, and respects the unique nature of public sector reporting. GFOA has specifically flagged concerns about the cost of applying LEIs comprehensively to a wide variety of municipal issuers, given that many smaller municipal issuers have no current need for an LEI and may face non-trivial costs in obtaining and maintaining one.
Municipal issuers should monitor the SEC's Phase 2 EMMA proposal closely. The comment period for that proposal will be the opportunity to raise concerns about compliance costs, timing, and the practical feasibility of moving from document-based to structured-data EMMA submissions.
Frequently Asked Questions
What is the FDTA Joint Data Standards final rule and when is it effective?
The Financial Data Transparency Act Joint Data Standards final rule (FR Doc. 2026-12787, Release No. 33-11420) was published in the Federal Register on June 25, 2026, with an effective date of October 1, 2026. It was jointly issued by nine agencies: the OCC, Federal Reserve Board, FDIC, NCUA, CFPB, FHFA, CFTC, SEC, and Department of the Treasury. The rule establishes seven common identifiers and a principles-based standard for data transmission schema and taxonomy formats. It does not change any current reporting requirement.
Does the FDTA final rule change what my company files with the SEC today?
No. The joint rule explicitly states that at the effective date, it will not change any reporting requirements without further action by the agencies. Changes to specific SEC filing requirements will come only through the SEC's Phase 2 agency-specific rulemaking, which has not yet been proposed as of June 2026.
What is the Legal Entity Identifier and does my company need one?
The Legal Entity Identifier (ISO 17442) is a 20-character alphanumeric code that uniquely identifies legal entities in financial transactions. The joint rule establishes the LEI as the common legal entity identifier for FDTA purposes, but does not mandate that agencies require LEIs in their specific reporting systems. The LEI mandate will be determined in Phase 2 through agency-specific rulemakings. Companies subject to CFTC or EU derivatives reporting likely already have an LEI. Companies without an LEI should assess whether the SEC's Phase 2 proposal will require one.
Why was FIGI not adopted as the common securities identifier?
The agencies cited concerns raised by commenters about FIGI's interoperability with CUSIP, the existing, widely-used securities identifier in US markets. Because CUSIP is proprietary and cannot satisfy the FDTA's open-licence requirements on its own, the agencies concluded that the securities identifier question should be resolved in Phase 2, with agencies having flexibility to consider FIGI or other options based on industry feedback.
When will the SEC issue its Phase 2 agency-specific FDTA rulemaking?
The SEC's Phase 2 proposals are expected in mid to late 2026 for both public company SEC filings and municipal securities disclosure on EMMA. The statutory requirement is that agency-specific standards take effect not more than two years after the joint rule is finalised, which means a deadline of approximately June 2028.
What should compliance teams do now to prepare for FDTA Phase 2?
Three actions are worth taking now. First, confirm whether the company currently has a Legal Entity Identifier and, if not, assess whether it is likely to be required in Phase 2. Second, monitor the SEC's Phase 2 proposal for its position on securities identifiers, because any change from CUSIP affects EDGAR XBRL tagging and downstream data systems. Third, assess the company's current XBRL and data format infrastructure against the FDTA's four principles (machine-readable, non-proprietary, open-licensed, open-standards-based) to identify any gaps before the Phase 2 proposal defines specific requirements.
Key Takeaways
- The FDTA Joint Data Standards final rule (FR Doc. 2026-12787) was published June 25, 2026, effective October 1, 2026. It was jointly issued by nine agencies including the SEC. It does not change any current reporting requirement.
- The joint rule establishes seven common identifiers: the LEI (ISO 17442), UPI (ISO 4914), CFI (ISO 10962), ISO 8601 for dates, USPS abbreviations for states, GENC for geopolitical entities, and ISO 4217 for currencies.
- The joint rule establishes four principles for data transmission schema and taxonomy formats (machine-readable, non-proprietary, open-licensed, open-standards-based) but does not mandate a specific format such as XBRL or JSON. That decision is left to Phase 2.
- FIGI was not adopted as the common securities identifier due to CUSIP interoperability concerns. The SEC will determine in its Phase 2 rulemaking whether to mandate a securities identifier.
- The joint rule establishes Phase 1 of a two-phase structure. Phase 2 consists of agency-specific rulemakings in which each implementing agency, including the SEC, incorporates the joint standards into specific reporting requirements. The SEC's Phase 2 proposals are expected in mid to late 2026.
- Agency-specific standards must take effect not more than two years after the joint rule is finalised, implying a deadline of approximately June 2028 for Phase 2 compliance.
- Municipal issuers face a near-term compliance question: the SEC's Phase 2 rulemaking for EMMA is expected in mid to late 2026, with a compliance date in early 2027. The cost and systems implications of moving EMMA submissions to structured data formats are not yet known.
