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Pillar guide · Regulation

Securities Finance Regulation Across Global Markets

There is no single global rulebook. Each jurisdiction sets its own short selling, reporting, clearing and tax rules, and these change often. This guide sets out the main themes and links to official sources for each market.

Last reviewed 27 October 2026

Short selling regimes

Short selling frameworks in the Americas, Europe, Asia-Pacific, the Middle East and Africa differ on eligible securities, price tests, flagging requirements and penalties. Some emerging markets restrict short selling heavily or prohibit it for foreign investors. Regulators have also used temporary bans during periods of stress.

Position and transaction reporting

  • Short position reporting to the regulator above a threshold, with public disclosure in some markets.
  • Flagging of short sale orders to the exchange.
  • European Union: assess securities financing transaction reporting under SFTR and relevant short selling requirements.
  • United Kingdom: check FCA requirements and the UK versions of applicable reporting frameworks.
  • United States and Canada: review securities borrowing, short sale and settlement requirements with the relevant regulators.
  • Latin America, Middle East and Africa: confirm local exchange reporting, investor access and securities eligibility.
  • Aggregated publication of short interest by exchanges or regulators.

Clearing and margin rules

Clearing obligations depend on product, counterparty and jurisdiction. US Treasury clearing requirements, European market infrastructure rules and local Asian clearing arrangements should be assessed separately. Derivatives margin obligations can also affect collateral availability for lending and repo. Always check current scope and implementation dates.

Tax frameworks

Stamp duty, withholding tax on manufactured payments and treaty eligibility shape how and whether lending is economic. Hong Kong offers stamp duty relief for qualifying stock borrowing; Australia's franking regime affects dividend-period lending. Firms should take specialist tax advice.

Market guides