CFTC Sunsets Routine Large Trader Reporting for Physical Commodity Swaps
Swap dealers, clearing members, and clearing organizations dealing in physical commodity swaps must adjust compliance workflows to reflect the CFTC’s elimination of routine daily and event-based Part 20 large trader position reports, removing a longstanding regulatory filing burden.
On July 17, 2026, the CFTC issued a final order fully repealing routine position-reporting requirements under Part 20, the large trader reporting rules applicable to physical commodity swaps. The order applies to all covered market participants including swap dealers, clearing members, and derivatives clearing organizations, which will no longer be required to submit daily position reports or event-based filings for covered physical commodity swap positions effective immediately. Affected entities should review existing reporting infrastructure and compliance policies to remove redundant Part 20 filing steps, confirm no overlapping reporting obligations apply to affected positions, and update internal recordkeeping practices to align with the revised requirements. The update also notes additional recent regulatory actions including a CFTC stay of a KalshiEX emergency rule change, amended uncleared swap margin rules, and new EU derivatives market transparency and crypto supervisory initiatives from ESMA.