Global markets are evolving rapidly, and the push towards extended and continuous trading is gaining momentum. Investor demand and technological innovation are driving the expansion of trading hours, with exchanges and brokerages already extending their sessions and some securities information processors (SIPs) considering near-continuous operating hours.
While continuous trading offers benefits such as increased access to products and greater responsiveness to market developments, it also introduces significant considerations for market liquidity, operational complexity and investor protections. As the sole central counterparty (CCP) clearinghouse for U.S. listed options, and as a Systemically Important Financial Market Utility (SIFMU), we at OCC are committed to ensuring that clearing and settlement processes evolve securely and efficiently alongside this market evolution.
Recent developments
OCC is closely observing directional trends towards continuous trading in the equities market at both the CCP and industry-wide level, particularly from our participant exchanges. These observations will help inform the risk management and operational adjustments that may be required for continuous trading in derivatives such as listed options.
In December, Nasdaq filed a rule change proposal with the SEC to extend trading hours for equity securities and exchange-traded products (ETPs) to 23-5 (that is, 23 hours per day for five days a week). Nasdaq is the third national exchange to request extended trading hours for U.S. equities; earlier last year, the SEC approved proposals from 24 Exchange to enable 23-5 trading and from NYSE Arca to enable 22-5 trading.
From a clearinghouse perspective, DTCC announced in March 2025 that its National Securities Clearing Corporation (NSCC) plans to increase clearing hours to support 24-5 trading in Q2 2026, subject to regulatory review and approval of any necessary rule changes.
On the options side, Cboe has submitted a rule change proposal with the SEC to extend options trading hours, beginning each trading day at 6:30 a.m. ET instead of 8:30 a.m. ET. This extension would apply to a limited set of symbols that see consistent trading volume throughout the day. Cboe has also requested extending trading hours in the afternoon from 4 p.m. ET to 4:15 p.m. ET.
Key considerations
OCC is advocating for a gradual transition to a near-continuous model such as 22-5 trading and clearing, leaving a window for trade reconciliation and end-of-day processing, and maintaining weekends for system maintenance, backups and data deployments. Moving to a 22-5 or 23-5 model would enable clearing members and regulators to refine workflows, validate operational readiness and implement new risk protocols before moving to a fully continuous trading and clearing environment.
This transition would require the industry to examine key concepts and systems that underpin today’s markets, notably:
Payment and settlement
Today’s margin and settlement cycles are tied to traditional business hours, creating constraints during overnight trading and banking holidays. Custodial and settlement banks, as well as services such as Fedwire and the National Settlement Service (NSS), would need to observe longer operating hours. OCC supports the Federal Reserve’s recently announced plans to expand Fedwire and NSS operating hours to 22 hours and 21.5 hours per day, respectively, six days per week (22-6), including weekday holidays, by 2028 or 2029, with a path towards near-continuous and continuous trading and clearing environments. This expansion will support real-time margining and could reduce reliance on pre-funding.
Mobility of collateral
Distributed ledger technology (DLT) and tokenised assets could transform collateral mobility. These tools enable near-instant transfers and delivery versus payment outside traditional banking hours. Tokenisation could reduce pre-funding needs and support real-time margin obligations, once eligibility criteria and regulatory frameworks are established. The guardrails established by the GENIUS Act in 2025 are an important first step towards achieving such frameworks.
Operational readiness and resilience
Market participants will need to modify operational playbooks to support trade capture, confirmation, risk monitoring and settlement during extended hours. OCC is evaluating global “follow-the-sun” staffing models and event-driven workflows to replace batch processes, enhancing resilience and responsiveness.
Liquidity and market depth
Extended trading hours can have a significant impact on trading liquidity and margin requirements. Market makers may also scale back quoting activity during overnight sessions, affecting price discovery. OCC’s stress testing and margin models are being evaluated with these dynamics in mind.
OCC has offered Extended Trading Hours (ETH) for select products since 2015, enabling us to observe trading patterns and liquidity dynamics overnight. Volume from extended hours trading consistently accounts for less than 1% of our daily cleared contract volume, demonstrating the need for careful consideration around which products are made available and who is eligible to trade them overnight.
Parameters and lifecycle events
Parameters based on available market data that OCC uses to calculate margin requirements and regularly assess whether its financial resources are sufficient may need to be adapted. The industry would also need to define a trading day and delineate between ‘traditional’ hours and ‘extended’ sessions. We are currently evaluating OCC’s rules within this context.
Investor protections
Regulators may consider changes to mandated risk flags and market surveillance coverage, as well as guidance on best execution and suitability rules. Venues will need to ensure transparent order handling and pricing practices across all trading sessions. Ongoing and robust investor education will be critical to address potential risks during low-volume periods and following corporate action events.
Interoperability among financial market infrastructure firms
OCC is evaluating adjustments to existing cross-CCP agreements and exploring potential new agreements to support aligned margin cycles and risk management across financial market infrastructures. We support close coordination with CME Group, NSCC and other CCPs.
Global coordination
Expanded market and regulatory coordination, both domestically and internationally, will be critical to ensuring consistent and enforceable rules. Global alignment will help prevent fragmentation and address cross-border issues.
Looking ahead
The path towards continuous trading in U.S. listed options will require careful coordination across the entire market ecosystem. OCC is committed to ensuring that this transition enhances market access while safeguarding systemic stability. In September of last year, we published a white paper outlining our perspective on how to execute this transition carefully and in a way that protects market participants, and we are now engaging in regular discussions with industry groups, market participants, regulators and vendors to explore how best to address the necessary adjustments.
Continuous trading represents a fundamental shift in market structure, but OCC’s mission remains clear: to ensure confidence in our markets and the broader economy. By working together, the industry can unlock new opportunities while maintaining the integrity of the financial system.