To clarify the reporting requirements and transitional arrangements for program trading at the Shanghai Futures Exchange (“Exchange”), strengthen the oversight of program trading, regulate program trading activities, and maintain an orderly and fair futures market, the following notice is hereby given in accordance with the Program Trading Rules of the Shanghai Futures Exchange (“Program Trading Rules”).

I.     Reporting of Program Trading

(I)   Who Needs to File a Report

A trader at the Exchange is required to file a report if the trader meets one or more of the following criteria:

1. Placing and canceling 10 or more orders within 1 second for 10 or more times on any particular trading day. For the purpose of this rule, accounts linked by actual control relationship are treated as a single client account;

2. All the critical elements of a trading order such as contract code, buy/sell direction, order size, and order price as well as the timing of such order are automatically determined by a computer program;

3. Using a self-developed or customized program trading software; or

4. Falling under other circumstances deemed reportable by the Exchange.

(II)  What Information to Report

1. Basic account information, including trader’s name, trading code, manager of the relevant investment product, and the trader’s carrying Futures Firm Member (“FF Member”), Overseas Special Brokerage Participant (OSBP), and Overseas Intermediary;

2. Information about trading and the trading software, including the method of order execution and the name, basic features, and developer of the trading software; and

3. Other information required by the Exchange.

A program trader must file an update report within 30 trading days after any major change to the previously reported information.

Every program trader should ensure the reported information is true, accurate, and complete. The relevant FF Member, OSBP, and Overseas Intermediary must review the reported account, trading, and trading software information, among others. If it is correct, the FF Member and OSBP should submit the report to the Exchange within five trading days, and the Overseas Intermediary should also do so within five trading days through the relevant FF Member and OSBP.

Additionally, FF Members, OSBPs, and Overseas Intermediaries should review the information reported by a program trading client every six months or as required by the Exchange. They should supervise a client to take corrective actions in a timely manner if the client fails to file a report as required and, for any client that refuses to make such corrections, refuse to open new positions for the client as prescribed in their program trading service agreement.

(III) How to File a Report

Each program trading client should file reports in accordance with the requirements of the Program Trading Rules. FF Members, OSBPs, and Overseas Intermediaries should report clients’ program trading information to the Exchange through CFMMC’s program trading filing system in accordance with the Notice on the Launch of China Futures Market Monitoring Center’s Program Trading Reporting System.

Non-FF Members and Overseas Special Non-Brokerage Participants should report the relevant information to the Exchange through the Exchange’s member service system before engaging in program trading.

The reporting requirements for high-frequency traders will be separately announced by the Exchange.

II.    Transitional Arrangements

The following arrangements will apply to FF Members, OSBPs, Overseas Intermediaries, and traders that already engage in program trading before October 9, 2025.

1. Before April 8, 2026, each such FF Member must enter into a program trading service agreement with each client to set out their rights and obligations and the requirements in relation to reporting and risk management. This applies similarly to any OSBP and Overseas Intermediary that accepts program trading orders from a client.

2. Traders must report program trading information in a truthful, accurate, and complete manner through the designated channels. Starting from April 9, 2026, traders who fail to report program trading through the designated channels will not be allowed to engage in program trading.

3. For high-frequency traders and clients frequently involved in erroneous orders or other abnormal trading behaviors, the Exchange may require the relevant FF Members and OSBPs to test the IT systems they use for program trading. FF Members and OSBPs may conduct these tests themselves or through a third-party testing agency.

III.  Supervisory Requirements

For any program trader that violates applicable rules, the Exchange will order the trader to make corrections and may take additional measures such as sending an alert, requiring the submission of an explanation, arranging a meeting, or restricting the opening of positions. For any FF Member, OSBP, or Overseas Intermediary that violates applicable rules, the Exchange will order it to make corrections and may take additional measures such as sending an alert, arranging a meeting, issuing a warning letter, or issuing an opinion letter. Severe violations will be handled in accordance with the Enforcement Rules of the Shanghai Futures Exchange. 

Annexes:

1.  Reporting Form for Futures Market Program Trading Clients

2.  Instructions for the Reporting Form for Futures Market Program Trading Clients

Shanghai Futures Exchange

August 8, 2025