Nasdaq Sets September 26 Production-System Window for Disaster-Recovery Pre-Test

The three-hour Regulation SCI session gives firms a chance to test connectivity and market systems ahead of Nasdaq’s October 24 annual BC/DR exercise.

Ken Stephens
Written by Ken Stephens
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Nasdaq scheduled its production systems to open Saturday, September 26, for a three-hour Regulation SCI business-continuity and disaster-recovery pre-test, giving member firms a chance to check their connections and automated workflows before the exchange group’s annual coordinated exercise in October.

The testing window was set for 9:00 a.m. to 12:00 p.m. Eastern Time. It covered The Nasdaq Stock Market, Nasdaq Texas, Nasdaq PSX, the Nasdaq Options Market, Nasdaq PHLX, Nasdaq Texas Options, Nasdaq ISE, Nasdaq GEMX and Nasdaq MRX. Firms that wanted to take part were required to register with Nasdaq Trading Services by noon ET on Friday.

Nasdaq described the September 26 session in a September 22 trader alert as Regulation SCI BC/DR customer pre-testing. The date is separate from Nasdaq’s regular monthly Saturday general-testing schedule, which listed September 12 as the month’s standard session. Nasdaq’s policy also allows additional product-specific and user-acceptance tests outside those regular dates.

A three-hour production window across Nasdaq markets

The session uses Nasdaq production systems rather than only a weekday test environment. That distinction matters for member firms because a production testing window lets them exercise the interfaces, network paths and operational processes they would rely on when connecting to the exchanges under controlled weekend conditions.

Nasdaq’s Saturday testing policy lists a broad set of systems available during weekend tests. For the Nasdaq equity market, those include OUCH, FIX, FLITE, RASH, QIX, CTC, Nasdaq Workstation and market data. Nasdaq Texas and PSX also support several order-entry protocols during Saturday tests. On the options side, the listed systems span SQF, FIX, OTTO and CTI along with venue-specific market-data products for Nasdaq Texas Options, NOM, PHLX, ISE, GEMX and MRX.

The September 26 notice did not describe the session as a normal Saturday trading day for investors. It was a customer testing opportunity for firms that connect to Nasdaq services. Nasdaq separately maintains its Nasdaq Testing Facility for weekday testing of automated systems, software changes and product enhancements, while scheduled Saturday windows provide access to production environments for specific exercises.

That setup gives brokers, market makers and other exchange participants a chance to find configuration or connectivity problems before a coordinated disaster-recovery event. A firm may be able to reach a test environment successfully yet still want to validate how its production connectivity, order-entry software, market-data handling and internal procedures behave during an exchange-run weekend test.

The September session is a pre-test, not the annual exercise

Nasdaq’s annual Business Continuity and Disaster Recovery Plan test is scheduled for Saturday, October 24. The exchange group announced two pre-Regulation SCI testing opportunities ahead of it: September 26 and October 10. The September session therefore serves as preparation for the annual exercise rather than replacing it.

That distinction is important because Nasdaq requires certain designated members and participants to take part in the annual coordinated functional and performance test. In its April regulatory notice, Nasdaq said it encourages participation from all members, member organizations, PSX participants and options participants, but specified volume-based standards for firms that must participate. The Nasdaq Stock Market and PHLX designate their top 10 qualifying participants by trading volume, while several other Nasdaq markets use top-five thresholds. ISE uses a top-10 standard. Nasdaq said firms meeting the criteria for the 2026 annual test were to be notified by April 27.

The mandatory annual exercise stems from Rule 1004 of Regulation Systems Compliance and Integrity, or Regulation SCI. SEC guidance on Regulation SCI says covered entities must establish standards for designating members or participants needed to help maintain fair and orderly markets if business-continuity or disaster-recovery plans are activated. Those designated participants must take part in scheduled functional and performance testing at least once every 12 months, and the testing must be coordinated on an industry- or sector-wide basis with other SCI entities.

The SEC has also explained that the rule does not require every functional and performance test to occur at one time. SCI entities can use weekend sessions or conduct testing in segments over the course of a year when that approach is appropriate. That flexibility helps explain why exchanges can run preparatory windows before the main annual industry exercise.

Regulation SCI puts exchange resilience under recurring tests

Regulation SCI applies to systems that directly support core securities-market functions such as trading, order routing, market data, market regulation and market surveillance. The SEC requires SCI entities to maintain policies and procedures designed to provide adequate capacity, integrity, resiliency, availability and security. The framework also covers business-continuity and disaster-recovery planning, including backup systems.

Some systems receive heightened treatment because their failure could have an outsized effect on market functioning. SEC guidance identifies critical SCI systems as a subset that includes systems supporting functions such as openings and closings on a primary listing market, trading halts, initial public offerings and consolidated market data. The framework sets a two-hour resumption goal for critical SCI systems following a wide-scale disruption, while broader trading operations are subject to a next-business-day resumption goal.

The next scheduled preparatory date is October 10, followed by Nasdaq’s annual Regulation SCI BC/DR test on October 24. Those dates give firms another opportunity to address issues found during pre-testing before the coordinated annual exercise that designated participants are required to complete.

Ken Stephens

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Ken Stephens

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Ken Stephens leads MarketReview’s editorial work and writes about investing, trading and the forces that shape financial markets. Drawing on decades of market experience, he focuses on testing common explanations against evidence and making complex ideas easier to evaluate.

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