Why the SEC Dismantled the Case Against Payment for Order Flow in 2025

Executive Summary

The U.S. Securities and Exchange Commission (SEC) will not ban the practice of Payment for Order Flow (PFOF) in 2025. The probability of such a prohibition occurring this year is effectively zero. In a decisive policy reversal, the Commission has moved in the diametrically opposite direction, actively dismantling the nascent regulatory framework that would have been required to implement a ban. This outcome represents one of the most significant pivots in U.S. market structure policy in recent years.

The pivotal cause for this reversal is a profound ideological shift at the SEC following the appointment of Paul Atkins as Chairman in early 2025. The new leadership's philosophy, which prioritizes facilitating capital formation and reducing regulatory burdens on market participants, stands in stark contrast to the investor-protection-centric, structural-reform agenda pursued by the previous Chair, Gary Gensler.

The most conclusive evidence of this policy change was the Commission's formal withdrawal on June 12, 2025, of a slate of fourteen rule proposals from the Gensler era [1]. Critically, this action included the rescission of the two cornerstone proposals that directly targeted the PFOF business model: the Order Competition Rule and Regulation Best Execution [2]. This was not an isolated decision but part of a comprehensive rollback of the prior administration's ambitious and often contentious regulatory agenda, signaling a new, less interventionist approach to market oversight.

Looking forward, PFOF will continue to be a legal and prominent feature of the U.S. equity market landscape. Regulation of the practice will revert to the pre-existing framework centered on disclosure requirements under SEC Rules 605 and 606 and the established best execution duty enforced by the Financial Industry Regulatory Authority (FINRA). The Atkins-led SEC evidently views this framework as sufficient to manage the conflicts of interest inherent in PFOF. With this move, the United States has set itself on a divergent path from other major jurisdictions, notably the United Kingdom and the European Union, which have both moved to prohibit the practice.

The Anatomy of Payment for Order Flow: A Contested Practice

To fully appreciate the significance of the SEC's 2025 policy reversal, it is essential to first understand the mechanics of Payment for Order Flow and the deep-seated controversy it has generated for decades. PFOF is not merely a technical market feature; it is the financial engine of the modern retail brokerage industry and sits at the nexus of a fierce debate over market fairness, investor protection, and the definition of "best execution."

The PFOF Mechanism: How "Free" Trading is Funded

At its core, Payment for Order Flow is the compensation that a retail stockbroker receives from a wholesale market maker in exchange for routing its customers' trade orders to that market maker for execution [3]. This practice, often involving payments of mere fractions of a penny per share, is the primary business model that enables the "commission-free" trading offered by prominent brokers such as Robinhood Markets, E-Trade, Charles Schwab, and Webull [3].

The value chain of a PFOF transaction unfolds in a sequence of steps:

1. A retail investor places a trade—for example, an order to buy 100 shares of a company—through their commission-free brokerage app [6].
2. Instead of sending this order directly to a public exchange like the NYSE or Nasdaq, the broker routes the order to a wholesale market maker, such as Citadel Securities, Virtu Financial, or Susquehanna International Group [3]. These firms specialize in executing large volumes of retail orders.
3. The market maker executes the trade. It profits by capturing the "bid-ask spread," which is the small difference between the highest price a buyer is willing to pay for a security (the bid) and the lowest price a seller is willing to accept (the ask) [3]. For example, if a stock's bid is $98.00 and its ask is $100.00, the market maker can buy at or near the bid and sell at or near the ask, capturing a portion of that $2.00 spread [6].
4. The market maker then rebates a portion of its profit from the spread back to the retail broker as PFOF. This payment is the broker's compensation for sending the valuable order flow its way [3].
5. In many cases, the market maker may also provide the investor with "price improvement." This means executing the investor's order at a price slightly better than the nationally displayed best price, known as the National Best Bid and Offer (NBBO) [3]. An order to buy might be filled a fraction of a cent below the best offer, or a sell order a fraction of a cent above the best bid.

The scale of this practice is immense and has grown dramatically. In 2020, total PFOF payments to the seven leading retail brokerages amounted to $2.6 billion [4]. By 2021, that figure had grown to $3.8 billion for the twelve largest U.S. brokerages, highlighting PFOF's central role in the economics of the retail trading boom [8].

The Economic and Ethical Debate: A Dichotomy of Views

The debate over PFOF is characterized by two fundamentally opposing viewpoints, each rooted in a different interpretation of the practice's impact on investors and the market.

Arguments in Favor of PFOF (The Industry View):
Proponents, primarily brokerage firms, market makers, and industry groups like the Securities Industry and Financial Markets Association (SIFMA), argue that PFOF is a beneficial innovation that has democratized finance [3]. Their core arguments include:

• Lowering Investor Costs: The most prominent defense is that PFOF subsidizes and makes possible the zero-commission trading model [3]. By eliminating per-trade fees, which were once a significant barrier, PFOF has enabled millions of new retail investors to access the equity markets.
• Providing Price Improvement: Supporters contend that routing orders to wholesalers results in superior execution for retail investors. Because wholesalers can execute trades "inside" the public bid-ask spread, they often provide price improvement that is not available on exchanges, which are generally prohibited from quoting in sub-penny increments by Regulation NMS [3]. Academic research has shown that retail investors receive tens of millions of dollars per month in aggregate price improvement [10].
• Enhancing Market Liquidity and Efficiency: The predictable stream of retail order flow allows market makers to better manage their inventory risk. This, in turn, enables them to provide more liquidity to the market, which can lead to tighter bid-ask spreads and more efficient price discovery for all participants [3].

Arguments Against PFOF (The Critic's View):
Critics, including investor advocacy groups like Better Markets and, until 2025, the SEC leadership, argue that PFOF creates a flawed and conflicted market structure that harms investors. Their primary arguments are:

• Inherent Conflict of Interest: This is the central and most potent criticism. A broker has a legal and fiduciary duty to seek "best execution" for its clients' orders [4]. However, the PFOF model creates a direct financial incentive for the broker to route orders to the market maker that pays the highest rebate, which may not be the venue that provides the best execution quality [3]. Former SEC Chair Gary Gensler repeatedly characterized this as an "inherent conflict of interest," while critics have gone further, calling the practice a "kickback" [3].
• Inferior Execution and Hidden Costs: Opponents argue that the "price improvement" provided is often illusory or suboptimal. They contend that it is measured against a wide and artificial benchmark (the NBBO) and that in a more competitive, auction-based system, investors would receive even better prices [7]. The Gensler-led SEC's own analysis suggested that replacing the PFOF model with a competitive auction system could save retail investors an estimated $1.5 billion annually [8]. Better Markets alleges that the difference between the price improvement received and the better price that
  could have been achieved is effectively a hidden cost borne by retail investors [12].
• Market Fragmentation and Opacity: PFOF has led to a market structure where a vast portion of trading volume—especially from retail investors—is diverted away from transparent public exchanges. In 2022, over 90% of retail marketable stock orders were routed to a concentrated group of just six off-exchange wholesalers [8]. Critics argue this segmentation harms the public price discovery process, reduces transparency, and creates a two-tiered market that disadvantages investors whose orders remain on lit exchanges [12].

The table below summarizes the key arguments in this long-standing debate.

The Gensler-Era SEC and the Path Toward Reform (2021-2024)

The regulatory environment from 2021 through the end of 2024 was characterized by increasing skepticism of PFOF, driven directly by the public stance of then-SEC Chair Gary Gensler. This period saw the development of a comprehensive reform package that laid the legislative groundwork for a potential ban, creating significant momentum that would be abruptly halted in 2025.

A Critical Stance from the Top: "A Ban is on the Table"

In the wake of the "meme stock" trading frenzy of early 2021, which cast a spotlight on the business models of retail brokerages, SEC Chair Gary Gensler made PFOF a primary focus of his market structure agenda [18]. He moved beyond the traditional regulatory language of managing conflicts, instead adopting a more critical tone. Gensler publicly and repeatedly stated that PFOF presents an "inherent conflict of interest" for brokers [4]. This choice of words from the nation's top securities regulator was a clear signal of a fundamental disapproval of the practice.

Most significantly, Chair Gensler confirmed in public interviews that an outright ban on PFOF was "on the table" [15]. This declaration electrified the policy debate, galvanizing both the financial industry's opposition and the efforts of investor advocates who had long called for such a prohibition. It transformed the question of a PFOF ban from a theoretical possibility into a tangible regulatory threat.

The 2022 Market Structure Overhaul: The Legislative Toolkit for a Ban

The Gensler SEC translated its critical stance into concrete action in December 2022, when it unveiled a sweeping package of four interconnected rule proposals aimed at fundamentally reshaping U.S. equity market structure [20]. These proposals were not a piecemeal effort but a holistic, synergistic strategy designed to dismantle the PFOF ecosystem by promoting direct competition for retail orders.

The centerpiece of this anti-PFOF agenda was the Order Competition Rule (proposed Rule 615). This rule would have mandated that brokers route the majority of their individual investor orders into "fair and open auctions" before they could be executed internally by any trading center [20]. By forcing orders into a competitive bidding process open to a wide range of market participants, the rule was engineered to directly sever the exclusive, bilateral relationships between brokers and wholesalers that form the basis of PFOF. If a broker could no longer guarantee its order flow to a specific wholesaler, the wholesaler would have no reason to pay for it, effectively eliminating the PFOF revenue stream [18].

A second critical proposal was Regulation Best Execution. This aimed to establish, for the first time, a detailed best execution standard directly under the SEC's own rules, supplementing the existing principles-based rule enforced by FINRA [20]. The proposed SEC rule would have imposed a more rigorous and prescriptive standard, with heightened requirements for brokers managing conflicts of interest. Specifically, a broker accepting PFOF would have faced a much higher compliance burden to document and justify that its routing decisions were, in fact, in its customers' best interests, notwithstanding the conflicting payments it received [21]. This would have significantly increased the legal and operational risks associated with PFOF, making the practice far less attractive even if it were not explicitly banned.

Supporting these two main pillars were proposals to reduce minimum pricing increments ("tick sizes") and to expand the disclosure requirements under Rule 605. These were designed to further enhance transparency and foster a more competitive environment, making it easier to compare execution quality across different venues and harder to obscure the potential costs of conflicted routing arrangements [20]. The interconnected nature of these proposals demonstrated a sophisticated, multi-pronged regulatory strategy aimed at systemically undermining the PFOF model.

The Battle Lines Are Drawn: Industry vs. Advocates

The SEC's ambitious proposals triggered a fierce response from all corners of the market. The financial industry, led by powerful trade groups like SIFMA, launched an intense lobbying campaign to oppose the reforms [19]. In a 2023 objection letter, SIFMA argued that the proposals were "far reaching" and, rather than protecting investors, would "harm competition among trading centres and make markets less efficient" [18]. The core industry argument was that the existing system, governed by disclosure rules and FINRA's best execution standard, was functioning well and delivering significant benefits to retail investors in the form of zero commissions and price improvement [9].

On the other side, investor advocacy organizations like Better Markets threw their full support behind the reforms. They viewed the proposals as a long-overdue effort to fix what they described as a "polluted" market structure rife with conflicts that cost Main Street investors billions of dollars annually [12]. The stage was set for a protracted regulatory battle over the future of retail trade execution in the United States.

International Precedent: The Global Case Against PFOF

The Gensler-era SEC's move toward reform was not occurring in a vacuum. It was aligned with a clear and growing international regulatory trend against PFOF. This global context is crucial, as it demonstrates that the subsequent 2025 policy reversal by the U.S. was not just a domestic decision but a conscious divergence from the path taken by its major international peers.

The United Kingdom's 2012 Ban: A Case Study in Reform

The United Kingdom has been at the forefront of the anti-PFOF movement. In 2012, the UK's Financial Services Authority (FSA), the precursor to the Financial Conduct Authority (FCA), issued guidance that effectively banned the practice [7]. The regulator's rationale was straightforward: the conflict of interest created by PFOF was fundamentally incompatible with a firm's duty to provide best execution and with rules prohibiting improper inducements [7].

The outcomes of the UK ban provided powerful ammunition for reformers in the U.S. A 2016 study by the CFA Institute analyzed the impact of the ban and found significant improvements in market quality. The percentage of retail-sized trades executing at the best publicly quoted price on the London Stock Exchange surged from 65% in 2010 to over 90% by 2014 [7]. While the frequency of trades executed with "price improvement" inside the spread decreased, this was accompanied by a significant narrowing of the quoted spreads themselves. This suggested that the market had become more transparent and efficient, with investors receiving better "touch prices" on the whole, validating the regulator's concerns that PFOF had been contributing to artificially wide spreads [7].

The European Union's 2024 Prohibition: A Continental Consensus

Following years of debate, the European Union took decisive action in 2024. On March 28, 2024, amendments to the Markets in Financial Instruments Regulation (MiFIR) entered into force, establishing a comprehensive, EU-wide prohibition on investment firms receiving PFOF for executing retail client orders [3]. The European Securities and Markets Authority (ESMA) had long signaled its view that PFOF was likely incompatible with the investor protection principles enshrined in the MiFID II framework [16]. The new rule makes this position explicit law across the Union.

The MiFIR amendments include a transitional period until June 30, 2026, allowing member states where PFOF was prevalent, such as Germany, to phase out the practice [26]. However, the ultimate direction is unambiguous: PFOF is being eliminated from the European market.

PFOF Bans in Other Jurisdictions

The anti-PFOF consensus extends beyond Europe. The practice is also banned for domestic securities in Canada and has been prohibited in Australia, further cementing its controversial status in major developed markets [3].

This global regulatory landscape is critical. Under the Gensler SEC, the successful bans in the UK, EU, and elsewhere served as a powerful roadmap, demonstrating that prohibiting PFOF was not only feasible but could lead to positive market outcomes. They provided political and regulatory cover for a similar move in the U.S. However, the 2025 SEC policy reversal has fundamentally changed this dynamic. International precedent is no longer a model to be emulated but a foil against which to contrast the American approach. The new U.S. position is a conscious choice to chart a different course, one that prioritizes what its proponents call "innovation" and competitiveness over alignment with a global standard of investor protection. This reframes the PFOF decision as a strategic move in the global competition for capital and financial services leadership.

The table below starkly illustrates the divergent path the U.S. has taken.

The Atkins Commission: A New Chair, A New Philosophy (2025)

The definitive reversal of the SEC's stance on PFOF in 2025 can be traced to a single, pivotal event: the change in leadership at the Commission. The departure of Gary Gensler and the arrival of Paul Atkins as the new Chair heralded not just a personnel change, but an ideological sea change that reshaped the agency's priorities and spelled the end for the ambitious market structure reforms of the preceding era.

Transition of Power

Following the 2024 presidential election, Gary Gensler announced he would step down as SEC Chairman, with his departure effective on Inauguration Day, January 20, 2025 [27]. He was succeeded by Paul Atkins, a former SEC Commissioner (2002-2008) with a well-established record as a proponent of free-market principles, capital formation, and a more restrained approach to regulation. Atkins officially took the helm of the agency in April 2025, immediately setting a new tone [28].

The Atkins Doctrine: A New Regulatory Blueprint

From his first public remarks, Chair Atkins made it clear that a "new day at the SEC" had arrived [30]. He articulated a regulatory philosophy that was a sharp departure from his predecessor's, built on several key tenets:

• A Rebalanced "Core Mission": Atkins has consistently emphasized a return to what he terms the SEC's "familiar three-part mission": protecting investors, facilitating capital formation, and ensuring fair, orderly, and efficient markets [30]. While acknowledging investor protection as a cornerstone, his public statements reveal a significantly greater emphasis on the
  facilitation of capital formation—that is, making it easier for companies to raise money and for markets to innovate [30].
• Reducing Regulatory Burden: A central theme of the Atkins Commission is the need to ease regulatory burdens that are seen as inhibiting economic growth and capital investment [31]. He has been a vocal critic of what he terms "mis-regulation" and has stressed that the agency should not create "a solution in search of an unidentified problem" [30].
• A More Deliberate Rulemaking Process: Chair Atkins has called for a return to a more traditional and deliberate rulemaking process, advocating for longer public comment periods (60 to 90 days), greater use of concept releases and roundtables, and a more rigorous analysis of the economic impact of proposed rules [30]. This is a direct reaction to the aggressive and rapid pace of rulemaking that characterized the Gensler years.
• A Shift in Enforcement Priorities: The new Commission's enforcement focus is shifting back toward what Atkins calls "classic" fraud—cases involving clear deception where bad actors "lie, cheat, and steal" [30]. This signals a move away from enforcement actions based on technical violations, such as the prior focus on off-channel communications, and toward cases with more direct and demonstrable investor harm [30].

This regulatory philosophy is fundamentally incompatible with an outright ban on PFOF. A ban represents a highly interventionist, complex, and burdensome regulation designed to solve a problem—the "inherent conflict of interest"—that the new leadership likely believes is already adequately managed by existing disclosure and best execution rules. From a perspective that prioritizes capital formation and market-led innovation, PFOF is the financial model that enables zero-commission trading, a practice that has undeniably increased retail investor participation in the markets. Therefore, banning it would be viewed as a regressive step that harms an innovative business model and potentially restricts retail access, all to address a conflict that can be managed through less drastic means.

Skepticism of the Gensler Legacy

Chair Atkins' skepticism of the previous administration's agenda was not new. He has been a long-time public critic of Regulation NMS, the foundational rule set that governs modern market structure. He has described Reg NMS as "unnecessarily complex," arguing that it "invites gamesmanship, induces widespread market fragmentation, disperses liquidity, and diminishes transparency" [36]. Given this deeply held view, it was highly improbable that he would support the addition of even more complex market structure rules like the Order Competition Rule.

This philosophical disposition was quickly reflected in the new Commission's actions. Throughout the first half of 2025, the Atkins SEC demonstrated a clear pattern of re-evaluating, delaying, or actively withdrawing from the defense of controversial Gensler-era initiatives. This included repeatedly extending the compliance date for amendments to Form PF for private fund advisers, with Chair Atkins publicly questioning whether the data's utility justified the "massive burdens" of its collection [37]. Most notably, the Commission voted to end its legal defense of the contentious climate-related disclosure rules adopted under Gensler [40]. The subsequent move against the market structure proposals was the logical continuation of this broader trend.

The Great Withdrawal: Deconstruction of the Anti-PFOF Agenda (June 2025)

The definitive answer to whether the SEC would ban PFOF in 2025 arrived on June 12. On that day, the Commission took a single, sweeping action that effectively terminated the anti-PFOF regulatory project and provided an irrefutable conclusion to the debate.

The June 12, 2025, Formal Withdrawal

In a move that signaled a decisive clearing of the regulatory decks, the SEC formally withdrew fourteen outstanding rule proposals that had been issued by the prior administration [1]. This was not a piecemeal rollback but a comprehensive repudiation of the Gensler-era agenda.

Critically, the list of rescinded rules included the two essential pillars of the proposed PFOF overhaul [2]:

• File No. S7-31-22: Order Competition Rule
• File No. S7-32-22: Regulation Best Execution

Other related market structure proposals, such as one targeting "Volume-Based Exchange Transaction Pricing for NMS Stocks," were also withdrawn in the same action, confirming a complete retreat from the 2022 reform package [2].

The Inescapable Implication: The End of the Road for a Ban

The withdrawal of these specific rules was a dispositive act. By rescinding the Order Competition Rule, the Commission removed the primary mechanism through which it could have effectively prohibited PFOF. Without a mandate to route retail orders to competitive auctions, the foundational business model of bilateral agreements between brokers and wholesalers can continue unimpeded.

Simultaneously, the withdrawal of the proposed Regulation Best Execution removed the threat of a heightened, SEC-enforced compliance standard. This eliminated the risk that PFOF arrangements would become too legally perilous or operationally costly for brokers to maintain. By dismantling the very tools that were designed for the task, the SEC has made a PFOF ban in 2025 a regulatory impossibility. The effort has not been merely paused; its machinery has been scrapped.

This action was the logical culmination of the change in leadership and philosophy at the Commission. It also represents a significant victory for the financial industry's extensive lobbying efforts against the Gensler-era proposals [18]. Historical analysis of financial regulation shows that intensive lobbying by the industry is often effective in preventing or weakening rules perceived as overly burdensome [23]. The arrival of a new, more industry-sympathetic Chair created a highly receptive audience for these arguments. The sweeping withdrawal of fourteen rules on a single day suggests the implementation of a pre-determined agenda that aligns closely with the industry's long-standing objectives, demonstrating the powerful interplay between political change, regulatory philosophy, and industry influence in shaping market outcomes.

The timeline below provides a clear narrative of this policy arc, from ambitious reform to complete dismantlement.

Conclusion and Forward Outlook

The accumulated evidence and the definitive regulatory actions taken in 2025 lead to an unequivocal conclusion regarding the future of Payment for Order Flow in the United States. The question of a potential ban is no longer a matter of speculation or prediction; it has been answered.

The Verdict: No Ban in 2025

The SEC will not ban Payment for Order Flow in 2025. The formal withdrawal of the Order Competition Rule and the proposed Regulation Best Execution on June 12, 2025, was a dispositive act that terminated any viable regulatory path toward such a prohibition. This outcome was driven primarily by the fundamental shift in regulatory philosophy at the Commission following the appointment of Chair Paul Atkins, whose focus on facilitating capital formation and reducing regulatory burdens is antithetical to the kind of heavy-handed, interventionist reform that a PFOF ban would represent.

The Future of PFOF Regulation: A Return to the Status Quo Ante

With a ban decisively off the table, the regulation of PFOF in the U.S. reverts to the framework that existed prior to the Gensler-era reform push. This framework is built on two main components:

• Disclosure as the Primary Tool: The SEC will continue to rely on its existing disclosure regime to provide transparency into the practice. This includes Rule 606, which requires brokers to publish quarterly reports detailing their order routing practices and the PFOF they receive, and Rule 605, which requires market centers to publish monthly statistics on their execution quality [3]. The prevailing philosophy at the Atkins Commission suggests a belief that market forces, informed by robust disclosure, are the most effective regulators.
• FINRA's Best Execution Rule: The broker-dealer's duty of best execution will continue to be governed and enforced primarily under FINRA Rule 5310. This rule requires firms to use "reasonable diligence" to ascertain the best market for a security and execute orders so that the price is as favorable as possible under prevailing conditions [4]. The withdrawal of the SEC's own proposed Regulation Best Execution means this standard will not be heightened or subjected to a new, more prescriptive layer of SEC oversight.

While critics will undoubtedly continue to voice concerns about the conflicts inherent in PFOF, the regulatory threat to the practice has been effectively neutralized for the foreseeable future. The issue is likely to remain politically dormant, potentially re-emerging under a different future administration, but it is no longer on the active regulatory agenda [19].

Implications for the U.S. Market

This policy reversal has significant implications for all market participants:

• For Brokers and Wholesalers: The PFOF-based business model is secure. Zero-commission brokers can continue to rely on this crucial revenue stream to fund their operations, and wholesale market makers can continue to purchase and internalize retail order flow, which is central to their trading strategies [4].
• For Retail Investors: The most visible benefit—commission-free trading—will remain the industry standard. The underlying debate over the "hidden costs" of potentially inferior execution will persist, but the system itself is no longer facing an existential regulatory challenge.
• For U.S. Market Structure: The U.S. has cemented its position as a global outlier on PFOF regulation. This strategic choice reflects a different philosophical balance between direct investor protection and a belief in market-led innovation. The U.S. equity market will continue on its current trajectory of a fragmented, intensely competitive, and complex structure, where a significant portion of retail trading volume is executed in off-exchange venues.

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