Speedplay (and the new TriRig pedal, and Aerolite) present a particular problem by the cleat wrapping around the pedal and no rotating part of the pedal being accessible to which you could bolt a reflector bracket. I think to be strictly legal, you'd have to attach BS stamped reflectors to the cleats, and then argue that since the pedals are useless without cleats, the cleats are part of the pedal.
Speedplay (and the new TriRig pedal, and Aerolite) present a particular problem by the cleat wrapping around the pedal and no rotating part of the pedal being accessible to which you could bolt a reflector bracket. I think to be strictly legal, you'd have to attach BS stamped reflectors to the cleats, and then argue that since the pedals are useless without cleats, the cleats are part of the pedal.