Form 13F Filing Requirements for Registered Investment Advisors

Some investment advisors have to report certain portfolio holdings to the Securities and Exchange Commission (SEC) on Form 13F. The filing applies to institutional investment managers that exercise investment discretion over securities above a specified threshold. For registered investment advisors, understanding when Form 13F applies and how the filing process works can help avoid missed reporting obligations.

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Understanding SEC Form 13F

Form 13F is an official reporting form used to collect information about institutional investment managers who are subject to regulation under Section 13(f) of the Securities Exchange Act of 1934. Congress enacted this section in 1975 “to increase the public availability of information regarding the securities holdings of institutional investors.”

Here’s an overview of commonly asked questions about Form 13F: ¹

A manager that meets the $100 million threshold on the last trading day of any month during a calendar year generally must file Form 13F for the fourth quarter of that year and for the first three quarters of the following year. The due date is 45 days from the end of the calendar quarter. For 2026 and 2027, the deadlines are as follows:

These deadlines are firm and the SEC doesn’t grant extensions. Missing a filing deadline could subject your firm to closer regulatory scrutiny and/or enforcement actions, including fines or other penalties.

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Form 13F Filing Requirements for Registered Investment Advisors

RIAs must submit Form 13F if they exercise discretion over $100 million or more in Section 13(f) securities. It doesn’t matter if your firm is registered with the SEC or state regulators; if you meet the qualifying asset threshold at the end of any month during the calendar year, you’ll need to file Form 13F.

Here’s what RIAs must do to file Form 13F:

1. Collect and Format Your Information

You’ll need to share details of all Section 13(f) securities you have discretion over. The SEC requires this information to be submitted in XML format, rather than a PDF or Excel spreadsheet. Here’s a recap of what you need to collect to build your information table:

• Security issuer name and class
• 9-digit CUSIP number
• Number of shares
• Total market value, rounded to the nearest dollar
• Investment discretion
• Voting authority

Again, you would only include Section 13(f) securities here. You would not include open-end mutual funds, short positions, cash and cash equivalents, most fixed-income securities and any other security not included on the SEC’s official list.

2. Submit a Form ID Application

All Form 13F submissions must be made through EDGAR, the SEC’s Electronic Data Gathering, Analysis, and Retrieval system. To use EDGAR, you’ll need to complete a Form ID application. Here’s how it works:

• Visit the EDGAR Filer Management System
• Select ‘Apply for EDGAR Access’
• Select ‘New EDGAR Account’ if you don’t have an account yet, or ‘Existing EDGAR Account’ if you do have one
• Follow the prompts to select the appropriate Form ID form, then complete all six parts

You’ll need to provide your full legal name or company name, and federal tax identification number. If you’re applying as an individual, do not include your Social Security number.

You’ll also add billing information, create an electronic signature and upload a notarized authenticating document to your application. Once you submit your application, the SEC will review it for approval and reach out to you if any errors need to be corrected.

If approved, you’ll receive a 10-digit Central Index Key (CIK), which you’ll need to complete your Form 13F filing. Note that this is separate from your Form 13F file number, which is a unique identifier used to distinguish you from other firms. File numbers are issued after you submit Form 13F for the first time and begin with 28. For example, your file number would look like this: 28-000.

3. Create a Cover Page

Form 13F has three parts: a cover page, a summary page and the information table you created in step one. The cover page includes the reporting period date, the name and contact information of the entity or individual filing the form, the filer’s signature and the firm’s file number. Again, if this is your first time filing Form 13F, you would not have a file number to include yet.

4. Draft the Summary Page

The summary page provides an overview of what’s included in your information table and your firm’s details. Your page should include the following:

• Total value of 13(f) securities
• List of other included managers, apart from the one filing the report
• Detailed list of securities

Here’s an example of what a Form 13F cover page and summary look like.

5. Review for Errors and Formatting

Once you’ve completed the cover and summary pages and built your information table in XML format, the last step is reviewing your submission for errors or inaccuracies before filing with EDGAR. Common errors to check for include incorrect CUSIP numbers, misplaced decimal points and missing or incomplete data fields.

If you’re confident that everything is correct, you can log in to EDGAR to complete your filing using the CIK provided to you when you submitted your Form ID application. You’ll also need a separate CIK Confirmation Code (CCC), which you can view through your EDGAR account dashboard.

Frequently Asked Questions

Bottom Line

Understanding 13F filing requirements for RIAs is part of your firm’s overall compliance strategy. Failing to meet the filing deadline or file this form at all if required to do so could trigger serious penalties if you come under the SEC’s scrutiny. Coordinating with your firm’s chief compliance officer to ensure timely filings can help you avoid potential violations.

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