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Registered investment advisors are subject to SEC rules, and there are several important regulatory deadlines to be aware of. Arguably the most important is the annual deadline for Form ADV updates, which are due within 90 days of the end of a firm’s fiscal year. Assuming your fiscal year ends December 31, that makes the filing cutoff March 31 of the following year. Learn what other important dates advisors should be aware of to remain compliant.
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SEC Filing Deadlines for Registered Investment Advisors (RIAs)
The SEC has an extensive list of annual filing requirements for registered individuals and entities, though not all of them may apply to you. The following are some of the most important filing deadlines that registered advisors should know in order to remain compliant:
| Form | Purpose | Filing Deadline |
|---|---|---|
| Form ADV Annual Updating Amendment | Includes material information about your firm’s structure, fees, ownership and operations | 90 days from the end of the firm’s fiscal year (typically March 31 for most firms) |
| Form ADV Part 3 (Form CRS) Updating Amendment | Written disclosure that RIAs and broker-dealers must provide when offering advisory services | 30 days from any material changes |
| Form 3 | Required when someone becomes an insider, and is used to disclose their ownership of company securities | 10 days from the date the person becomes an insider |
| Form 4 | Must be filed when there is a material change in the holdings of company insiders, such as directors, officers and significant shareholders | Within two days of the transaction date |
| Form 5 | Must be filed when insiders conduct transactions in the company’s securities | 45 days from the end of the fiscal year |
| Form 8-K | Used to disclose material events that shareholders should be aware of, such as the acquisition of assets or a bankruptcy filing | Within four business days after the occurrence of a triggering event, with some exclusions |
| Form 10-K (Annual Report) | Offers a comprehensive overview of a company’s operations, performance and risks, including cybersecurity risks | Large accelerated filer: 60 days after the end of the fiscal quarter Accelerated filer: 75 days after the end of the fiscal quarter Non-accelerated filer: 90 days after the end of the fiscal quarter |
| Form 10-Q (Quarterly Report) | Quarterly report disclosing business performance and operations for the previous fiscal quarter | Large accelerated filer: 40 days after the end of the fiscal quarter Accelerated filer: 40 days after the end of the fiscal quarter Non-accelerated filer: 45 days after the end of the fiscal quarter |
| Form PF | Private fund advisors use Form PF to report regulatory assets under management | 120 days after the end of the firm’s fiscal year |
There are other deadlines you may need to be aware of, depending on your registration status and the type of services you offer. Note that these are federal deadlines only; state regulatory authorities may have additional filing requirements and deadlines you’ll need to meet.
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Consequences of Missing SEC Regulatory Filing Dates
Missing a deadline might seem like a minor misstep, but it can have serious consequences for advisors. The SEC can initiate an investigation into your firm and penalize you with monetary fines. Missed deadlines can also damage your firm’s brand reputation, making it difficult to retain your existing clients and attract new ones.
In a worst-case scenario, noncompliance with SEC filing deadlines may result in lawsuits, legal action or forfeiture of your registration status with the SEC. A recent example occurred in 2024, when the SEC charged an investment advisor with violations of the custody rule and Form ADV requirement. Among other violations, the firm failed to update its Form ADV promptly and ended up agreeing to a $75,000 fine as well as censure. 1
SEC enforcement actions can have other costs if your brand image suffers. You may lose clients or find it difficult to attract new ones to your firm with a compliance violation on your record. Working with your firm’s CCO to manage SEC regulatory filing deadlines or using compliance software to track them can help you avoid this type of scenario.
Other Filing Deadlines for Advisors
In addition to SEC rules, there are other important deadlines to be aware of. For example, if you’re subject to the NASAA’s continuing education rule for investment advisor representatives, you must report credits earned by December 31 each year. 2 Most course providers will report this for you automatically, but you may want to keep track of the credits you earn yourself to make sure none fall through the cracks. Note that not all states or jurisdictions follow the NASAA guidelines; check with your state regulatory authority to determine if this deadline applies to you.
Additionally, advisors who are dual-registered as broker-dealers or registered at the state level must participate in the IARD renewal program administered by FINRA. This program allows you to renew your state registration and the annual deadline for 2027 renewals is Dec. 27, 2026. The deadline to report any discrepancies on your filing statement is Jan. 22, 2027. FINRA advises beginning preparation in October to meet the deadlines. 3
Frequently Asked Questions (FAQs)
When Is Form ADV Due?
Form ADV is due 90 days after the end of the fiscal year. If your fiscal year ends on December 31, your updated form is generally due by March 31 of the following year. When the deadline lands on a weekend, it’s moved to the next business day.
What Forms Are Registered Advisors Required to File With the SEC?
Advisors registering with the SEC for the first time are required to submit Form ADV. Part 1 and Part 2 are submitted to the SEC while Part 3, the Customer Relationship Summary (CRS), is submitted through the Investment Adviser Registration Depository (IARD).
What Do I Do if I Miss an SEC Filing Deadline?
Advisors have up to 24 hours after the day of the initial deadline to submit any required forms. This is known as a non-timely filing, and you must explain the reason why you missed the deadline. The SEC may waive penalties for late filings that have a reasonable explanation.
Bottom Line
SEC deadlines exist for a reason, and it’s important to keep track of them to ensure you’re meeting filing requirements on time. Establishing an annual compliance calendar can make it easier to plan your filings ahead of time, so you don’t risk missing an important due date.
Tips for Growing Your Advisory Business
- With so much to do as a busy advisor, it’s easy to let marketing slip to the back burner. That can be costly, however, if you’re missing opportunities to connect with prospects and grow your client base. Working with an advisor marketing platform like SmartAsset AMP can help you make sure nothing falls through the cracks. Schedule a demo to learn how you can leverage it to grow your book of business.
- Aside from filing deadlines, there are other SEC compliance rules registered advisors should know. Some of the newest rule additions include the SEC’s guidance on cybersecurity incident reporting and the marketing rule. Monitoring compliance trends can help you better prepare for new rules as they emerge.
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Article Sources
All articles are reviewed and updated by SmartAsset’s fact-checkers for accuracy. Visit our Editorial Policy for more details on our overall journalistic standards.
- “SEC Charges Investment Adviser for Custody Rule and Form ADV Violations.” U.S. Securities and Exchange Commission, 23 Aug. 2024, https://www.sec.gov/enforcement-litigation/administrative-proceedings/ia-6665-s.
- “Investment Adviser Representative Continuing Education.” North American Securities Administrators Association, https://www.nasaa.org/industry-resources/investment-advisers/investment-adviser-representative-continuing-education/.
- “Annual Renewal Program.” FINRA, https://www.finra.org/registration-exams-ce/broker-dealers/annual-renewal.