SEC investment adviser deadlines, month by month

Updated 13 Oct 2026

For an SEC-registered investment adviser with a December 31 fiscal year end, most deadlines fall in the first four months: code of ethics transaction reports by January 30, Form 13F and Form 13H by February 14 if they apply, the Form ADV annual amendment by March 31, and the brochure delivery, Form PF and audited fund financial statements by April 30. The IARD renewal payment follows in early December, and the annual compliance review and holdings reports fall on dates you choose.

Table of SEC investment adviser deadlines for a December 31 fiscal year end: code of ethics transaction reports January 30, April 30, July 30 and October 30 (Rule 204A-1(b)(2)); Form 13F February 14, May 15, August 14 and November 14 (Rule 13f-1); Form 13H annual update February 14 (Rule 13h-1); Form ADV annual amendment March 31 (Rule 204-1(a)(1)); brochure or summary of material changes to clients April 30 (Rule 204-3(b)(2)); Form PF annual update April 30 (Rule 204(b)-1); audited fund financial statements to investors April 30 (Rule 206(4)-2(b)(4)); Form N-PX August 31 (Rule 14Ad-1); IARD renewal payment in early December; annual compliance review and annual holdings reports on dates you choose. — Dates for a December 31 fiscal year end in a non-leap year. In a leap year, 90 and 120 days run out a day earlier, on March 30 and April 29.

January to March: Form ADV season

January 30: code of ethics transaction reports for the fourth quarter, from every access person (Rule 204A-1).
February 14: Form 13F for the fourth quarter, if you exercise discretion over $100 million or more in 13(f) securities, and the Form 13H annual update if you're a large trader (Rule 13h-1).
March 31: the Form ADV annual amendment, within 90 days of your fiscal year end. Update Part 1A, the Part 2A brochure and, as the instructions require, Form CRS (Rule 204-1).

Many advisers finish the annual compliance review before the Form ADV filing, so anything it changes can go into the brochure.

April: clients, funds and Form PF

April 30: if your brochure changed materially, deliver the current brochure, or a summary of material changes that offers it, to each client free of charge, within 120 days of your fiscal year end (Rule 204-3).
April 30: the Form PF annual update, if you advise private funds and had at least $150 million in private fund assets at your last fiscal year end (Rule 204(b)-1-1)). Large hedge fund advisers file quarterly within 60 days instead, and large liquidity fund advisers within 15 days.
April 30: audited financial statements to fund investors, within 120 days of each fund's fiscal year end, if you rely on the custody rule's audit approach (Rule 206(4)-2-2)).

Every quarter

Code of ethics transaction reports within 30 days of each calendar quarter end: January 30, April 30, July 30 and October 30.
Form 13F within 45 days of each quarter end: February 14, May 15, August 14 and November 14 (Rule 13f-1).

August and December

August 31: Form N-PX, if you file Form 13F, with your say-on-pay votes for the 12 months to June 30 (Rule 14Ad-1).
Early December: the IARD renewal. Pay the Preliminary Statement for next year's state notice filing and registration fees by the deadline on the IARD renewal calendar, which was December 7 for the 2027 renewals. A Final Statement follows in January if more is owed.

On dates you choose

The annual compliance review of your policies and procedures, at least once a year (Rule 206(4)-7-7)).
Annual holdings reports from access persons, at least once every 12 months, with information current within 45 days.

Keep the records behind each one. The policies in force and the records of each annual review are kept for five years (Rule 204-2), and they're what an examiner asks for first.

Not on a calendar

If you have custody of client assets and don't use the audit approach, an independent accountant verifies them by a surprise examination once each calendar year, at a time it chooses.
FinCEN has postponed its anti-money laundering rule for investment advisers to January 1, 2028.
The 2024 amendments to Form PF have had their compliance date pushed back several times, so check the SEC's Form PF page before your next filing.

Get reminded before each deadline

Regmindr sets up your compliance calendar from a template in about two minutes, and emails your team before each deadline is due.

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Sources

This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.