New RIA compliance calendar: first-year deadlines

For an SEC-registered adviser with a 31 December fiscal year end, the dates set by rule are fixed offsets from the year end or the calendar quarter. Form ADV annual updating amendment: 31 March, under Rule 204-1(a)(1). Brochure, or a summary of material changes with an offer of the brochure, to each client: 30 April, under Rule 204-3(b)(2). Code of ethics transaction reports: 30 January, 30 April, 30 July and 30 October. Dates published annually by someone else, mainly FINRA's IARD renewal programme, change each year and must be checked. This page is general information, not legal advice.

What is due as soon as you register?

• Code of ethics initial holdings reports. Each access person reports holdings no later than 10 days after becoming an access person, with information current as of a date no more than 45 days before that (Rule 204A-1(b)(1)(ii)(A)). A firm whose only access person is the owner does not report to itself under Rule 204A-1(d), but must keep records of the same holdings and transactions.
• Brochure and Form CRS at the start of each relationship. Deliver the brochure before or at the time of the advisory contract (Rule 204-3(b)(1)) and, for retail investors, Form CRS at the same point. See posting Form CRS on your website.
• Regulation S-P. The 2024 amendments (Release 34-100155) applied to smaller entities from 3 June 2026, so a new registrant needs an incident response programme and service provider oversight from day one. See Reg S-P vendor oversight.
• Custody. If you have custody and need a surprise examination, the agreement with the accountant must provide for the first examination within six months of becoming subject to Rule 206(4)-2(a)(4), then once each calendar year at a time the accountant chooses without notice.
• The 120-day check. If you registered under Rule 203A-2(c) on a reasonable expectation of becoming eligible for SEC registration within 120 days, you must file Form ADV-W within 120 days of your registration becoming effective if you would then be prohibited from SEC registration.
• State notice filings. SEC registrants make notice filings and pay fees in the states that require them, through IARD. Requirements vary by state.

Month by month: first full year (2027)

"Fixed" means the date follows from a rule and your fiscal year end. "Published" means a body sets it each year. Several 2027 dates fall on a weekend, so file before the date rather than after it.

The 2026 renewal dates come from FINRA's 2027 Renewal Program Calendar: preliminary statements on 9 November 2026, payment received by 7 December 2026, final statement payment by 22 January 2027. Do not assume the same dates for later years.

Which items have no fixed date?

• Form CRS amendments. File within 30 days of any information becoming materially inaccurate, and tell existing retail clients within 60 days (Form CRS General Instruction 8). Form ADV Instruction 4 says you may, but need not, file Form CRS with the annual amendment.
• Other-than-annual Form ADV amendments. File promptly when the items listed in Form ADV Instruction 4 become inaccurate or materially inaccurate.
• Annual compliance review. Rule 206(4)-7(b) requires a review "no less frequently than annually". You choose the date. Write the review down.
• Annual holdings reports. At least once each 12 months on a date you select, with information no more than 45 days old.
• Form PF changes. The 2024 Form PF amendments now have a compliance date of 1 July 2027, after an extension in August 2026.

When does the SEC examine a new adviser?

No date is published. The Division of Examinations' fiscal year 2026 priorities say: "As with previous years, the Division will prioritize examinations of advisers that have never been examined, with particular emphasis on recently registered advisers." The same document lists Regulation S-P and vendor oversight as a focus. Expect the request list to ask for evidence that each deadline above was met, not only the policy that describes it.

IAR continuing education under the NASAA model rule is 12 credits a year (6 ethics and professional responsibility, 6 products and practice) by 31 December, and only in jurisdictions that have adopted it. More than 20 have, so check NASAA's current list for each state where your representatives register. State-registered advisers follow state versions of most of these rules.

Plumb generates this calendar from your fiscal year end and firm profile, marks the IARD dates as approximate, and stores each completion with an evidence note for the exam binder.