An RIA compliance calendar for 2026 and 2027 starts with the deadlines a rule fixes every year: the Form ADV annual amendment within 90 days of fiscal year-end, brochure delivery within 120 days, Form 13F within 45 days of each quarter, Form N-PX by 31 August, private fund audited financials within 120 days and the annual compliance review. Then come the dates that moved after the calendar was printed: the Form PF amendments, now July 1, 2027 after four extensions; Form N-PORT reporting under the Names Rule, now November 17, 2027 for fund groups of $10 billion or more; and new proposals with comment deadlines running to December 14, 2026. The Regulation S-P amendments did not move, and both of their compliance dates have passed. A calendar built in January is wrong by June unless something re-reads the regulators. Botminds' Regulatory Change Management for Asset Managers keeps the dates on a 20-month horizon, detects moved dates from the regulators' notices and re-plans every dependent task for a person to approve.
This guide is for the CCO of a registered investment adviser. Dates assume a fiscal year ending 31 December; every rule is linked to its text, and the moved dates to the Federal Register notice that moved them. Examples of the software use its fictional sample firm, Quillfield Capital.
The calendar’s moving parts on 28 October 2026
1 Jul 2027
Form PF amendments compliance date, after four extensions
3 Jun 2026
last Regulation S-P compliance date, for smaller entities: passed
17 Nov 2027
Names Rule Form N-PORT reporting for fund groups of $10 billion or more
5
SEC proposals for advisers and funds with comments due between 9 November and 14 December 2026
The recurring RIA compliance calendar for 2027
These dates come from the rules themselves and recur every year. For an adviser with a 31 December fiscal year, the 2027 dates fall as shown; for another fiscal year, count from its end. For Form 13F, a 45th day on a Saturday, Sunday or federal holiday rolls forward to the following business day, as the SEC's Form 13F FAQ explains (SEC, Form 13F FAQ); check each other form's instructions for its own rule. The 13F quarter, with the Schedule 13G, Form 13H and Form N-PX dates that share it, is laid out in 13F filing deadlines for 2026.
Recurring SEC deadlines for a registered investment adviser, 2027
| Obligation | Rule | Timing the rule sets | 2027 date (31 Dec year-end) |
|---|---|---|---|
| Form 13F for Q4 2026 | 17 CFR 240.13f-1 | 45 days after quarter end, for managers with $100 million or more in 13(f) securities | 16 Feb 2027 (45th day a Sunday; 15 Feb a federal holiday) |
| Form 13H annual amendment | 17 CFR 240.13h-1 | Within 45 days after each full calendar year, for large traders | 45th day: Sunday 14 Feb 2027 |
| Form ADV annual updating amendment | 17 CFR 275.204-1 | Within 90 days of fiscal year-end | 31 Mar 2027 |
| Brochure or summary of material changes to clients | 17 CFR 275.204-3 | Within 120 days of fiscal year-end, if the brochure materially changed | 30 Apr 2027 |
| Private fund audited financials to investors | 17 CFR 275.206(4)-2(b)(4) | Within 120 days of the fund’s fiscal year-end | 30 Apr 2027 |
| Form 13F for Q1, Q2 and Q3 2027 | 17 CFR 240.13f-1 | 45 days after each quarter end | 17 May, 16 Aug, 15 Nov 2027 |
| Form N-PX, votes for the year to 30 June 2027 | 17 CFR 240.14Ad-1 | By 31 August each year, for 13F filers | 31 Aug 2027 |
| Annual compliance review | 17 CFR 275.206(4)-7(b) | At least once a year, no gap longer than 12 months | Twelve months from the last review |
When is Form ADV due in 2027?
By 31 March 2027 for an adviser whose fiscal year ends on 31 December 2026. The rule requires the annual updating amendment to Parts 1 and 2 "at least annually, within 90 days of the end of your fiscal year" (17 CFR 275.204-1(a)), and Part 3, Form CRS, at the frequency its instructions require. Clients then receive the updated brochure, or a summary of material changes offering it, within 120 days of year-end, 30 April 2027, if the brochure changed materially (17 CFR 275.204-3).
The SEC staff's September 2026 risk alert found advisers whose regulatory filing procedures had never been updated for Form CRS, years after it was required. A calendar entry for Form ADV should therefore name all three parts, not "Form ADV" alone, and the procedure behind it should be checked whenever the form changes. The custody proposal of 6 October 2026, for example, would amend Form ADV if adopted (91 FR 63870).
When is Form N-PX due for a 13F filer in 2027?
By 31 August each year, covering say-on-pay and related shareholder votes for the 12 months to 30 June, for every institutional investment manager required to file Form 13F (17 CFR 240.14Ad-1). The next filing is due 31 August 2027 for the year to 30 June 2027. A manager filing its first 13F does not file N-PX for the 12-month period ending in the year that first 13F is due, and a manager that stops filing 13F still owes a short N-PX for July to September of its final year, due 1 March of the following year.
Regulation S-P amendments compliance date: both have passed
The amended Regulation S-P took effect on 2 August 2024 and gave larger entities 18 months and smaller ones 24 months from its Federal Register publication on 3 June 2024 (89 FR 47688). That made the compliance dates 3 December 2025 for larger entities, which for advisers means $1.5 billion or more in assets under management, and 3 June 2026 for smaller ones. Neither date moved.
On a 2026–27 calendar Regulation S-P is therefore not a deadline but a standing obligation to test: the incident response programme, customer notification within 30 days of becoming aware of unauthorised access to sensitive customer information, and service-provider contracts requiring notice within 72 hours. The SEC's fiscal 2027 examination priorities say staff will evaluate the response programme policies, including customer notification and oversight of service providers, under the amended rule.
The dates that moved in 2025 and 2026
Between March 2025 and October 2026, dates for advisers, funds and their brokers moved or were set by five notices. Two of them split one rule's dates in two, which is where calendars typed by hand go wrong.
Adviser and fund dates that moved, with the notice that moved them
| Obligation | Was | Now | Notice |
|---|---|---|---|
| Form PF, 2024 amendments | 1 Oct 2026 | 1 Jul 2027 (fourth move since March 2025) | 91 FR 56593, 3 Sep 2026 |
| Names Rule: Form N-PORT reporting only | With the rule’s compliance dates | 17 Nov 2027 for fund groups of $10 billion or more; 18 May 2028 for smaller groups | Federal Register, 23 Feb 2026 |
| Names Rule: the rule and prospectus disclosure | 11 Dec 2025 and 11 Jun 2026 | 11 Jun 2026 for groups of $1 billion or more (passed); 11 Dec 2026 for smaller groups | 90 FR 13076, 20 Mar 2025 |
| FINRA Rule 2210: projections and targeted returns | Prohibited, with exceptions | Approved by the SEC on 15 Oct 2026; effective date to be set by FINRA | 91 FR 66371, 20 Oct 2026 |
| FINRA Rule 4515.01: bulk order allocations | Principal approval of late allocations | Requirement removed from 16 Nov 2026 | FINRA Regulatory Notice 26-17 |
The Names Rule is the clearest case of a split. Its compliance date for larger fund groups arrived on 11 June 2026, but the Form N-PORT reporting it introduced was moved separately to 17 November 2027, and the size test for that reporting is $10 billion of net assets, not the $1 billion used for the rule itself. A single calendar line for "Names Rule" gets one of the two wrong. The allocation change matters for a different reason: an adviser that relied on its broker's principal review of late allocations should check its own allocation procedures before 16 November 2026; the post-trade allocation guide covers that change from the trading desk's side, and the 2026 FINRA Rule 2210 changes cover the projections change for an affiliate's marketing.
The dated items between now and mid-2028, on one line
- Comments: pay-to-play rescission (9 Nov)9 Nov
- FINRA 4515.01 change (16 Nov)16 Nov
- Comments: custody, fees, cross trades (7–14 Dec)7–14 Dec
- Names Rule, smaller groups (11 Dec)11 Dec
- Form ADV (31 Mar)31 Mar
- Brochures, audits (30 Apr)30 Apr
- Form PF amendments (1 Jul)1 Jul
- Form N-PX (31 Aug)31 Aug
- Names N-PORT, ≥$10bn (17 Nov)17 Nov
- Names N-PORT, smaller groups (18 May)18 May
SEC compliance dates for proposals still open
Proposals have no compliance dates, but they have comment deadlines, and an RIA calendar should carry them. Five touching advisers and funds were open on 28 October 2026: the proposal to rescind the political contribution rule, comments by 9 November (91 FR 57698); interval fund modernization, by 4 December; adviser and fund custody, by 7 December; adviser performance-based compensation, by 7 December; and investment company cross trading, by 14 December (91 FR 65622). The SEC reg flex agenda 2026 guide shows how each one reached the Federal Register.
"In addition, the Commission is modifying the operation of the compliance dates to allow for compliance based on the timing of certain annual disclosure and reporting obligations that are tied to the fund's fiscal year-end."
SEC, Investment Company Names; Extension of Compliance Date, 90 FR 13076
A compliance date can therefore depend on each fund's own fiscal year, which a single line on a shared calendar cannot show. Form PF adds a second pattern, a date moved while the rule itself is reconsidered, which is why its line belongs on two calendars at once: the build plan to July 1, 2027, and the proposal that could remove part of the build. The Form PF compliance date extension guide works through both.
The 2026 calendar so far: what passed between January and October
A 2026 calendar reviewed at year-end should show these items as done, with the evidence for each, or as decided not to act on, with a reason. Several were comment deadlines rather than compliance dates, and a calendar that carried only compliance dates would never have shown them.
Adviser and fund items dated between January and October 2026
| Date | Item | Kind | What the calendar should now show |
|---|---|---|---|
| 31 Mar 2026 | Notice of intent to raise the qualified client thresholds for inflation; hearing requests by 27 Apr | Notice | Whether the order followed, and the new thresholds in the performance fee procedure |
| 24 Apr 2026 | Comments closed on Form N-PORT reporting: 15 more days to file monthly, quarterly publication restored | Comment deadline | Proposal stage; no compliance date yet |
| 3 Jun 2026 | Regulation S-P amendments, smaller entities | Compliance date | In force for all advisers; incident response programme tested |
| 11 Jun 2026 | Names Rule, fund groups of $1 billion or more | Compliance date | In force for larger groups; Form N-PORT reporting still to come |
| 23 Jun 2026 | Comments closed on the Form PF proposal: $1 billion filing threshold | Comment deadline | Proposal stage; entities mapped against both thresholds |
| 3 Sep 2026 | Form PF amendments moved to 1 Jul 2027 | Date change | Build plan re-planned to the new date, with the history kept |
| 21 Sep 2026 | Comments closed on Regulation E-Delivery | Comment deadline | Proposal stage; delivery procedures flagged |
Proposals that could add dates to the 2027 calendar
None of the open proposals has a compliance date, and some may never be adopted. Each, if adopted, would bring its own compliance period, and a calendar for 2027 should hold a placeholder for each with an owner who watches it. The Form PF proposal, for instance, suggests "a minimum 12-month transition period" from publication of any final rule (91 FR 22232), so a final rule in 2027 would set a date in 2028 or later.
The others would touch different parts of the calendar. The custody proposal would amend Form ADV and Form N-CEN; the cross-trading proposal would add aggregated reporting of cross trades to Forms N-PORT and N-MFP; the performance-based compensation proposal would widen the qualified client definition to accredited investors and add disclosure of performance fees to regulated funds' forms (91 FR 63676); and the proposal on political contributions would remove the rule's prohibitions and the related record duties if adopted. A rescission is a calendar change too: the procedures and their annual tests come off.
How to keep an RIA compliance calendar current
Generate it from the change register instead of typing it, and re-check every date against the regulator's own notices each month. The checklist below is the routine that would have caught each moved date in this guide within days.
Keeping a compliance calendar current through the year
- Every date cites its rule or notice
A date without a citation cannot be re-checked when the regulator moves it.
- Split rules into their dated parts
A rule, its disclosure and its reporting can carry different dates and size tests.
- Read the Federal Register for date changes monthly
Extensions arrive as final rules titled "extension of compliance date"; the SEC filed four for Form PF alone.
- Carry comment deadlines for proposals
With an owner who decides whether the firm comments.
- Re-plan dependent tasks when a date moves
Same buffer to the new date, approved by a person, with the old date kept.
- Record dates that did not move
Regulation S-P’s dates held; a calendar that assumed otherwise was wrong.
- Include affiliates’ dates that change your procedures
FINRA changes for the broker-dealer affiliate and executing brokers.
A 20-month horizon with the moved dates and their history
A moved date reaches the change manager as one decision
To see your own adviser calendar generated from your regulators and entities, start from Regulatory Change Management for Asset Managers.
Questions people ask
What goes on an SEC compliance calendar for 2026?
For the rest of 2026: Form 13F for the third quarter by 16 November, five comment deadlines on adviser and fund proposals between 9 November and 14 December, and the Names Rule compliance date for smaller fund groups on 11 December. For advisers the Regulation S-P dates have already passed and the Form PF amendments have moved to 2027.
Is the Form PF compliance date still October 1, 2026?
No. A notice published on 3 September 2026 moved it to July 1, 2027, the fourth extension of the 2024 amendments. Until then filers use the version of Form PF in effect before those amendments.
When is the Form 13F deadline for the fourth quarter of 2026?
16 February 2027. The 45th day after 31 December is Sunday 14 February, and Monday 15 February is Presidents' Day, a federal holiday, so the report is due the next business day.
Do FINRA rule changes belong on an RIA compliance calendar?
When they change how the adviser's orders or communications are handled, yes. The Rule 4515.01 change effective 16 November 2026 alters how broker-dealers handle late allocations of advisers' bulk orders, and the approved Rule 2210 change on projections will apply to broker-dealer affiliates' communications once FINRA sets its effective date.
How often should an RIA update its compliance calendar?
Continuously from the change register, with a monthly check of every date against the regulators' notices. The Form PF date alone changed four times between February 2025 and September 2026, twice within five months.