A well-organized annual compliance calendar is the foundation of an effective registered investment adviser compliance program. The following checklist organizes key compliance obligations by quarter for the 2026 calendar year, helping chief compliance officers and their teams stay ahead of regulatory deadlines and demonstrate a proactive approach to compliance during SEC examinations.
First Quarter Priorities
First quarter priorities center on annual filings and program assessment. Advisers must file their annual Form ADV amendment within 90 days of fiscal year-end, with most firms targeting a March 31 deadline. This includes updating Part 1A, Part 2A (the brochure), and Part 2B (brochure supplements) to reflect any material changes. Firms must also deliver updated brochures to existing clients or provide a summary of material changes along with an offer to deliver the full brochure. Additionally, Q1 is the ideal time to complete the annual compliance review required under Rule 206(4)-7.
Additional Q1 Tasks:
- Filing Form PF for advisers to private funds (within 120 days of fiscal year-end)
- Completing the annual update to the firm compliance policies and procedures manual
- Conducting the annual code of ethics certification and personal trading report collection
- Submitting Schedule 13F filings for institutional investment managers
- Verifying state registration renewals
Second Quarter Priorities
Second quarter priorities shift to mid-year testing and training. Firms should conduct interim testing of key compliance procedures, including advertising review, best execution analysis, and trade allocation processes. Q2 is also an ideal time to deliver compliance training to advisory personnel, covering topics such as Marketing Rule requirements, insider trading prevention, cybersecurity awareness, and client privacy. Firms should also review and update their business continuity plans to reflect any organizational or technological changes.
Third Quarter Priorities
Third quarter activities include preparing for the annual compliance review that will be documented in Q4 or early Q1 of the following year. Firms should begin gathering data on advertising review completions, personal trading compliance rates, client complaint trends, and any regulatory developments that may require policy updates. Q3 is also the time to conduct the annual cybersecurity risk assessment, test incident response procedures, and verify that vendor due diligence files are current.
Fourth Quarter Priorities
Fourth quarter tasks close out the year with critical deadlines and forward planning. Advisers must ensure that custody-related annual audit reports are on track for timely delivery if the firm has custody of client assets under the surprise examination or audit approach. State registration renewals processed through IARD are typically due in Q4. Firms should finalize their compliance testing for the year, document findings and remediation actions, and begin drafting the annual compliance review report.
Year-Round Ongoing Obligations
Throughout all four quarters, firms should maintain ongoing obligations including:
- Monitoring and reviewing marketing materials before use
- Processing personal trading pre-clearance requests and reviewing quarterly transaction reports
- Maintaining accurate books and records
- Responding to client complaints within required timeframes
- Monitoring for regulatory developments that may require policy or procedure updates
Customization for Your Firm
This checklist should be customized to the firm specific business activities, regulatory registrations, and client base. Firms with private fund clients, ERISA plan clients, wrap program sponsors, or municipal advisor registrations will have additional obligations not captured in this general framework. The checklist should be reviewed and updated annually to reflect changes in regulatory requirements and firm operations.