Guidance November 17, 2025

SEC Division of Examinations Announces Fiscal Year 2026 Examination Priorities

On November 17, 2025, the SEC's Division of Examinations announced its fiscal year 2026 examination priorities, identifying the areas where examiners will focus during the 2026 exam cycle.

## Key Focus Areas

The priorities emphasize investment adviser fiduciary duty and standards of conduct, conflicts of interest, the Compliance Rule (Rule 206(4)-7), anti-money laundering, cybersecurity, Regulation S-P and Regulation S-ID (privacy and identity theft), emerging financial technology including AI-related representations, and Regulation SCI.

The Division continues to emphasize protecting retail investors, examining newly registered and never-before-examined advisers and funds, and broker-dealer compliance with Regulation Best Interest.

## A Shift in Emphasis

Notably, the 2026 priorities drop crypto assets and private fund advisers as standalone priority headings — a shift from prior years. These were the first examination priorities issued under the SEC's current leadership.

Firms should review their compliance programs against the published priorities — particularly conflicts of interest, the Compliance Rule, cybersecurity, and AI-related claims — and address any gaps ahead of their examination cycle.

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