The annual compliance calendar for a registered investment adviser is not a single document — it is a composite of SEC filing deadlines, state filing deadlines, ongoing review obligations, examination preparation cycles, and internal review schedules mandated by Rule 206(4)-7. Managing these obligations effectively requires mapping them to the actual calendar year, assigning ownership, and building review buffer time. This reference covers the primary federal filing and review obligations for 2025–2026. State-level requirements vary and are not addressed here. Nothing in this article constitutes legal advice.
Q1: January Through March
Form ADV Annual Amendment — March 31 Deadline
Under Rule 204-1(a), SEC-registered investment advisers must file an annual updating amendment to Form ADV within 90 days of the end of the fiscal year. For firms with a December 31 fiscal year end — the most common for RIAs — the deadline is March 31. The annual amendment must update all items that have changed and must include a current version of Part 2A (the "brochure") and Part 2B (the brochure supplement for supervised persons who provide investment advice and have direct client contact).
The annual ADV amendment is also the trigger for the annual delivery obligation. Under Rule 204-3(b)(2), advisers must deliver to each client, within 120 days of fiscal year end (April 30 for December 31 fiscal year advisers), either a copy of the updated Part 2A or a summary of material changes along with an offer to provide a copy. If no material changes occurred, the adviser may provide just the summary with the offer to provide the full brochure; if material changes occurred, delivery of the updated brochure itself is required.
Form CRS — the Client Relationship Summary required for registered investment advisers under Regulation Best Interest — must also be updated when any information in it becomes materially inaccurate. The annual ADV process is a natural checkpoint for reviewing Form CRS accuracy.
Annual Review Under Rule 206(4)-7 — First Quarter Planning
Rule 206(4)-7 requires each registered investment adviser to review the adequacy of its compliance policies and procedures no less frequently than annually. While the rule does not specify when in the year this review must occur, CCOs typically conduct the annual review in Q1 using the prior calendar year as the review period. A well-documented annual review covers: whether any material violations of the compliance program occurred; whether any regulatory developments during the year require policy updates; whether the firm's risk profile has changed in a way that requires additional procedures; and whether testing of the program revealed weaknesses requiring remediation.
The SEC's Division of Examinations publishes its examination priorities annually, typically in January or February. For CCOs conducting a Q1 annual review, this is essential reading. The 2024 examination priorities document identified Marketing Rule compliance, cybersecurity practices, and adviser custody as focus areas. The 2025 priorities document continued to emphasize compliance with the Marketing Rule, particularly testimonials and performance advertising, and added increased attention to the treatment of retail investors and dual registrant conflicts of interest. These priority areas should inform risk assessments for the annual review.
Q2: April Through June
April 30 — ADV Part 2 Delivery Deadline
As noted above, the 120-day window for either delivering an updated Part 2A or delivering a summary of changes with an offer closes April 30 for December 31 fiscal year firms. This is an operationally significant deadline: it requires that the CCO have a current client list as of a date certain, that the delivery mechanism (mail, email, or client portal) be ready, and that a delivery record be created and retained under Rule 204-2.
We are not saying that email delivery is problematic — it is the most common delivery method and is permissible if the adviser has reasonable grounds to believe the client has access to email and the client has not indicated a preference for paper delivery. But the delivery record must be adequate. An email with a read receipt is evidence of delivery; a mass email to a distribution list with no individual tracking is weaker evidence and may not satisfy the requirement in an examination context.
Mid-Year Marketing Material Review
While not required by a specific rule deadline, a mid-year review of marketing materials is a best practice for firms with active marketing programs. The Marketing Rule requires that any new advertisement be reviewed before use, but it does not require ongoing review of materials that were pre-approved and remain in use. In practice, materials that were reviewed in early 2024 should be reviewed again against current standards in mid-2025, particularly if: the firm's performance track record has changed; a new testimonial or endorsement arrangement has been entered into; or the SEC or FINRA has issued new guidance or risk alerts on advertising practices.
The Division of Examinations has issued risk alerts on Marketing Rule compliance. When a risk alert identifies a specific deficiency pattern — for example, performance presentations lacking net return figures — a mid-year review of materials is the appropriate CCO response. Not acting on a published risk alert, and then having the same deficiency identified in an examination, is a particularly avoidable outcome.
Q3: July Through September
State Notice Filing Review
SEC-registered advisers who conduct business in multiple states must file notice filings with each state in which they have clients above the de minimis threshold. State de minimis thresholds vary, but many states use the SEC's threshold of 5 clients from that state before a notice filing is required. State notice filings are typically renewed annually through the IARD system. The timing varies by state — some states require renewal before the first calendar quarter, others follow different schedules.
Q3 is a practical time to audit state notice filing status: confirm which states have active notice filings, identify any states where the client count has crossed the de minimis threshold since last review, and confirm that renewal fees have been paid and filings are current. IARD system access allows advisers to view their current notice filing status by state. Failing to maintain a required state notice filing is a compliance deficiency and, in some states, a registration violation.
Cybersecurity Program Review
Rule 206(4)-9 — the Investment Adviser Cybersecurity Rule, adopted by the SEC in August 2023 — requires registered investment advisers to adopt and implement written policies and procedures reasonably designed to address cybersecurity risks. The compliance date for most registered advisers was August 26, 2024, meaning that by Q3 2025, advisers should have had their cybersecurity programs operational for approximately one year. A Q3 review should assess: whether significant security incidents have occurred and been documented; whether annual training has been conducted; whether the risk assessment is current; and whether any required SEC reporting obligations have been triggered. Rule 206(4)-9 requires prompt reporting to the SEC of significant cybersecurity incidents on Form ADV-C, filed within 48 hours of determining that a significant cybersecurity incident has occurred.
Q4: October Through December
Year-End Compliance Program Preparation
Q4 is the planning period for the annual review that will be conducted in Q1 of the following year. A CCO conducting a December year-end review preparation should: compile the testing results from the prior year's periodic reviews; identify open remediation items from any examination findings or internal audits; update the compliance risk assessment to reflect changes in firm personnel, products, and business activities; and confirm that written policies and procedures reflect regulatory developments during the year.
Regulatory developments in 2024 that require policy review for 2025 programs include: the Implementation of the Marketing Rule's ongoing examination focus (risk alerts from late 2024); the cybersecurity rule compliance obligations (effective August 2024); and any guidance issued by the Division of Examinations on the evolving interpretation of Rule 206(4)-1's testimonial and endorsement requirements. Rule amendments or guidance that were effective after the prior year's annual review must be incorporated into written procedures before the current year closes.
Form ADV Part 1 Material Change Updates — Year-Round Obligation
While Form ADV's annual amendment is due March 31, Rule 204-1(b) requires prompt amendment to Part 1 — within 30 days — whenever any information in Part 1A becomes materially inaccurate. This is a year-round obligation, not an annual one. Material changes include changes in AUM above or below registration thresholds, changes in the identity or control of the firm, disciplinary events, and changes in the adviser's business activities. The annual amendment also provides an opportunity to clean up Part 1 items that should have been updated during the year.
Similarly, Part 2A must be updated promptly when information in the brochure becomes materially inaccurate — not only at the annual amendment. A change in fee schedule, the addition of a new service offering with different conflicts of interest, or a material change in investment strategy should trigger a brochure update and delivery. An adviser that delivers an April 30 brochure but then makes a material change in August without updating and delivering the brochure has a compliance deficiency regardless of the annual deadline being satisfied.
Examination Preparedness as an Ongoing Practice
The Division of Examinations operates on a risk-based schedule. Newly registered advisers are typically examined within the first three years. For established advisers, the cycle has historically been every three to seven years for smaller firms, though it may shorten for firms identified as higher-risk. A firm that structures its compliance calendar around an assumption that examination is years away is taking a meaningful risk. Examination preparedness means maintaining records in a state where they can be produced within the Division's standard initial response window — often 10 business days. A CCO who has a written examination response protocol, who knows where the firm's records are and can pull them on short notice, is better positioned than one who treats exam readiness as an event rather than an ongoing condition. The compliance calendar is the mechanism that keeps the firm in that state year-round.
Nothing in this article constitutes legal advice. Filing deadlines and regulatory requirements are subject to change. State-specific requirements are not addressed in this reference. Consult qualified legal counsel for compliance obligations specific to your firm's registration, structure, and state operations.