Upcoming 2026 Form ADV Annual Updating Amendment

Avoiding Common Deficiencies in the 2026 Form ADV Annual Updating Amendment

As the 2026 filing season approaches, investment advisers should begin preparing their Form ADV Annual Updating Amendment. The SEC requires Exempt Reporting Advisers (ERAs), SEC-Registered Investment Advisers, and State-Registered Investment Advisers to file this amendment within 90 days of their fiscal year-end. For firms with a December 31 fiscal year-end, the 2026 filing deadline is March 31, 2026.

Form ADV is a publicly available disclosure document that is provided to clients and reviewed by regulators. It outlines key information about an adviser’s business, including services offered, fee structures, ownership, disciplinary history, and conflicts of interest. Because this information is relied upon by both clients and examiners, the accuracy and internal consistency across the Form ADV and other regulatory filings is critical.

What Must Be Updated

To be considered complete, the Form ADV Annual Updating Amendment must include updates to all applicable sections, including:

• Part 1A and Part 1B

• Part 2A (Firm Brochure)

• Schedules A, B, C, and D, as applicable

• Schedule R for each relying adviser, if applicable

Although Form ADV Part 2B (Brochure Supplement) is not always uploaded as part of the annual amendment, it must still be reviewed and updated annually to ensure information about supervised persons remains accurate.

How Coast to Coast Compliance Can Help

A common category of SEC examination deficiencies stems from inconsistencies or inaccuracies within Form ADV, particularly between different sections of the form or between Form ADV and other compliance documents. The annual updating amendment is an important opportunity to ensure all disclosures accurately reflect the firm’s current operations and practices.

Start Early to Avoid Issues

Beginning the review process early allows firms time to identify changes, reconcile disclosures across documents, and address potential issues before filing. Coast to Coast Compliance can proactively assist preparing your firm to help reduce regulatory risk from noncompliance with SEC expectations ahead of the March 31, 2026 deadline.

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