RIA compliance calendar for 2027

For an SEC-registered adviser with a December 31 fiscal year end, the fixed dates of 2027 start with the IARD renewal Final Statement on 22 January, run through the Form ADV annual updating amendment on Wednesday 31 March and brochure delivery on Friday 30 April, and come back every quarter for code of ethics transaction reports and, for firms that file them, Form 13F, Schedule 13G amendments and Form PF. Some obligations apply to every registered adviser, and others only once a firm crosses a threshold or advises a particular kind of client.

This guide lists the dates a rule actually fixes, computed for 2027, and then the recurring obligations that have no fixed date but still belong on the calendar. Every date below assumes a fiscal year ending on December 31. If yours ends on another date, the method section explains how to move them.

How the dates are counted

Most adviser deadlines run in calendar days from a fixed point: the end of your fiscal year, the end of a calendar quarter, or an event. Two rules decide what happens when the last day is not a working day.

• Filings made through IARD. Under Advisers Act Rule 0-4(a)(2), a filing due on a day the IARD is closed is timely if it is filed the following business day. Under Rule 0-4(a)(3), a filing due during the IARD's December shutdown is timely if it is filed by the following 7 January.
• Filings under the Exchange Act. Form 13F, Schedule 13G, Form 13H and Form N-PX are Exchange Act filings. Exchange Act Rule 0-3(a) says that if the last day for a timely filing falls on a Saturday, Sunday or holiday, the filing may be made on the first business day after it. The staff's Form 13F FAQ applies that rule to the 13F deadline.

Internal deadlines, such as code of ethics reports that go to the firm rather than to the SEC, are not filings with the Commission, so neither rule moves them. When one falls on a weekend, the practical answer is to collect it before the weekend.

Among the Exchange Act dates in 2027, one federal holiday matters: Washington's Birthday falls on Monday 15 February, the day after the fourth-quarter 13F deadline lands on a Sunday.

The 2027 calendar, month by month

The table gives each date, what is due and the rule behind it. A date in brackets is the calendar-day count before any weekend adjustment.

Three Form PF dates fall on a Sunday. The Form PF instructions count calendar days and do not themselves say what happens on a weekend, so confirm the treatment with the Private Fund Reporting Depository's guidance before relying on the following Monday.

The filings, one at a time

Form ADV annual updating amendment: 31 March

Rule 204-1(a)(1) requires an adviser to amend Parts 1 and 2 of Form ADV at least annually, within 90 days of the end of its fiscal year. For a December 31 year end that is Wednesday 31 March 2027. The annual IARD filing fee is paid with it, and FINRA will not accept the amendment until the fee is paid. Part 3, Form CRS, follows its own timetable, described below. The guide to the Form ADV annual amendment covers what to update and how regulatory assets under management are counted.

Brochure delivery: 30 April

Rule 204-3(b)(2) requires an adviser whose brochure has changed materially since the last annual updating amendment to deliver, within 120 days of fiscal year end, either the current brochure or a summary of material changes that offers it. For a December 31 year end that is Friday 30 April 2027. If nothing material changed, nothing has to be delivered. See the guide to Form ADV Part 2.

IARD renewals: January and again in November

The renewal program for 2027 registrations began in 2026. Under FINRA Regulatory Notice 26-22 and the IARD's 2027 renewal calendar, Preliminary Statements were available on 9 November 2026, payment was due on 7 December 2026, and the last day to submit registration filings before year end is Monday 28 December 2026. IARD is then unavailable for renewals processing on 29 December and 1 January, and available for queries and pending filings only on 30 and 31 December. Final Statements are available on Saturday 2 January 2027, and the deadline for Final Statement payments and discrepancy reports is Friday 22 January 2027.

The renewal program for 2028 will run in November and December 2027. FINRA has not published those dates yet. For the 2027 program, the IARD posted its renewal calendar in August 2026 and FINRA issued its Regulatory Notice in October 2026.

Code of ethics reports: 30 days after each quarter

Rule 204A-1(b)(2)(ii) requires each access person to submit a transaction report no later than 30 days after the end of each calendar quarter. In 2027 those dates are 30 January, 30 April, 30 July and 30 October; the first and last are Saturdays. A report is not needed where it would duplicate broker confirmations or statements the firm already holds, as long as the firm receives them within the same 30 days.

Holdings reports are due within 10 days of becoming an access person and then at least once in each 12-month period, on a date the firm selects, with information current as of no more than 45 days before the report is submitted. Because the firm chooses the annual date, it does not appear in the table, but it should appear on the firm's own calendar. The guide to code of ethics requirements explains the reports and the exceptions.

Form 13F: 45 days after each quarter

Rule 13f-1 requires an institutional investment manager whose accounts hold section 13(f) securities at or above the rule's threshold, on the last trading day of any month of a calendar year, to file Form 13F within 45 days after that calendar year ends and within 45 days after each of the first three quarters of the following year. Applying Rule 0-3, the 2027 deadlines are Tuesday 16 February, Monday 17 May, Monday 16 August and Monday 15 November.

Schedule 13G: quarterly since 2024

The Commission's October 2023 amendments to the beneficial ownership rules moved Schedule 13G to a quarterly rhythm. A registered investment adviser filing as a qualified institutional investor under Rule 13d-1(b) files its initial Schedule 13G within 45 days after the end of the calendar quarter in which it became obligated, measured by its ownership at quarter end, unless it passes 10 percent of the class before the quarter ends, in which case it files within five business days after the end of the first month in which it did. Under Rule 13d-2(b), amendments are due within 45 days after the end of each calendar quarter in which there is a material change in the information previously reported. The quarterly amendment dates in 2027 match the 13F dates.

Form 13H: 45 days after year end

A large trader, as defined by the identifying activity level in Rule 13h-1, files Form 13H annually within 45 days after the end of each full calendar year, and amends it promptly after the end of any calendar quarter in which the information has become inaccurate. The annual filing for 2026 is due Tuesday 16 February 2027 under Rule 0-3.

Form PF

Form PF is required of SEC-registered advisers to private funds with private fund assets at or above the threshold in Rule 204(b)-1. Under Instruction 9 of the form:

• Large hedge fund advisers file a quarterly update within 60 calendar days after the end of each calendar quarter.
• Large liquidity fund advisers file within 15 calendar days after the end of each calendar quarter.
• All other filers file an annual update within 120 calendar days after fiscal year end: Friday 30 April 2027 for a December year end.
• Advisers to private equity funds file an event report in Section 6 within 60 calendar days after the end of each fiscal quarter in which a reporting event occurred, and large hedge fund advisers file current reports in Section 5 within the time the form sets for each event.

On 3 September 2026 the SEC and CFTC extended the compliance date for the February 2024 Form PF amendments, for the fourth time, to 1 July 2027 (Release IA-6992). Until then, filers may continue to use the version of the form in effect before those amendments. The Commissions said the delay was to avoid the cost of building reporting that a separate April 2026 proposal might substantially revise, so this date may move again.

Form N-PX: 31 August

Rule 14Ad-1 requires every institutional investment manager that files Form 13F to file an annual report on Form N-PX of its say-on-pay votes no later than 31 August, covering the 12 months ended 30 June. A manager does not file for the 12-month period ending 30 June of the year in which its first 13F filing falls due.

Audited financial statements for pooled vehicles: 30 April

An adviser that uses the audit approach under Rule 206(4)-2(b)(4) for a limited partnership or other pooled vehicle must distribute audited GAAP financial statements to all investors within 120 days of the fund's fiscal year end. For a fund with a December year end that is Friday 30 April 2027. The auditor must be registered with, and subject to regular inspection by, the PCAOB. See the custody rule explained.

Annual privacy notice

Regulation S-P requires an annual privacy notice "not less than annually" during the customer relationship, meaning at least once in any 12 consecutive months the firm defines and applies consistently (17 CFR 248.5(a)). Under paragraph (e), a firm need not deliver it if it shares nonpublic personal information with nonaffiliated third parties only under the exceptions in sections 248.13, 248.14 and 248.15, and has not changed the disclosure policies described in its most recent notice. A firm that does use the calendar year as its period, and does not meet the exception, delivers by 31 December.

Obligations with no fixed date

These do not come from a calendar-day count, but each needs a date on the firm's calendar.

• Annual compliance review. Rule 206(4)-7(b) requires a review "no less frequently than annually." The rule sets no month, but the Division of Examinations' 14 September 2026 Risk Alert lists gaps between reviews and review periods longer than 12 months among its observations. See the annual compliance review checklist.
• Custody surprise examination. Where Rule 206(4)-2(a)(4) applies, the independent accountant verifies client assets at least once each calendar year, at a time it chooses without notice and that varies from year to year, and files Form ADV-E within 120 days of that time. The adviser cannot set the date, but it can calendar the engagement letter and the account list it gives the accountant.
• Form CRS. Form CRS is not tied to the annual amendment. It is amended within 30 days whenever information in it becomes materially inaccurate, and existing retail investors are told of the changes within 60 days of when the amendment was required. See Form CRS requirements.
• Other Form ADV amendments. The Form ADV instructions require prompt amendments between annual filings when certain items change.
• Regulation S-P incident response. Smaller entities' compliance date for the 2024 amendments was 3 June 2026, so 2027 is the first full calendar year in which every SEC-registered adviser operates under them. The incident response program, the 30-day customer notice and service provider oversight have no calendar date; they run from events. See the Regulation S-P compliance checklist.
• Schedule 13G triggers within a quarter. The five business day filings for passive investors and for qualified institutional investors that cross 10 percent run from the event or the month end, not from quarter end.

If your fiscal year does not end on December 31

Every date in this guide that runs from fiscal year end moves with your fiscal year: Form ADV (90 days), brochure delivery (120 days), the Form PF annual update (120 days) and the pooled vehicle audit (120 days from the fund's own fiscal year end, which may differ from the adviser's). Count the days from your actual year end. Dates that run from calendar quarters or the calendar year, such as Form 13F, Schedule 13G amendments, Form 13H, Form N-PX and code of ethics transaction reports, do not move.

Common questions

When is Form ADV due in 2027?

For a fiscal year ending 31 December 2026, the annual updating amendment is due within 90 days, which is Wednesday 31 March 2027. Brochure delivery to existing clients, if the brochure changed materially, follows within 120 days, by Friday 30 April 2027.

What happens if a filing deadline falls on a weekend?

For IARD filings, Rule 0-4(a)(2) treats a filing as timely if it is made the next business day after a day the IARD is closed. For Exchange Act filings such as Form 13F, Rule 0-3(a) allows filing on the first business day after a Saturday, Sunday or holiday. Internal deadlines, such as code of ethics reports, do not move.

When are the 2027 Form 13F deadlines?

Tuesday 16 February, Monday 17 May, Monday 16 August and Monday 15 November 2027. Each is 45 days after the quarter ends, moved to the next business day under Rule 0-3 because the 45th day falls on a weekend or, in February, next to a federal holiday.

Does every RIA need to file Form 13F or Form PF?

No. Form 13F applies to managers whose accounts hold section 13(f) securities at or above the Rule 13f-1 threshold, and Form PF to advisers whose private fund assets meet the Rule 204(b)-1 threshold. Many advisers file neither, but should check each year against their own holdings and assets.

When is the annual compliance review due?

Rule 206(4)-7 does not fix a date. It requires the review at least annually, so most firms choose a month and keep to it, completing each review no more than 12 months after the last.

Put the year on one calendar

Luna's compliance calendar is free and seeds the obligations that fit your registration type, with the IARD renewal dates and the rule behind each entry, and reminds the person who owns each one before it is due. The regulatory filings policy template sets out who prepares and reviews each filing. For the program behind the calendar, see chief compliance officer duties and books and records requirements.