When Is Form ADV Due?

Registered investment advisors are subject to SEC rules, and there are several important regulatory deadlines to be aware of. These deadlines determine when specific forms must be submitted to the SEC to meet compliance requirements. Are you wondering: When is Form ADV due? What’s the deadline for filing annual cybersecurity disclosures? Below is a list of some of the most important filing deadlines registered advisors should be aware of.

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SEC Filing Requirements for Registered Advisors

An advisor researching when Form ADVs are due.

SEC-registered advisors must meet certain filing requirements throughout the year. The Securities and Exchange Commission sets the deadlines for individual forms.

Missing a deadline might seem like a minor misstep, but it can have serious consequences for advisors. The SEC can initiate an investigation into your firm and penalize you with monetary fines. Missed deadlines can also damage your firm’s brand reputation, making it difficult to retain your existing clients and attract new ones.

In a worst-case scenario, noncompliance with SEC filing deadlines may result in lawsuits, legal action or forfeiture of your registration status with the SEC.

SEC Annual and Quarterly Filing Deadlines

The SEC has an extensive list of annual filing requirements for registered individuals and entities, though not all of them may apply to you. The following are some of the most important filing deadlines that registered advisors should know in order to remain compliant:

Form	Purpose	Filing Deadline
Form ADV Annual Updating Amendment	Form ADV includes material information about your firm’s structure, fees, ownership and operations	90 days from the end of the firm’s fiscal year
Form ADV Part 3 (Form CRS) Updating Amendment	Form ADV Part 3 is a written disclosure RIAs and broker-dealers must provide when offering advisory services	30 days from any material changes
Form 3	Form 3 is required when someone becomes an insider, and is used to disclose their ownership of company securities	10 days from the date the person becomes an insider
Form 4	Form 4, Statement of Changes in Beneficial Ownership, must be filed when there is a material change in the holdings of company insiders, such as directors, officers and significant shareholders	Within two days of the transaction date
Form 5	Form 5 must be filed when insiders conduct transactions in the company’s securities	45 days from the end of the fiscal year
Form 8-K	Form 8-K is used to disclose material events that shareholders should be aware of, such as the acquisition of assets or a bankruptcy filing	Within four business days after the occurrence of a triggering event, with some exclusions
Form 10-K (Annual Report)	Form 10-K offers a comprehensive overview of a company’s operations, performance and risks, including cybersecurity risks	Large accelerated filer: 60 days after the end of the fiscal quarter Accelerated filer: 75 days after the end of the fiscal quarter Non-accelerated filer: 90 days after the end of the fiscal quarter
Form 10-Q (Quarterly Report)	Form 10-Q is a quarterly report disclosing business performance and operations for the previous fiscal quarter	Large accelerated filer: 40 days after the end of the fiscal quarter Accelerated filer: 40 days after the end of the fiscal quarter Non-accelerated filer: 45 days after the end of the fiscal quarter
Form PF	Private fund advisors use Form PF to report regulatory assets under management	120 days after the end of the firm’s fiscal year

There are other deadlines you may need to be aware of, depending on your registration status and the type of services you offer. Note that these are federal deadlines only; state regulatory authorities may have additional filing requirements and deadlines you’ll need to meet.

Frequently Asked Questions (FAQs)

When Is Form ADV Due?

Form ADV is due 90 days after the end of the fiscal year. For 2024, registered advisors were required to submit their Form ADV to the SEC by March 30.

What Forms Are Registered Advisors Required to File With the SEC?

Advisors registering with the SEC for the first time are required to submit Form ADV. Parts I and II are submitted to the SEC while Part III, the Customer Relationship Summary (CRS), is submitted through the Investment Adviser Registration Depository (IARD).

What Do I Do if I Miss an SEC Filing Deadline?

Advisors have up to 24 hours after the day of the initial deadline to submit any required forms. This is known as a non-timely filing, and you must explain the reason why you missed the deadline. The SEC may waive penalties for late filings that have a reasonable explanation.

Bottom Line

Establishing an annual compliance calendar can make it easier to plan when Form ADV is due, among other filings.

SEC deadlines exist for a reason, and it’s important to keep track of them to ensure you’re meeting filing requirements on time. Establishing an annual compliance calendar can make it easier to plan your filings ahead of time, so you don’t risk missing an important due date.

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Aside from filing deadlines, there are other SEC compliance rules registered advisors should know. Some of the newest rule additions include the SEC’s guidance on cybersecurity incident reporting and the marketing rule. Monitoring compliance trends can help you better prepare for new rules as they emerge.