SEC’s 2026 Exam Priorities: What RIAs Need to Know (and What’s New This Year)

The SEC recently published its 2026 Exam Priorities, and for registrants, the message is clear. If 2025 was about identifying risks, 2026 is about proving you can manage them. Investor protection, operational resilience, and supervision will define the regulatory landscape in the year ahead.

The 2026 Exam priorities indicate how the SEC will evaluate compliance programs, technology use, disclosure and overall governance.

The list of SEC Exam Priorities include:

• Adherence to Fiduciary Standards of Conduct
• Effectiveness of Advisers’ Compliance Programs

• Governance and Disclosures
• Fees and Expense Structures
• Portfolio Management and Investment Strategy Alignment
• Complex, Illiquid, or Novel Investments
• Corporate Actions and Transactions
• New or Never-Examined Funds

• Never‑Examined Advisers and Recently Registered Advisers

• Broker‑Dealer Financial Responsibility Rules
• Broker‑Dealer Trading‑Related Practices and Services
• Retail Sales Practice, Including Compliance with Regulation Best Interest

What’s New or Different for Investment Advisers in 2026

Although many themes from last year remain, there are several important shifts that advisers should pay attention to.

1. Stronger Scrutiny of Newly Registered and Never-Before-Examined Advisers

New and young firms are receiving significantly more attention this year. While the SEC has always included them in its risk models, the 2026 priorities elevate them to a focal point. The Commission is clearly concerned that newer advisers may have:

• immature or incomplete compliance programs,
• rapid growth that outpaces governance,
• insufficient documentation,
• weak conflict-of-interest controls,
• limited oversight of third-party managers, platforms, or custodians, and
• novel business models involving alternative strategies, digital advice, or automated tools.

The SEC expects robust policies, procedures, and risk management from day one, raising the standard for compliance throughout the industry.

2. Technology and AI Risk Is Now a Core Part of Adviser Oversight

Cybersecurity remains a major priority, however, the 2026 priorities show that AI integration and risk management will be a key focus area in 2026. The SEC will pay close attention to:

• AI tools used for portfolio management or client recommendations,
• automated algorithmic decision-making,
• disclosures about technology use and its limitations,
• vendor and cloud-service risk,
• incident response readiness, and
• whether compliance teams understand and supervise the technology they rely on.

Advisers should expect examiners to test whether tools are used as described and whether they align with fiduciary duty and suitability standards.

3. A Deeper Dive into Conflicts, Fees, and Fiduciary Duty

Conflicts of interest, especially as they pertain to compensation, revenue sharing, affiliate relationships, and product selection, remain a key area of focus particularly for firms managing retirement accounts and sophisticated funds managing retail accounts.

4. A New Emphasis on Self-Regulatory Organizations (SRO)

The SEC’s 2026 Exam Priorities highlight an increased focus on self-regulatory organizations (SROs) and key market participants. The SEC will assess National Securities Exchanges for compliance with SRO rules and federal securities laws, including their participation in National Market System Plans.

FINRA will be examined through a risk-based program evaluating its regulatory programs, market regulation functions, advertising reviews, member examinations, and implementation of investor protection initiatives such as Regulation Best Interest and Form CRS. The Municipal Securities Rulemaking Board (MSRB) will also be subject to targeted risk-based reviews.

Beyond SROs, the SEC will examine market participants such as clearing agencies, municipal advisors, and transfer agents, with attention to fiduciary duties, compliance programs, recordkeeping, risk management, and adherence to Regulation S-P.

This strategic shift indicates that oversight is not limited to individual firms but extends to the organizations that regulate them.

This focus on SROs can indirectly affect RIAs and other practitioners such as more stringent reporting requirements or tighter compliance expectations.

Firms should monitor SRO updates and risk alerts closely, because any changes may require rapid adjustments in the firm’s policies and procedures.

The SEC’s priorities for 2026 indicate that compliance is no longer just about ticking boxes. It is about building resilient, well-governed firms that can manage risks across both internal operations and the broader market ecosystem.

For RIAs, this means adopting strong policies, maintaining supervisory controls, and vigilant oversight of technology and third-party relationships.

Those who take a proactive approach will not only reduce regulatory risk but also strengthen client trust and position their firms for sustainable success in a rapidly evolving market.

For assistance with updating your compliance program or prepare for an SEC Examination, please contact us at 619.298.2880 or email [email protected].