The US Securities and Exchange Commission Division of Examinations has published its rundown of Examination Priorities for Fiscal Year 2026. The 2026 Exam priorities provide insight into the items the Division will focus on in the upcoming year. Reviewing the priorities will allow CCOs to assess their programs in these areas of potentially heightened risk, ensuring they have the required policies, procedures, and controls in place—and that there are systems to easily evidence compliance.
The SEC Division of Examinations 2026 Examination Priorities outline the agency's strategic approach, direction and priorities for the upcoming year across types of regulated market participants. The priorities include the Division’s assessment of key risks, issues, and policy matters related to market and regulatory developments.
“In this increasingly complex and changing financial and regulatory environment, we strive to improve compliance in a way that is both transparent and practical.”
—Keith Cassidy, Acting Director of the Division of Examinations
The leadership of the current administration reinforced its commitment to advancing four core pillars:
The 2026 priorities confirm that, even working with fewer resources, the agency under the leadership of Chair Paul S. Atkins remains committed to conducting exams and taking a risk-based approach to enforcement. In the press release accompanying the priorities, Atkins notes, “examinations are an important component to accomplishing the agency’s mission, but they should not be a 'gotcha' exercise. Examination priorities should enable firms to prepare to have a constructive dialogue with SEC examiners and provide transparency into the priorities of the agency.”
Core areas of focus for exams in 2026 include fiduciary duty, standards of conduct and the custody rule. The Division will also continue to prioritize examinations of newly registered advisers and investment companies, with the expectation that these firms will build robust compliance programs.
The priorities note that "market participants are navigating an increasingly complex and changing financial and regulatory environment." They also reinforce that every firm is responsible for maintaining a robust compliance program.
Firms should be aware that other areas will be covered in exams depending on an individual firm's business practices and risk profile, and that Division exam priorities may shift in response to new and emerging risks, market events or investor concerns.
The agency will continue to examine how investment advisers adhere to fiduciary standards of conduct, focusing on the suitability of investment advice, the impact of conflicts of interest on providing financial advice, investment products that are alternative, complex, or high-cost and the consistency of disclosures. Advisers to private funds can expect to be examined to see if disclosures are consistent with actual practices.
Exams will also focus on types of advisers, services and practices that may create additional risks or conflicts of interest, including dual registrants, advisers utilizing third parties, and recent mergers and acquisitions which may result in operational or compliance complexity and generate new conflicts of interest.
Continuing the trend from previous years, examinations of newly registered advisers, those who have never been examined, and those who have not been examined in a while will continue to take priority.
Read about Compliance Pitfalls for Newly Registered Investment Advisers.
A continued agency priority because of their importance to retail investors, registered investment companies (RICs or funds) will be reviewed for the soundness of their compliance programs, disclosures, filings and governance practices. Focus may include fees and expenses , portfolio management practices, and disclosures.
The Division will monitor developing areas of interest, including RIC participation in mergers and acquisition activity, complex investment strategies and novel strategies and investments. As with Adviser exams, the agency will continue to prioritize never-examined and newly registered firms.
For broker-dealers, top priorities include compliance with the net capital rule and consumer protection rule along with related processes and controls. Reviews will also focus on operational resiliency, including supervision of third-party or vendor services, risk management controls and cash sweep programs and prime brokerage activities.
Other priorities include compliance with Regulation Best Interest (Reg BI) and the use of Form CRS, as well as the financial responsibility rules and trading-related practices and services.
Exams may also focus on dual registrants and how these firms identify and mitigate conflicts of interest.
The Division will examine the compliance programs, policies and procedures, risk management, operational resilience, and third-party relationships of other market participants, including municipal advisors, transfer agents, funding portals, security-based swap dealers and security-based swap execution facilities, focusing on oversight and governance as well as the protection of customer assets and data.
The risk areas impacting various market participants are broken down into four key categories:
The Division continue to monitor the use of emerging financial technologies, including artificial intelligence, automated investment tools, trading algorithms and platforms, and alternative data sources, with a particular focus on firms that offer digital and automated investment services. Assessments will evaluate:
The Division will focus on recent advancements in AI and assess whether firms have implemented adequate policies and procedures to monitor key risks, including fraud, anti-money laundering, operations and trading.
Using AI? The Rules of Effective Compliance Still Apply
Division reviews of SCI entities will focus on the effectiveness of incident response policies and procedures, and the identification and management of third-party systems and third-party vendor risk.
Broker-dealers and certain RICs are required to establish anti-money laundering (AML) programs to ensure compliance with the Bank Secrecy Act. Programs should be tailored to the firm's specific risk profile and be reasonably designed to protect the firm from money laundering or the financing of terrorist activities. Examinations will continue to review:
Learn how MCO helps firms effectively manage AML and Third-Party Compliance
The importance of maintaining a sound and robust compliance program is critical to meeting SEC expectations in 2026 and beyond. Having robust policies and procedures is essential for firms to establish a strong compliance framework that aligns with the SEC’s 2026 examination priorities, and for that matter, to align with any regulator around the globe.
MCO provides firms with a robust and flexible compliance program that enables them to effectively manage compliance obligations and identify and mitigate potential conflicts of interest across employees, firm transactions and third parties.
Equally important is the ability to evidence compliance. Regulators like the SEC expect tangible and defensible proof that the compliance program meets their standards. MyComplianceOffice delivers the compliance technology that's crucial in this process, streamlining the management and tracking of compliance activities, ensuring firms can efficiently meet regulatory requirements—and then easily pull the audit trail to prove it. Read a white paper on the importance of compliance evidence.
MCO can help you streamline compliance across your organization and be ready to stand up to regulatory scrutiny. Contact us today for a demo to see MyComplianceOffice in action.