Form ADV annual amendment date planner

The Form ADV filing deadline for the annual updating amendment is 90 days after the end of the adviser’s fiscal year, and an SEC-registered adviser whose brochure changed materially then has until day 120 to put the current brochure, or a summary of the changes, in front of every client. The planner turns your year-end date into those two dates and lists the work that leads up to each one. The parts of Form ADV, and who files which, are laid out in the guide What is Form ADV?

The answers change with the registration you pick. An SEC-registered adviser gets the full list. A state-registered adviser gets the 90-day filing date, which the Form ADV instructions set for SEC- and state-registered advisers alike, and a pointer to its state’s delivery rule, which this page does not read. An exempt reporting adviser files the same annual amendment within 90 days, but Parts 2A, 2B and 3 do not apply to it, so the brochure and Form CRS steps drop out.

Filing Form ADV each year is a short sequence. The planner dates each step; this is the order.

1. Update every item, not only the ones that changed

   The annual amendment refreshes all items in Part 1A (and 1B for a state-registered adviser), the brochure and the brochure supplements, with their schedules. An other-than-annual amendment is set off by particular items going inaccurate; the annual one covers them all. What each brochure item asks is in the guide to the Form ADV Part 2A brochure and Part 2B supplement.

2. Write the summary of material changes

   If the brochure changed materially since the last annual update, Item 2 of Part 2A asks for a summary on the cover page or the page after it, or as a separate document, stating that it covers only material changes since the last annual update and giving that update’s date.

3. Pay the annual filing fee, then file through IARD

   Rule 204-1(c) charges an annual filing fee each time you file the annual updating amendment, and FINRA, which runs IARD, does not accept the amendment until it is paid. Parts 1A, 2A and 3 go in electronically. Brochure supplements are not filed with the SEC.

4. Deliver to clients and keep the record

   Send the brochure or the summary by day 120 when the changes were material, and keep the copy and the delivery dates under Rule 204-2(a)(14). The books and records checklist generator lists that record beside the rest an adviser keeps.

Start with the planner’s default: an SEC-registered adviser whose fiscal year ends on December 31, 2026. Day 1 is January 1, 2027, so day 90 is March 31, 2027, a Wednesday, and the amendment is due by then. The brochure changed materially, so the summary of material changes, with its offer of the full brochure, goes to every client by day 120, April 30, 2027.

The last row is the one to watch. 2028 is a leap year, so February has 29 days and both dates land a day earlier than in 2027: March 30 and April 29. April 29, 2028 is also a Saturday. The rule text we read says nothing about a weekend or holiday moving a deadline, so the planner leaves the date where it falls and tells you to deliver before it.

The annual date is the floor, not the only filing. The Form ADV instructions name the changes that cannot wait for next year’s amendment.

Two things do not force an interim brochure update on their own. The instructions say: “You are not required to update your brochure between annual amendments solely because the amount of client assets you manage has changed or because your fee schedule has changed.” Both still get refreshed in the annual amendment. A firm that keeps its filing calendar in software can see how six products handle Form ADV work in the comparison of RIA compliance software; a firm that hands the filing to an outside firm can start with the RIA compliance consultants we read. The rest of the year’s duties are in the RIA and FINRA compliance checklist and the guide to RIA compliance for a small adviser.

Three sentences set the planner’s dates. The first is the filing deadline itself.

The second sets the client delivery, and only when the brochure changed materially.

The third is why Form CRS has its own clock rather than riding on the annual amendment.

None of the three says what happens when day 90 or day 120 lands on a weekend or a holiday, and we did not find that anywhere in what we read, so the planner states no roll-forward. The tool reads the rule text; it is not legal advice, and a date you will act on is worth a check with your compliance counsel.

Every step in the planner rests on one of these sentences. Open a row to read it. The full texts are on the eCFR for Rule 204-1, Rule 204-3 and Rule 204-5, and in the SEC’s Form ADV General Instructions.