The final quarter of 2025 delivered several important regulatory developments for U.S. investment advisers and market participants, with implications for compliance planning, supervisory focus, and disclosure obligations heading into 2026 and beyond.
While some anticipated requirements have been delayed, others are now in effect, reinforcing the need for attention to privacy, governance, and operational resilience.
IA AML rule delayed to 2028
On December 31, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule extending the effective date of the rule establishing anti-money laundering (“AML”)/countering the financing of terrorism program and suspicious activity report filing requirements for registered investment advisers and exempt reporting advisers (“IA AML rule”) from January 1, 2026 to January 1, 2028.
Regulation S-P (privacy rule) – compliance deadlines
Effective December 3, 2025, Securities and Exchange Commission (“SEC”)-registered investment advisers (“RIAs”) with more than $1.5 billion in assets under management (“AUM”) are required to be in compliance with recent amendments to Regulation S-P. These amendments require RIAs to protect customer information through enhanced privacy safeguards, including new breach notification requirements. The compliance deadline for smaller firms is June 3, 2026.
2026 SEC Division of Examinations priorities
On November 17, 2025, the U.S. SEC Division of Examinations announced its 2026 examination priorities. The 2026 priorities focus on fiduciary duties, conflicts of interest, fee and expense practices, and retail investor protection. They also include emerging areas of focus, including cybersecurity, artificial intelligence (“AI”), and amendments to Regulation S-P. The SEC continues to focus on alternative investments and now includes private fund issues within broader thematic review areas rather than as a standalone section.
SEC signals support for semi-annual reporting
SEC Chairman Paul Atkins announced support for changing from quarterly reporting to semi-annual reporting for U.S. public companies, in line with other jurisdictions such as the United Kingdom and European Union. The changes may be proposed in the SEC’s “Rationalization of Disclosure Practices” proposal listed in its regulatory agenda, with a target proposal date of April 2026. In the U.S., the current quarterly reporting regime, which requires that public companies disclose their financial results on Form 10-Q each fiscal quarter, has been in place since 1970.
California’s climate disclosure law halted
On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit granted an injunction pending appeal halting enforcement of the Climate-Related Financial Risk Act (“SB 261”), which would have required many large companies doing business in California to publicly disclose climate-related financial risk by January 1, 2026. SB 261 requires companies doing business in California with over $500 million in revenue to publicly disclose their climate-related financial risks in a biennial report. As a result of the injunction, covered companies are no longer under an immediate legal obligation to comply with the January 1, 2026, deadline. The California Air Resources Board will provide additional guidance after the appeal concludes.
