Form ADV Filing Guide for RIAs (2026)

A lot of advisers know they need to file form ADV every year. Fewer have a clear picture of what Part 1, Part 2, and Form CRS each actually require, or what the SEC is looking at when examiners pull your filing. This guide covers the whole document, from registration basics to brochure delivery rules to the filing errors that tend to draw scrutiny.

TLDR:

• Form ADV is the SEC's standard registration and disclosure document, required under the Investment Advisers Act of 1940.
• The form has three parts: Part 1 for regulators, Part 2 for clients, and Form CRS for retail investors.
• SEC registration is mandatory above $110 million AUM; your annual amendment is due within 90 days of fiscal year-end.
• Stale AUM figures, missing Part 2B supplements, and late disciplinary disclosures are the most common exam findings.
• Greenboard keeps form ADV and Form U4 disclosure data in the same system as your other compliance workflows, so trigger events surface in context and don't get missed between annual filings.

What is form ADV?

Form ADV is the standard registration and disclosure document that investment advisers file with the SEC, state securities authorities, or both. It tells regulators who you are, how you run your business, and what clients should know before hiring you.

The SEC requires it under the Investment Advisers Act of 1940. As the SEC's own instructions explain, advisers use form ADV to register with the SEC, register with state securities authorities, and update or correct registration information on file. It also serves as the report form for exempt reporting advisers who don't fully register but still have disclosure obligations.

Form ADV is how the SEC keeps tabs on the advisory industry. Every piece of information on it, from your firm's ownership structure to your fee arrangements to any disciplinary history, becomes part of the public record through the SEC's Investment Adviser Public Disclosure database.

Who must file form ADV

Most registered investment advisers must file form ADV as part of RIA registration requirements, but the specific obligation depends on your firm's size and structure. Three main categories apply: SEC-registered advisers, state-registered advisers, and exempt reporting advisers (ERAs).

The AUM thresholds that determine which regulator you file with are fairly clear. Advisers may register with the SEC once regulatory AUM exceeds $100 million, with SEC registration becoming mandatory above $110 million. ERAs must register with the SEC once private fund AUM exceeds $150 million. Below those thresholds, you generally register with your state securities authority instead.

ERAs occupy a middle category: they don't fully register with the SEC but still file a partial form ADV as a reporting requirement. State-registered advisers follow similar requirements, administered through their home state instead of the SEC directly.

The structure of form ADV: parts 1, 2, and 3

Form ADV has three distinct parts, each aimed at a different audience and serving a different purpose.

Part 1 is the regulatory-facing section. It's a structured, largely checkbox-driven questionnaire that gives the SEC and state regulators a standardized snapshot of your firm: ownership structure, business activities, assets under management, disciplinary history, and affiliated entities. Regulators use it to monitor the industry and flag firms for examination.

Part 2 requires a narrative brochure written in plain English. As the SEC's Part 2 instructions explain, it sets out the minimum required disclosure your firm brochure and brochure supplements must contain. Part 2A covers the firm-level brochure; Part 2B covers individual supervised persons who advise clients. Part 3 is Form CRS, the client relationship summary, which applies to SEC-registered advisers and broker-dealers serving retail investors. It's shorter by design, giving retail clients a plain-language comparison of services, fees, conflicts of interest, and legal standards.

Form ADV part 1 in detail

Part 1A is the structural core of form ADV. It collects the structured data regulators rely on to understand your firm before any exam ever starts. Think of it as the SEC's permanent file on your business.

The items in Part 1A cover:

• Basic identification and contact information
• Business activities and types of clients served
• Assets under management and number of accounts
• Fee arrangements and compensation structures
• Custody of client assets
• Affiliated entities and relationships
• Disciplinary history (via Item 11 Disclosure Reporting Pages)

Schedules A and B deserve particular attention, especially for firms managing third-party compliance across affiliated entities. Schedule A identifies every person or entity that directly owns 25% or more of your firm. Schedule B goes one level deeper, capturing indirect owners. Regulators use this to map control relationships and spot potential conflicts.

Item 11 is where disciplinary history lives. Any criminal charges, regulatory sanctions, or civil actions involving the firm or its advisory personnel must be disclosed here through Disclosure Reporting Pages. Incomplete or inaccurate disclosure in Item 11 is one of the more common exam findings.

Part 1B applies only to state-registered advisers, capturing additional information required by state securities authorities, such as arbitration history and certain business practices that Part 1A doesn't require.

Form ADV part 2 in detail

Part 2 is what clients actually read. Where Part 1 is built for regulators, Part 2 is the disclosure document your firm hands to existing and prospective clients before they hire you.

Part 2A: the firm brochure

Part 2A must be written in plain English, narrative format. The SEC replaced the old checkbox approach to give clients meaningful, readable information in place of a form advisers could fill out mechanically. Required disclosures include:

• Advisory services offered and investment strategies used
• Fee schedules and compensation arrangements
• Types of clients served and minimum account sizes
• Conflicts of interest, including soft dollars and referral arrangements
• Disciplinary history affecting the firm or its personnel
• Code of ethics and personal trading practices
• Proxy voting policies
• Custody arrangements

Part 2B: the brochure supplement

Part 2B covers specific supervised persons, often financial advisors, who provide investment advice directly to clients. If an adviser or portfolio manager actually manages your account, you receive a brochure supplement on that individual covering their educational background, work history, disciplinary events, and outside business activities.

Firms with distinct service lines have some flexibility. A firm that offers substantially different types of advisory services may prepare separate brochures for each service, provided each client receives all information applicable to their arrangement.

Brochures must be submitted as text-searchable PDF files through the IARD system and appear publicly in the Investment Adviser Public Disclosure database the following day.

How to file form ADV: the IARD system

Nearly all investment advisers file form ADV electronically through the Investment Adviser Registration Depository (IARD), a system operated by FINRA on behalf of the SEC. There's no paper option for most filers. You set up an account through IARD, pay the required filing fees, and submit directly through the system.

Once submitted, your Part 2 brochure is publicly accessible through the SEC's Investment Adviser Public Disclosure (IAPD) website, typically the following business day. Part 1 data feeds into the SEC's broader regulatory databases, which staff use for examination targeting and industry analysis.

IARD also handles email reminders for certain filing deadlines, but only if you've entered a valid contact email in Item 1.J of Part 1A and confirmed it through the system's verification process. That step is easy to miss, and skipping it can become a compliance bottleneck, so it's worth checking if you haven't done this.

Annual amendment requirements and deadlines

Advisers must file an annual updating amendment within 90 days of their fiscal year-end, covering all items in Parts 1A, 2A, and 2B, along with the corresponding schedules. If your fiscal year ends Dec. 31, that puts your deadline at March 31. This applies to both SEC-registered advisers and ERAs filing with the SEC.

Form CRS operates on a different schedule. It doesn't require an annual update, but you must amend it whenever any information becomes materially inaccurate. In practice, that means reviewing it alongside your annual amendment even if a formal update isn't required.

Prompt amendment triggers outside the annual cycle

The annual filing is the baseline. But form ADV is a living document, and certain changes require an amendment well before your next annual deadline, which is why firms are shifting toward a system of action for compliance.

The SEC's standard is "promptly," which in practice means as soon as reasonably practicable after the triggering event. The SEC's Form ADV General Instructions use this term without defining a specific number of days, but regulators expect you to move quickly. Events that typically require a prompt amendment include:

• Material changes to your advisory services or investment strategies
• New or amended disciplinary events affecting the firm or supervised persons
• Changes in ownership or control (Schedule A or B updates)
• A change in your firm's mailing location or contact information
• The addition of new advisory personnel who require Part 2B supplements
• Changes to your fee arrangements or compensation structure that materially affect clients

The Part 2A brochure carries its own prompt amendment standard for material changes. Any time information in the brochure becomes materially inaccurate, you must update it and deliver the revised version, or a summary of changes, to existing clients. Disciplinary events deserve extra attention: if a new Disclosure Reporting Page is triggered, waiting until the annual amendment is not an option.

What the brochure delivery rule requires

Under 17 CFR § 275.204-3, every SEC-registered adviser must deliver a current brochure and applicable supplements to each client or prospective client, with timing that depends on whether the recipient is new or existing.

Prospective clients must receive the brochure before or at the time you enter into an advisory contract. Existing clients must receive either an updated brochure or a summary of material changes within 120 days of your fiscal year-end. If no material changes occurred, a written confirmation with an offer to provide the full brochure on request satisfies the requirement.

The SEC hasn't issued a precise definition of "material," but in practice it covers anything a reasonable client would weigh when deciding whether to continue the relationship. Fee changes, new conflicts of interest, disciplinary events, and changes in investment strategy generally qualify. Minor administrative updates, like a phone number change, typically don't.

Brochure supplements follow the same logic: clients must receive a supplement before or when a supervised person begins advising them, and updated supplements must go out promptly when material changes affect that individual.

How investors use form ADV

Form ADV is a two-way document. So far we've covered what advisers must file. Here's what clients actually do with it.

The SEC makes every firm's ADV publicly searchable through the Investment Adviser Public Disclosure (IAPD) website at adviserinfo.sec.gov. Anyone can look up a registered adviser by name, location, or CRD number and pull the full filing. No account required.

When a prospective client opens an ADV, a few sections do most of the work:

• Part 2A for fees, services, conflicts of interest, and investment strategy
• Item 11 Disclosure Reporting Pages for disciplinary history, including criminal charges, regulatory sanctions, and civil actions
• Schedules A and B for ownership and control relationships
• Part 2B supplements to review the background of the specific adviser managing their account

Fee schedules in Part 2A also reveal whether arrangements like referral fees or soft dollar practices create incentives that don't fully align with a client's interests. Form CRS adds a layer for retail investors: a short summary that lets them compare services and standards of care across firms side by side.

Common form ADV filing errors and how to avoid them

Stale AUM figures are one of the most common issues examiners flag. Advisers often carry forward AUM from the prior year without recalculating, which creates a mismatch between what's on file and what regulators see in other data sources. AUM in Part 1A should reflect your regulatory assets under management as of your fiscal year-end, calculated using the SEC's prescribed method.

Missing Part 2B supplements come up regularly too. When a supervised person begins advising clients directly, a supplement needs to be on file and delivered. Firms that grow quickly sometimes add advisers without updating their brochure supplement roster.

Schedule A and B ownership information is another frequent gap. Indirect ownership chains shift when firms restructure, bring on investors, or reorganize entities. Regulators use this data to map control relationships, so outdated entries draw scrutiny.

Disciplinary disclosure is where errors carry the highest risk. If a new event triggers a Disclosure Reporting Page, it needs to go on file promptly, not at your next annual amendment. Examiners check filing dates against the timing of underlying events, and waiting is one of the more serious mistakes an adviser can make.

A few practical steps help:

• Calendar your AUM calculation date well before the annual deadline so you have time to run the numbers correctly.
• Maintain a current roster of supervised persons who advise clients directly, and update it whenever someone's role changes.
• Review Schedule A and B whenever ownership or control changes, not just at annual amendment time.
• Flag disciplinary events as they arise and assess the disclosure obligation immediately.

Form ADV and the SEC examination process

The SEC's Division of Examinations cannot audit every registered adviser every year. With 16,544 SEC-registered advisers managing $176.8 trillion (a subset of the broader adviser population), examiners rely heavily on form ADV data to decide who gets looked at, and what they look for when they arrive.

Before an exam begins, staff typically pull your most recent ADV filings and compare them against prior years, other data sources, and industry norms. Discrepancies in disclosed AUM, gaps in disciplinary reporting, or ownership schedules that haven't been updated after a known restructuring are the kinds of signals that move a firm up the priority list. An ADV that's current, consistent, and internally coherent, supported by reliable compliance software, tends to generate fewer questions before examiners ever contact you.

Once an exam starts, your ADV sets the scope. Examiners test what you said against what you actually do. If Part 2A describes a particular investment strategy, they'll look for evidence that clients are managed that way. If your fee schedule discloses a specific structure, they'll check whether client invoices match. Stale or inaccurate disclosures aren't a filing problem alone. They become substantive findings, a common theme covered in our FAQ resource guide.

How Greenboard helps RIAs manage form ADV compliance

Managing form ADV as a once-a-year filing event is how errors accumulate. Ownership changes, disciplinary events, and new supervised persons don't wait for your annual deadline, and neither should your disclosure tracking.

Greenboard's GreenboardGo capability maintains form ADV and Form U4 disclosure data within the same system where your other compliance workflows run, so disclosure currency is visible alongside personal trade monitoring, attestations, and marketing review, rather than buried in a separate spreadsheet someone checks once a year. When a trigger event occurs, it surfaces in context and doesn't get lost between annual filing cycles.

More than 600 financial firms run their compliance programs on Greenboard, with over 99% customer retention. Firms that treat compliance as a continuous process rather than a series of filing deadlines tend to stay ahead of exam findings instead of responding to them.

Final thoughts on how form ADV works

Form ADV covers a lot of ground, from ownership structures to disciplinary history to fee disclosures, and each piece carries real weight with regulators and clients alike. The annual filing is the deadline, but the disclosure obligation runs all year. Firms that treat it as a continuous process tend to walk into exams with a lot less to explain.

FAQ

What triggers a prompt form ADV amendment outside the annual cycle?

Several events require a prompt amendment before your next annual deadline: new or amended disciplinary events, changes in ownership or control, material updates to your fee arrangements or investment strategies, and the addition of supervised persons who need Part 2B supplements. The SEC doesn't define a specific number of days for "promptly," but examiners check filing dates against when underlying events occurred, so moving quickly matters.

What's the difference between form ADV Part 1 and Part 2 in terms of who actually reads them?

Part 1 is built for regulators and feeds the SEC's examination targeting process, while Part 2 is the disclosure document clients and prospective clients actually read before hiring you. Part 1 is a structured questionnaire covering ownership, AUM, and disciplinary history; Part 2A requires a plain-English narrative brochure covering fees, conflicts of interest, and investment strategy.

How do I avoid the most common SEC form ADV filing errors?

The most frequent issues are stale AUM figures carried forward from prior years, missing Part 2B supplements when new advisers begin working with clients directly, and outdated Schedule A and B ownership information after a firm restructures. Calendar your AUM calculation date well before the annual deadline, maintain a current roster of supervised persons, and treat disciplinary disclosure as an immediate obligation rather than something to fold into the next annual amendment.

When does form ADV need to be amended versus when is the annual update enough?

The annual amendment covers routine updates to Parts 1A, 2A, and 2B within 90 days of your fiscal year-end. Anything that makes your current disclosure materially inaccurate requires a prompt amendment before that deadline, including new Disclosure Reporting Pages, ownership changes, and material changes in how you manage client assets. Waiting for the annual cycle on a disciplinary event is one of the more serious mistakes an adviser can make.

Can Greenboard help RIAs track form ADV disclosure obligations between annual filings?

Yes. Greenboard's GreenboardGo capability maintains form ADV and Form U4 disclosure data within the same system where personal trade monitoring, attestations, and marketing review run, so disclosure currency is visible year-round rather than checked once before the March 31 deadline. When a trigger event surfaces, it appears in context alongside your other compliance workflows instead of sitting in a separate spreadsheet.