Alerts12.4.25
The SEC’s 2026 Examination Priorities
Highlights
- In its Examination Priorities for Fiscal Year 2026, the U.S. Securities and Exchange Commission (SEC) signals a shift back to the foundational priorities of retail investor protection, market integrity, and consistent examination practices, while indicating they will move away from “regulation by enforcement” and novel legal theories.
- Examiners will intensify focus on cybersecurity and operational resiliency, including firms’ readiness for amended Reg S-P requirements and controls addressing identity theft and advanced cyber threats.
- Investment advisers, investment companies, and broker-dealers should expect close review of fiduciary duties, compliance program effectiveness, fund fees and disclosures, order routing and execution quality, and risks associated with complex or illiquid products.
- The SEC will examine anti-money laundering (AML) program design, sanctions compliance, and the accuracy and oversight of AI, automated tools, and alternative data.
On November 17, 2025, the SEC’s Division of Examinations published its Examination Priorities for Fiscal Year 2026 (2026 Exam Priorities), signaling where and how the Division intends to focus its organizational resources over the next fiscal year. As the first examination priorities released under new SEC Chairman Paul Atkins, these priorities provide important insights into the areas on which the Division expects to focus during exams of regulated entities, as well as a potential indicator of the SEC’s enforcement priorities going forward.
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