2026 Regulatory Agendas Published

July 7, 2026

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Inclusion of E-Delivery, Pay to Play, and Recordkeeping Reflect Key IAA Priorities 

After a much longer wait than usual, the federal agencies have officially published their 2026 regulatory agendas. The agendas provide a much clearer picture of the rulemaking priorities of the SEC, DOL, Treasury Department, and CFTC than did the spring agendas (which were issued last September). The SEC’s agenda in particular signals Chairman Atkins’ priorities and includes several initiatives that reflect key IAA advocacy priorities.

Here’s What You Need to Know: The SEC’s agenda includes several new initiatives that have been longstanding IAA advocacy priorities, including electronic delivery, Pay to Play reform, modernization of the Recordkeeping Rule, expanding investor access to the private markets, and improving Form PF – the confidential form filed by private fund advisers.

Since Chairman Atkins took the helm at the SEC, the IAA has worked closely with the Commission to identify opportunities to modernize outdated regulatory requirements, reduce unnecessary regulatory burdens, and continue to protect investors. Shortly after Chairman Atkins was confirmed, we sent him a letter outlining several of our highest priorities for advisers and have continued to advocate for these reforms through meetings with SEC leadership and staff, comment letters, and other engagement. The inclusion of several of these items in the SEC’s agenda reflects the SEC’s focus on issues the IAA has consistently raised on behalf of members.

The SEC’s agenda is extremely ambitious, especially as the agency is still feeling the effects of significant staffing reductions while also recovering from the longest government shutdown ever. As a result, the SEC’s priorities, the timing of individual rulemakings, and ultimately which initiatives move forward remain uncertain.

Notable New Items on the SEC’s Agenda:

• E-delivery: The SEC plans to “modernize the Commission’s approach to the use of electronic media and reduce costs associated with paper delivery.” The proposal has already been submitted to the Office of Management and Budget (OMB) for review, indicating that it could be released soon. The IAA has long advocated for modernizing the SEC’s framework for delivery of regulatory disclosures.
• Pay to Play reform: The SEC plans to propose amendments to the Pay to Play Rule that would “address identified compliance burdens.” The IAA has consistently highlighted to SEC leadership and staff the rule’s significant unnecessary complexity, compliance burdens, and disproportionate penalties, and we continue to press for meaningful reform.
• Retail access to private markets: The SEC plans to consider amendments to the Advisers Act and Investment Company Act rules to expand retail investor exposure to private markets through registered investment companies and allow advisers to charge performance fees to an expanded set of clients. The IAA supports appropriately expanding investor access to private markets.
• Recordkeeping modernization: The SEC plans to revisit the Advisers Act Recordkeeping Rule to address “the appropriate scope of compliance burdens related to electronic communications” and technological developments since the rule was adopted. The IAA strongly supports modernizing this rule, particularly in light of the recent off-channel communications enforcement actions and the rapid evolution of communications technologies, including AI. As discussed in our recent comment letter, the current framework should better reflect today’s communications technologies while remaining appropriately tailored to the SEC’s regulatory objectives.
• Form PF: Amendments to Form PF were expected to be included in the agenda given that the SEC already issued a proposal to amend the form. The amendments are intended to raise reporting thresholds to exclude small advisers from having to file the form at all, as well as to reduce unnecessary complexity and better focus reporting on information relevant to systemic risk monitoring. The IAA supports these proposed changes and, as discussed in a comment letter we recently submitted, we also make recommendations to further streamline reporting obligations under the form.
• Semiannual reporting by public issuers: The agenda also includes the SEC’s proposal to allow public companies to file semiannual rather than quarterly reports. The IAA recently submitted a comment letter generally opposing the proposal. We strongly support efforts to strengthen the public markets, but do not believe that reducing the frequency of standardized public company reporting is the right approach. The SEC has also proposed to modernize the shelf registration process and simplify the filer status of public companies.

Other New Notable SEC Items Include:

• Amendments to proxy rules;
• Rescission of climate-related disclosure rules for corporate issuers. The administration has also abandoned human capital management and board diversity disclosures;
• A new exemptive rule addressing affiliated securities lending agent arrangements;
• The regulatory status of finders under Section 15(a) of the Exchange Act;
• Clarification of “business as such” for purposes of the broker-dealer recordkeeping rule;
• Amendments to short sale reporting requirements;
• Form S-K executive compensation disclosure reform;
• Rule amendments related to financial institution resolution transactions; and
• Amendments to the SEC’s Whistleblower Program Rules (added to the SEC’s long-term agenda).

Important Ongoing SEC Items: The agenda also continues to include several important rulemakings on which the IAA remains actively engaged, including:

• Amendments to the Advisers Act and Investment Company Act Custody Rules to address crypto assets and make other modernizations “needed to remove burdens from certain outdated provisions that are no longer needed to provide investor protection given the evolution in the markets and security trading and holding practices.”
• Updating the definition of “small entity” under the Advisers Act and Investment Company Act. The IAA strongly supports this proposal and has advocated for this change for years, including through our 2023 petition for rulemaking.
• Crypto-related rules, relating to the offer and sale of crypto assets, potentially to include certain exemptions and safe harbors, transfer agent rules, and rules to account for the trading of crypto assets on alternative trading systems and national securities exchanges.
• Amendments to Rule 17a-7, which governs investment company cross trades, Form N-PORT reporting, and potential changes to the exempt offering framework, including potentially the accredited investor definition.
• A revised proposal addressing the definition of “dealer” following the prior rule being vacated by a court. The IAA had strongly opposed the prior rule, which expanded the definition of dealer in a way that inappropriately captured routine adviser activity. We believe that the SEC plans to codify a definition of “dealer” more in line with its longstanding – and in our view correct – interpretation of that term.
• A proposal to exclude fixed income securities from public quotation requirements under Rule 15c2-11. The IAA has advocated for and supports this proposal.
• Potential amendments to Rule 14a-8 governing shareholder proposals.
• Proposal to amend Rule 611, the trade through rule.
• The proposed Customer Identification Program (CIP) Rule, proposed jointly by the SEC and Treasury’s Financial Institutions Crimes Enforcement Network (FinCEN) is included in the SEC’s long-term action list.

Not in the SEC’s agenda, but . . . The SEC has opened a 60-day request for comment on ETFs seeking to invest in “innovative asset classes” or engage in “novel investment strategies.”

Notable Items from Other Agencies Include:

Department of Labor

• Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights would replace the Biden-era ESG Rule, which the DOL announced in May 2025 that it would no longer defend in litigation. The proposal is expected to address the role of non-pecuniary factors in investment decision-making and to be designed “to ensure that plan fiduciaries select investments and exercise shareholder rights based only on financial considerations . . . and not to advance social causes.” The proposal has now been submitted to OMB for review, indicating that it may be released soon.
• New item: Fiduciary duty in selecting investment alternatives for retirement plans. This rulemaking responds to an Executive Order directing the DOL to consider ways to expand access to alternative investments in retirement plans. The IAA recently submitted a comment letter supporting the DOL’s proposed asset- and strategy-neutral framework, which neither favors nor disfavors particular investment options or investment strategies. 

Treasury/FinCEN

• Oddly, while the SEC’s agenda includes the CIP Rule as a long-term item, Treasury’s agenda includes it as a proposal. Treasury’s agenda also does not include the investment adviser AML Rule, for which the compliance date has been extended until January 2028 and which FinCEN has announced it intends to revisit. Treasury’s agenda does include a broader proposal to modernize the AML framework applicable to financial institutions, which has already been issued, and on which the IAA recently submitted a comment letter.
• New item: AML requirements for permitted payment stablecoin issuers.
• Final rule stage: Revisions to beneficial ownership reporting

CFTC

• Continuing items: The CFTC continues to consider proposals to exempt mutual funds and certain private equity funds from specified commodity pool operator (CPO) requirements, as well as amendments to Form CPO-PQR reporting requirements.
• New item: Following its recent request for comment, the CFTC proposed a regulatory framework for prediction markets (event contracts).
• New item: The CFTC plans to consider amendments to its regulations to address blockchain-based trading systems and digital assets.

How to Read the Regulatory Agendas

The agendas provide a useful roadmap, but they should be interpreted with appropriate caution.

• They reflect an agency’s current priorities and in many ways are aspirational. They should not be viewed as binding commitments to meet the published timetable.
• Publication schedules also frequently change as priorities evolve.
• Agencies submit agenda items to OMB months before publication, meaning events can overtake the published agenda.
• The agendas are also not exhaustive. Significant rulemakings may emerge even if they are not listed.

The IAA Has Your Back

The IAA continues its robust advocacy and engagement with regulators on behalf of our members on rulemakings that affect investment advisers. In addition to our advocacy on the specific areas mentioned above, we’ve emphasized the need to ensure that new regulations are principles based and appropriately tailored to advisers and their businesses, that implementation timelines are reasonable and realistic, and that regulators consider the cumulative impact of regulation on advisers of all sizes and in particular on smaller advisers. Our advocacy positions in our comment letters and other documents are included on the IAA website.

As these rulemakings move forward, we will continue engaging with policymakers and regulators, advocating for meaningful reforms on behalf of advisers, and keeping members informed of important developments.

Members with questions or comments should contact the IAA Legal Team at iaalegalteam@investmentadviser.org. IAA adviser firm members are also encouraged to contact the IAA Legal Team and join our committees, working groups, and forums, where members discuss the issues covered in this alert and other important issues.