The SEC has released its 2026 Examination Priorities, setting a clear direction for where the agency will concentrate oversight in the year ahead. The document outlines the areas that pose the greatest risk to investors and the markets, while reinforcing long-standing expectations around compliance, transparency, and sound governance.

Issued on November 17, 2025, the priorities continue the SEC’s focus on protecting investors, promoting fair markets, and supporting capital formation, while also responding to the rapid evolution of technology and financial products.

What the 2026 Priorities Highlight

Fiduciary Duties & Standards of Conduct

The SEC is placing significant emphasis on advisers’ obligations to act in the best interest of clients. Examinations will look closely at the duty of care, the duty of loyalty, conflict disclosures, and compliance with the Marketing Rule. Firms that are newly registered or have never been examined should expect increased attention.

Cybersecurity & Operational Resilience

Cyber and operational risks continue to be a top priority. Examiners will review how firms safeguard customer information, respond to incidents, supervise vendors, and maintain continuity plans. Compliance with the amended Regulation S-P, including new breach-notification requirements, will be a central part of these reviews.

Financial Technology, AI, and Automated Tools

As investment processes become more automated, the SEC is focusing on how firms supervise models, manage algorithmic and AI-driven tools, and assess related risks. The agency will look at whether firms understand the technology they deploy and whether client disclosures accurately reflect how these tools are used.

Retail Investor Protection

Retail practices remain a core exam area. Reviews will center on:

• Fee transparency

• Best execution

• Recommendations of complex or high-risk products

Broker-dealers can expect detailed examinations related to Regulation Best Interest, sales practices, and order-routing quality.

Investment Companies and Private Funds

The SEC will continue to prioritize liquidity management, valuation practices, use of derivatives, expense allocations, and compliance with the updated Names Rule for funds. Private fund advisers can expect scrutiny of conflicts, disclosures, and fee calculations.

AML, Custody, and Safeguarding Assets

Across all market participants, exams will focus on anti-money-laundering obligations, customer identification programs, beneficial-ownership verification, and compliance with safeguarding requirements. As firms expand into digital assets and new investment structures, these obligations are becoming more complex and more critical.

Why This Matters

The 2026 priorities offer a clear signal of where the SEC expects strong controls, where firms may be falling behind, and where emerging risks are likely to shape enforcement and examination strategy. For compliance teams and leadership, these priorities provide a practical blueprint to evaluate policies, conduct internal gap analyses, and address vulnerabilities before an examination begins.

For investors, the roadmap reflects the SEC’s continued commitment to accountability, risk mitigation, and transparency across the financial markets.

Moving Toward a More Modern Regulatory Framework

The financial industry is evolving quickly, with technology, automation, and new asset classes reshaping how firms operate. The 2026 priorities recognize this shift and underscore the need for regulatory frameworks that adapt without compromising investor protection.

As traditional finance and innovative technologies increasingly overlap, the SEC’s focus for 2026 sends a clear message: firms must maintain robust, well-documented, and forward-looking compliance programs that reflect today’s market realities.

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