Key Themes from the 2026 SEC Examination Priorities

The Securities and Exchange Commission’s Division of Examinations just released its 2026 Priorities, giving SEC-registered firms and investors insight into the SEC's focus for the coming year.

The list of priorities includes several recurring focus areas for investment advisors, investment companies, broker-dealers, and other financial market participants, such as fiduciary duties and standards of conduct, as well as new areas for newer rules like Regulation S-P, and the significant omission of digital assets, marking a clear shift from the prior administration.

While the list of focus areas contains different specifics for investment advisers, broker-dealers, and other participants, three key themes are consistent that chief compliance officers should be keeping in mind:

Focus on the Basics of Running an Effective Compliance Program

Chairman Paul Atkins has repeatedly emphasized the need for the SEC to refocus on the basics of compliance, and this theme is evident in the 2026 priorities. Exams for investment advisors will again focus on the effectiveness of compliance programs as a fundamental part of the process.

Review for broker-dealers will also focus on fundamental parts of their programs, such as trading-related practices and services, and retail sales practices, including the now evergreen Regulation Best Interest. Overall, the focus is on whether financial services firms are meeting their compliance obligations.

Information and Data Security

Cybersecurity has been a focus area for several years running now, as well as Regulations S-ID and Regulation S-P, as applicable. With the updates to Regulation S-P coming into effect on December 3, 2025, for large firms, and on June 3, 2026, for smaller firms, examiners will be focused on reviewing relevant policies and procedures, internal controls, and oversight of third-party vendors and governance practices, to assess whether or not they are reasonably designed to identify and detect issues.

Impact of Emerging Technology and Artificial Intelligence

As in prior years, AI and other technologies, such as automated tools and trading algorithms, and the proper mitigation of the associated risks, remain a concern for regulators. Examiners will be especially focused on whether firms have implemented adequate governance, including policies and procedures to monitor and supervise use, for these types of tools.

Comprehensive Governance and Compliance Support for 2026 SEC Priorities

EisnerAmper supports firms with governance and compliance solutions that address not just these key themes but all focus areas for the SEC going into 2026, helping your firm remain at the leading edge of regulatory expectations.