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The annual Form ADV amendment

Two clocks start at your fiscal year end: a 90-day filing clock and a 120-day client delivery clock.

1. File within 90 days. You must amend Form ADV Parts 1 and 2 at least annually, within 90 days of the end of your fiscal year, and more often when the Form ADV instructions require (17 CFR 275.204-1(a)).
2. File through IARD and pay the fee. Amendments to Parts 1A, 2A and 3 are filed electronically with IARD unless you have a continuing hardship exemption. A filing is not accepted until the fee is paid (17 CFR 275.204-1(b), (c)).
3. Deliver within 120 days. If there are material changes in your brochure since your last annual updating amendment, deliver the current brochure or the summary of material changes to each client within 120 days after fiscal year end, without charge (17 CFR 275.204-3(b)(2)).
4. Keep the records. Keep copies and proof of delivery under your books and records obligations (17 CFR 275.204-2).

Calculate your dates

Sources: 17 CFR 275.204-1, 17 CFR 275.204-3. Read 2026-10-16. Not legal advice.