Investment Advisers Get Online Filing Lifeline Extended
Published Date: 4/13/2026
Notice
Summary
The SEC is extending the approval for Form ADV-H, which lets investment advisers ask for a break from filing paperwork online if they face technical or financial troubles. This affects advisers who might need extra time or relief from electronic filing rules, especially small businesses. No new fees or big changes are coming, but advisers should keep an eye on deadlines to stay in the clear.
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Analyzed Economic Effects
4 provisions identified: 3 benefits, 1 costs, 0 mixed.
Continuing Paper Filing Exemption
Certain advisers that are small businesses can apply for a continuing hardship exemption from electronic filing for up to one year by filing Form ADV-H at least ten business days before a filing is due. The continuing exemption is not available to exempt reporting advisers; the Commission will grant or deny the application within ten business days, and if approved the adviser may submit filings to FINRA in paper format for the approved period.
Temporary Paper Filing Relief
If an investment adviser has unanticipated technical problems, they can get a temporary hardship exemption by filing Form ADV-H on paper no later than one business day after the original filing was due. The adviser must still submit the subject filing electronically through IARD no later than seven business days after it was due; the temporary exemption is granted when the adviser files the completed Form ADV-H.
Paperwork Burden and Confidentiality Rules
The SEC estimates 22,495 potential respondents (16,404 registered investment advisers and 6,091 exempt reporting advisers) and expects to receive two Form ADV-H responses annually, each taking about one hour, for an estimated aggregate burden of two hours per year. The collection is mandatory, does not require recordkeeping, and the filings are not kept confidential.
OMB Approval Extension and Comment Window
The SEC submitted the Form ADV-H information collection for OMB review for extension under OMB Control No. 3235-0538 and is soliciting public comments; comments must be emailed or submitted through regulations.gov by May 14, 2026. The notice reiterates that an agency may not conduct or require responses to a collection of information without a currently valid OMB Control Number.
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