The SEC Examination Priorities for 2026 Set a Clear Tone for Compliance
The newly released SEC examination priorities for 2026 place a strong emphasis on fiduciary duty, conflicts of interest, fee-expense practices, retail investor protection, and cybersecurity. These five areas shape the regulatory roadmap for the year, signaling tighter expectations for advisers and broker-dealers. The SEC examination priorities highlight a growing need for firms to reassess their governance and oversight models. Because the SEC continues to spotlight fiduciary duty and conflicts of interest, firms must ensure their disclosure practices and internal controls cannot be challenged. Fee-expense practices and retail-investor protection are also front and center, demonstrating that transparency must be a core part of the compliance strategy in 2026. SEC examination priorities, fiduciary duty, conflicts of interest, fee expense practices, retail-investor protection, and cybersecurity are fundamental to the approaching regulatory cycle and must be addressed now to avoid deficiencies later.
Heightened Focus on Cybersecurity and Operational Resilience
Cybersecurity receives significant weight in the 2026 SEC examination priorities. With more firms using digital tools and automated workflows, managing cybersecurity risks is now a top priority for the SEC. The agency expects firms to show they can operate safely even when faced with challenges. This means demonstrating how they keep client data secure, prevent unauthorized access, and maintain business continuity during difficult times.
The SEC highlights cybersecurity repeatedly in its priorities because it sees vulnerabilities in firms of all sizes. Along with concerns about automated technology and AI systems, the agency is expecting to see stronger internal checks and more consistent reporting frameworks. To meet these expectations, firms should have clear cyber controls in place, regularly test their governance processes, and provide ongoing training.
Scrutiny on Private Funds, Private Credit and Conflicts of Interest
The SEC is intensifying its scrutiny of those involved in private markets. The focus of the 2026 review will be aimed at private-credit funds, the handling of fees and expenses in private funds, and how conflicts of interest are disclosed. Given that private fund frameworks typically contain multiple fees, intricate valuation techniques, and side agreements, the SEC anticipates comprehensive record keeping, straightforward disclosures, and transparent measures for conflict resolution.
How Firms Should Respond to the 2026 Examination Priorities
All firms need to refresh their internal audits, evaluation strategies, and compliance strategies need to be in line with the SEC examination focuses for 2026. Begin by examining frameworks related to fiduciary duties, practices concerning fees and expenses, records of conflicts of interest, and methods for safeguarding retail investors. Ensure that cybersecurity measures are verified and that they correspond with ongoing threats and regulatory demands.
You should also test AI-driven systems and automated tools to ensure they meet operational-resilience standards. Conduct tabletop incident drills. Update policies. Train frontline staff.
The SEC examination priorities make one thing clear: 2026 will challenge firms that delay compliance improvements. Strong oversight today prevents costly fines tomorrow.
