By: Ariana Monchick
From new continuing education requirements for investment adviser representatives (“IARs” as defined in Section 203A-3 of the Investment Advisers Act of 1940) to missed registration renewal payments, adviser licensing poses increased challenges for investment advisers’ compliance programs. 24 jurisdictions have now implemented continuing education (CE) requirements for investment adviser representatives that must be met each year in order for IARs to keep their registration active. FINRA offers the Maintaining Qualifications Program (MQP) for financial professionals who are terminating their securities registration with a broker-dealer to maintain their qualifications for up to five years. MQP participants may complete annual continuing education and return to a FINRA-member firm in the future without having to re-qualify by retaking the requisite securities exam(s). Each state also assesses an annual fee to keep an IAR’s registration active, as well as annual notice filing fees, which must be paid by a specified date each year.
With evolving registration requirements, even minor lapses can carry significant business and regulatory consequences. These consequences can include a financial adviser losing the ability to provide investment advice or charge advisory fees, the financial professional having to retake an examination to reinstate their license, and/or hefty fines levied by state regulators for not being properly licensed. Heightened enforcement by state regulators underscores the need for proactive oversight and adherence to important deadlines.
Continuing Education Requirements for Investment Adviser Representatives
Listed below are the jurisdictions that require continuing education for IARs, which must be completed by December 31st of each calendar year. With the year-end deadline quickly approaching, compliance officers should take steps to ensure their IARs have completed any required CE for the year.
- Arkansas
- California
- Colorado
- Florida
- Hawaii
- Illinois *Effective in 2026
- Kentucky
- Maryland
- Michigan
- Minnesota
- Mississippi
- Nebraska
- Nevada
- New Jersey
- North Dakota
- Oklahoma
- Oregon
- Rhode Island
- South Carolina
- Tennessee
- Vermont
- Washington, D.C.
- Wisconsin
- U.S. Virgin Islands
IARs in a jurisdiction requiring CE need to obtain 12 CE credits each year to maintain their IAR registration. A “credit” is a unit that has been designated by NASAA to be at least 50 minutes of educational instruction. The 12 credits must include:
- 6 credits – Products and Practices; and
- 6 credits – Ethics and Professional Responsibility.
There is an IAR CE course reporting fee (roster fee) of $3 per credit per person, which is due when the CE is submitted.
IARD Renewal Program
For IAR registrations to remain active, firms must pay an annual renewal fee through IARD. The annual renewal program also applies to investment adviser notice filings. The following timeline provides key dates applicable to this year’s renewal process:
| Action Needed | Key Dates |
| Retrieve the firm’s Preliminary Statement. Log in to E-Bill via FINRA Gateway. Select the Generate Statement button to view your statement | Available November 10, 2025 |
| Fund your E-Bill account and pay the Renewal Assessment. See E-Bill User Guide | Due December 8, 2025 |
| Review IAR registrations and state notice filings to determine whether any changes are needed. | Filings must be submitted by December 26, 2025 |
| Retrieve and review your Final Statement. | Available January 2, 2026 |
| Fund your E-Bill account and pay any additional funds owed. | Due January 23, 2026 |
Additional details and instructions on completing the IARD Renewal Program can be found on the IARD’s Renewal Program Page at https://iard.com/renewal-program.
As registration requirements continue to evolve, it is imperative that firms ensure licensing oversight has been integrated into the firm’s compliance infrastructure. In our December newsletter, we will cover Part II of our Adviser Registration Series, where we will dive into additional registration considerations, answer frequently asked registration questions, and provide strategies advisers can implement to stay ahead of registration and licensing issues.