Also on September 3, 2026, the SEC and CFTC announced another extension of the compliance date for the Form PF amendments adopted in February 2024. The compliance date has been extended by nine months, from October 1, 2026, to July 1, 2027. The extension became effective September 3, 2026.
The extension is particularly significant because the SEC and CFTC are currently considering a separate set of proposed amendments issued in April 2026 that could substantially reduce Form PF reporting requirements.
Why Was the Compliance Date Extended?
In April, the SEC and CFTC proposed significant changes to Form PF that would, among other things, substantially increase certain filing thresholds, eliminate certain reporting requirements and streamline other portions of the Form.
As discussed in Salus GRC’s May newsletter, those proposals would raise the general Form PF filing threshold from $150 million to $1 billion in private fund assets under management and raise the large hedge fund adviser threshold from $1.5 billion to $10 billion. The proposal would also eliminate or streamline a number of reporting requirements, including certain look-through, performance, counterparty exposure, and event-reporting requirements.
The SEC and CFTC explained that requiring advisers to implement the 2024 amendments while the agencies are considering whether to modify or eliminate portions of those amendments could cause Form PF filers to incur significant and potentially unnecessary compliance costs. The additional extension gives the agencies more time to consider comments on the April 2026 proposal and determine whether further action is appropriate.
What Does This Mean for Private Fund Managers?
Private fund advisers subject to Form PF will generally be able to continue filing the version of Form PF that was in effect before the 2024 amendments until July 1, 2027.
For managers that have been preparing systems, data collection processes, or service-provider arrangements for the 2024 amendments, the extension provides additional time before those requirements become applicable. More importantly, portions of those preparations may ultimately become unnecessary if the SEC and CFTC adopt the April 2026 proposal in whole or in part.
The agencies expressly acknowledged this possibility, explaining that the extension is intended in part to prevent advisers from incurring costs associated with requirements that could subsequently be modified or eliminated. At the same time, the agencies noted that the extension provides sufficient time for advisers to comply with the 2024 amendments if the proposed 2026 changes are ultimately not adopted.
Accordingly, private fund managers should update their compliance calendars to reflect the new July 1, 2027, compliance date and continue monitoring the pending 2026 Form PF proposal before undertaking significant additional implementation efforts related to the 2024 amendments.