California DFPI reiterates annual filing obligations for state-RIAs

In guidance published in February 2026, the California Department of Financial Protection and Innovation (DFPI) restated existing annual filing and financial reporting obligations for California-registered investment advisors.

According to the DFPI, each investment advisor must file an annual updating amendment to Form ADV with the Investment Adviser Registration Depository (IARD) within 90 days of the firm’s fiscal year end pursuant to Section 260.241.4. Additionally, each investment advisor must amend Form ADV Parts 1 and 2 whenever the information becomes inaccurate, as further detailed in the Form ADV General Instructions, Item 4. The DFPI stresses that Form ADV must contain current and accurate information, including a current email address, which the California regulator uses to communicate current issues and developments to advisers.

Where an investment adviser is subject to California’s minimum financial requirements under Section 260.237.2, the DFPI requires an annual financial report reflecting the firm’s financial condition to be filed with the DFPI Commissioner not more than 90 days after year end; that report must include a GAAP-compliant Statement of Financial Condition and computations of the applicable minimum financial requirements, which may be prepared using the DFPI’s Minimum Financial Requirements Worksheet.

If an advisor held or accepted custody of client funds or securities, or owed money or securities to clients during the reporting period, the DFPI requires audited financial statements prepared by an independent certified public accountant, whereas advisors with only discretionary authority over client assets need not submit audited financials.

The California DFPI further requires that a verification form – specifically the Verification Form Pursuant to Section 260.241.2(b) -- accompany the financial report, affirming that the financial statements and supporting schedules are true, correct and accurate to the best knowledge and belief of the signatory. The DFPI states that required financial reports should be submitted by email to [email protected].