The SEC adopted the amendments on May 16, 2024. They cover SEC-registered investment advisers, broker-dealers, investment companies, funding portals and transfer agents. Exempt reporting advisers are outside the investment-adviser scope.
For SEC-registered advisers the compliance date was December 3, 2025 for firms with at least 1.5 billion dollars in assets under management, and June 3, 2026 for smaller firms. Both have passed, so a small covered adviser needs the program in place now, not planned.
What the examiners say they will look at
The SEC's Division of Examinations lists Regulation S-P in its fiscal 2026 priorities and says examinations “will focus on firms' policies and procedures, internal controls, oversight of third-party vendors, and governance practices.” After the compliance dates it says it will examine “whether firms have developed, implemented, and maintained policies and procedures in accordance with the rule's new provisions that address administrative, technical, and physical safeguards for the protection of customer information.”
Not SEC-registered yet?
A state-registered adviser generally falls under the FTC Safeguards Rule and its state regulator's rules rather than Regulation S-P. If the firm is heading for SEC registration, build the Regulation S-P program before the switch, not after it. The financial services page covers that case.
This is a general summary for educational purposes, not legal advice. Application depends on your firm's registration, activities and facts, and the rules change over time. Consult qualified counsel and the official SEC guidance. Sources: the SEC's Regulation S-P rule page, the fiscal 2026 examination priorities, and, for a plain-English walkthrough, Holland & Knight on the approaching compliance deadline. All read on October 22, 2026.