The SEC's Division of Examinations released its fiscal year 2026 priorities late last year, and buried in the document is a shift that should get every small RIA's attention: AI oversight is now part of virtually all examinations, not just exams targeting firms that market AI capabilities.
Read that again. You don't need to be running a quant fund or advertising AI-driven portfolio management to face questions about artificial intelligence during your next exam. If you use ChatGPT to draft client emails, an AI-powered CRM, or automated rebalancing tools — the SEC wants to know about it, and they want to see that you're managing it.
The 2026 exam priorities outline three core areas where examiners will probe AI usage at advisory firms:
The SEC wants to know whether your disclosures match reality. If your ADV Part 2A, website, or marketing materials mention AI capabilities, examiners will check whether those tools genuinely influence your investment process — or if "AI-powered" is more marketing language than operational truth.
But it cuts both ways. If you're using AI tools without disclosing them, that's a problem too. The Division is evaluating whether firms are adequately describing their AI usage and the risks that come with it.
For small RIAs, the practical takeaway: review your Form ADV and marketing materials. If you mention AI, make sure it's accurate. If you're using AI in meaningful ways and haven't disclosed it, update your filings.
Examiners expect to see written policies that address:
The SEC isn't expecting small firms to have a 50-page AI governance framework. But they do expect something in writing. If an examiner asks "What's your firm's policy on using AI?" and the answer is "we don't have one," that's a deficiency finding waiting to happen.
This is the subtler requirement. The SEC is looking at whether your actual use of AI tools aligns with what you've told clients and regulators. If you claim AI drives your investment decisions, examiners want evidence. If you say you don't use AI but your team is running portfolio analysis through Claude or GPT, there's a disconnect.
The Division has also flagged that it will evaluate AI usage in the context of cybersecurity and operational resiliency — meaning your AI tools are part of your broader technology risk profile.
You might be thinking: "I'm a two-person RIA managing $50 million. The SEC isn't going to examine me about AI." And historically, you'd probably be right.
But the 2026 priorities also emphasize examinations of newly registered advisers and firms that haven't been examined recently. Small firms that have operated for years without an SEC exam may find themselves on the list — and when they do, AI will be on the examiner's checklist.
The reality is that AI adoption at small firms has exploded. Advisors are using AI tools for client communication, compliance tasks, research, and portfolio management. The SEC knows this, and the 2026 priorities reflect their expectation that even small shops have basic governance in place.
You don't need to overhaul your firm to prepare. Here's what's proportionate for a small RIA:
Inventory your AI tools. Make a simple list of every AI-powered tool your firm uses — including general-purpose tools like ChatGPT. Note what each is used for and who uses it.
Write a short AI usage policy. A one-to-two page document covering acceptable uses, prohibited uses (e.g., sharing non-public client data with consumer AI tools), and review procedures is sufficient. The SEC wants to see that you've thought about it.
Review your disclosures. Check your ADV Part 2A, website, and any marketing materials. Do they accurately reflect how you use (or don't use) AI? Update anything that's misleading or outdated.
Train your team. Even a 30-minute conversation about AI do's and don'ts counts. Document that it happened.
Log your monitoring. Periodically review what AI tools are being used and how. Keep a record. Examiners want evidence of ongoing oversight, not just a policy that sits in a drawer.
AI isn't the only focus area. The SEC also highlighted:
For small RIAs, the pattern is clear: the SEC expects the same compliance fundamentals from a 5-person firm as from a 500-person firm. The scale of your program can differ, but the substance can't.
Regulatory shifts like these are exactly the kind of thing that slips through the cracks when you're running a small firm. You're managing portfolios, meeting with clients, and handling operations — the last thing you have time for is reading 40-page SEC exam priority documents.
That's why we built Pulsio. We monitor SEC, FINRA, and federal regulatory sources daily, classify every change against your firm's specific profile, and deliver plain-English impact briefs so you know exactly what applies to you. No more guessing. No more missed deadlines. Sign up for free alerts at pulsio.ai and let us do the regulatory reading for you.
Sources: SEC Division of Examinations 2026 Priorities · Harvard Law: 2026 SEC Exam Priorities and Implications · Goodwin: 2026 SEC Exam Priorities for RIAs · KPMG: SEC 2026 Priorities