SEC 2026 Examination Priorities
A Back-to-Basics Agenda with Familiar Risks Ahead
What Compliance Teams Need to Know
The Securities and Exchange Commission’s (SEC) Division of Examinations has released its Fiscal Year 2026 Examination Priorities, and the tone marks a subtle, but meaningful shift. With new leadership changes influencing the Division’s direction, including the regulatory philosophy associated with Commissioner Paul Atkins, the program reflects a return to fundamentals: fiduciary duty, conflicts management, accurate disclosure, and core compliance governance. This “back-to-basics” approach does not signal a softer SEC. Instead, it underscores a renewed focus on the foundational protections expected by the investing public, even as markets, technologies, and business models evolve.
The Division states plainly that its work remains grounded in its Four Pillars—promoting compliance, preventing fraud, informing policy, and monitoring risk. What stands out in the 2026 priorities is an emphasis on strengthening the examination program itself and ensuring that it aligns with the Commission’s broader direction. The Division frames this moment as an opportunity to build on past strengths while sharpening the focus on meaningful misconduct and operational effectiveness. Some commentators have described this year’s priorities as concentrating on “speeding tickets, not parking tickets,” reflecting a more risk-oriented, less technical approach to examinations.
At the heart of the 2026 priorities is a reaffirmation that promoting compliance is not merely one pillar of the mission; it is an essential function. The SEC makes it clear that investment advisers’ compliance programs will be examined not only for the quality of their written policies, but also for the extent to which those policies are implemented, enforced, and tailored to the firm’s specific conflicts and business practices. Fee-related conflicts receive particular attention. Examiners will look closely at whether advisers fully disclose compensation structures, revenue incentives, and account-type recommendations, and whether those disclosures make clear how advisers are addressing the inherent conflicts of interest. The Division reiterates that advisers’ fiduciary obligations remain central, and that placing client interests first is not optional.
This focus extends across investment companies and broker-dealers, where expense allocation, valuation practices, liquidity risk programs, and books-and-records compliance continue to be significant areas of review. Broker-dealers, in particular, should expect ongoing scrutiny of their obligations under Regulation Best Interest, including the supervision of recommendations, the reasonableness of product selection, and the impact of compensation incentives on retail investors. The 2026 document reinforces a multi-year pattern: the SEC expects firms not only to identify conflicts, but to demonstrate that they are actively managing them.
One aspect of the 2026 priorities has drawn considerable attention: the absence of explicit references to “crypto” or “digital assets.” After years in which digital assets featured prominently in industry headlines and regulatory activity, the omission is notable. But firms should resist the temptation to infer a lack of interest. The underlying message is consistent with the broader reframing: if fraud is present, if conflicts exist, or if a product functions as a security, exam and enforcement interest can follow. Digital assets do not need to be named explicitly for compliance teams to understand that the underlying conduct, and the investor protection mandate remains firmly within the SEC’s jurisdiction.
What Compliance Teams Should Pressure-Test Now
For Compliance leaders, the takeaway is straightforward: the fundamentals matter more than ever, and ‘paper programs’ will not be enough. Examiners will expect firms to maintain robust personal-trading programs, effective management of material nonpublic information, and documented enforcement of code-of-ethics provisions. They will look closely at how firms identify and manage conflicts arising from compensation structures, outside business activities, and proprietary products. They will expect accurate, complete, and timely disclosures to investors. They will assess cybersecurity governance, operational resiliency, vendor oversight, and business-continuity planning with increasing intensity. And they will expect firms to demonstrate surveillance capability across all relevant assets and venues—whether traditional securities, tokenized instruments, or other financial innovations.
A practical way to interpret the 2026 priorities is this; exams will continue to reward firms that can show:
- Clear ownership
- Tested controls
- Documented follow-through
- Management visibility
Where Technology Fits
Meeting these expectations at scale is increasingly an operational challenge, not a policy-writing exercise. Many firms are investing in technology and workflow design that helps them operationalize core exam themes: pre-clearance and attestations, post-trade surveillance, integrated monitoring across traditional and digital assets, policy management tied directly to firm-specific risks, and reporting that demonstrates implementation and enforcement.
StarCompliance (Star) supports these outcomes by helping firms unify surveillance, disclosure, and governance across the enterprise – so compliance teams can demonstrate not just intent, but execution. As exam teams continue to focus on effectiveness ‘in practice,’ platforms that reduce fragmentation and improve auditability can materially strengthen exam readiness.
Bottom Line
The SEC’s 2026 priorities may use a simpler vocabulary and a more traditional regulatory posture, but they are not easing expectations. They reflect an SEC that intends to reinforce the core principles of investor protection with renewed clarity and consistency. For firms operating in an environment that spans both traditional and digital markets, this year’s priorities are a reminder that effective compliance is less about chasing trends and more about executing the fundamentals with discipline – and being able to evidence that discipline under scrutiny.
If your firm has any exposure to employee crypto or tokenized-asset activity, it’s worth pressure-testing that slice of your program now—especially given the SEC’s 2026 “back-to-basics” emphasis on conflicts, MNPI controls, accurate disclosures, and proving your policies operate in practice.
Star offers a wide range of tools to help firms strengthen oversight and stay ahead of evolving regulations. Download our timely Crypto Trading Compliance Checklist to benchmark your program, uncover monitoring gaps, and elevate exam readiness with confidence.
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