Form ADV, Form PF and N-CEN deadlines
Deadlines: the full filing calendar · the regulation library · practical guides
Three filings, three regulators' worth of detail, and all of them in one quarter. The ADV amendment is the one with the hardest date, because it is fixed to the fiscal year end rather than negotiable. In the United States the filing is due within 75 days of the fund's fiscal year end. Source: SEC Investment Company Reporting Modernization FAQ (Form N-CEN). For a 31 December year end that works out as 16 March 2027. It lands on the registered fund.
What is the US adviser filing?
These are the annual SEC filings a fund manager makes. Form ADV is the adviser's public registration and disclosure form, updated within 90 days of its fiscal year end. Form PF is a confidential systemic-risk report from larger private-fund advisers. Form N-CEN is the annual census for registered investment companies (SEC: Form ADV instructions).
What is in the report
Form ADV Part 1 gives regulatory data on the firm, its owners, clients and assets; Parts 2A and 2B are the plain-English brochures. Form PF reports fund size, leverage, liquidity and counterparty exposure. Form N-CEN reports the fund's structure and its service providers.
Who files, who prepares, who receives
A registered investment adviser files the ADV amendment. A private fund adviser over the reporting thresholds files Form PF. A registered investment company files N-CEN. One adviser can be inside all three, and each filing goes to the SEC.
This page carries 3 confirmed deadlines for the US adviser filing, each with the date its own regulator publishes.
When it is due
| Jurisdiction | Obligation | Due | Reporting period | Who files | Files with | Extension | Source |
|---|---|---|---|---|---|---|---|
| United States | Form N-CEN annual census report | within 75 days of the fund's fiscal year end | the fund's prior fiscal year | the registered fund | SEC | — | SEC Investment Company Reporting Modernization FAQ (Form N-CEN) · calendar |
| United States | Form ADV annual updating amendment — all Parts 1 & 2 updated | within 90 days of the adviser's fiscal year end | the adviser's prior fiscal year | the investment adviser | SEC | — | SEC Form ADV General Instructions · calendar |
| United States | Form PF annual update — private fund reporting | within 120 days of the adviser's fiscal year end | the adviser's prior fiscal year | the investment adviser | SEC | — | SEC Form PF FAQ (Division of Investment Management) · calendar |
Common mistakes
Form ADV and Form PF are not one exercise. They ask overlapping questions on different bases, and answering PF from the ADV numbers is how inconsistencies get filed. Examiners read the two side by side, which is exactly where a mismatch shows. The 90-day ADV clock also runs from the fiscal year end, so a non-calendar year end moves the date.
Questions this page answers
When is the Form ADV annual updating amendment due?
Within 90 days of the adviser's fiscal year end for an adviser with a December fiscal year end. The rule is ninety days after the fiscal year end, so a non-calendar year end moves the date.
When is the Form PF annual update due?
Within 120 days of the adviser's fiscal year end for annual filers. Larger advisers report on shorter cycles, so the annual date is the floor rather than the whole obligation.
What is the Form N-CEN deadline?
Within 75 days of the fund's fiscal year end. N-CEN is the annual census report for registered investment companies, filed on EDGAR alongside the adviser's other filings.