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We're hearing it consistently from prospects as we enter 2026: mandatory Investment Adviser Representative (IAR) Continuing Education (CE) requirements have blindsided them.
Despite the fact that the IAR CE Model Rule was adopted by the North American Securities Administrators Association (NASAA) years ago, many RIAs and their representatives are only now discovering a compliance gap. The primary problem? Many advisors rely on third-party compliance companies or general counsel who missed the individual state adoption deadlines.
The 2026 Reality: "CE Inactive" Status is Live
This is no longer a "future" risk. For many, this is an immediate compliance failure that has left IARs facing double CE requirements to keep their registrations active.
The most common point of shock is the timing of state adoptions.
- The 2024 Adopters: States like Florida, California, and Colorado made the rule effective in 2024. If an IAR in these states missed the December 31, 2024 deadline, they entered 2025 in a deficit.
- The 2025 Adopters: States like New Jersey, Minnesota, and Nebraska went live last year.
The penalty window puts you at risk of eventually being classified as “CE Inactive,” if you do not catch up on your 2024 credits and complete your 2025 credits. This status will lead to the termination of your IAR registration in that state, which means you can no longer conduct business there.
The Critical Catch-24: If you are currently "CE Inactive" because you missed your 2024 or 2025 credits, you now owe 24 hours of CE (the missed year + the current 2026 requirement) to prevent your registration from being terminated.
IAR Continuing Education: The Quick Facts
Here is a breakdown of the mandatory IAR CE requirements for IARs registered in a state that has adopted the NASAA Model Rule:
IAR CE Requirement FAQs
Q: What happens if an IAR misses the Continuing Education deadline?
A: If an IAR misses the deadline, they are first placed in a “CE Inactive” status for one year. If the IAR still has not completed the overdue CE hours by the end of that inactive period, their IAR registration in that state will be terminated.
Q: Do IARs need to complete CE for every state in which they’re registered?
A: No. An IAR subject to the rule only needs to complete the total 12 credit hours once per year, regardless of how many states they are registered in that have adopted the Model Rule.
Q: Can I use my CFP CE or CPA CPE credits to satisfy the IAR requirement?
A: Possibly. If the IAR maintains an approved professional designation (like CFP or CPA), the CE completed for that designation may satisfy the IAR requirement, provided the course meets the specific NASAA IAR content and credit hour breakdown (6 hours regulatory/ethics, 6 hours products/practice, with 3 hours dedicated to ethics) and the course provider is an authorized vendor.
IAR CE Requirement FAQs
The IAR CE requirement is just one example of a regulatory change that can slip past firms without dedicated, ongoing compliance oversight. If your firm’s compliance support failed to notify you of a mandatory requirement like this, it points to deeper structural weaknesses in your regulatory preparedness.
Don't wait until your advisors are designated “CE Inactive.” Take this opportunity to conduct a full review of your firm’s registration and CE status.
Seamless CE Solution: Access Through AdvisorLaw's Partner Network
To provide comprehensive resources to help IARs meet their CE requirements, AdvisorLaw has an established partnership with Financial Experts Network.
Through this partnership, IARs can access self-study courses approved for both the ethics and regulatory and products and practices categories, covering essential topics relevant to your firm's advisory services. These programs are available for immediate use.
To see our available courses and begin working toward compliance, visit the Financial Experts Network site. As always, AdvisorLaw’s team of compliance specialists is available should you have any questions.
Engage with our experts today!