Updated October 19, 2026. Source: SEC Form 13F FAQs, accessed October 19, 2026. Informational guidance only; consult your qualified adviser about your specific filing obligation.
Your firm has grown — congratulations. But with that growth comes a new compliance obligation that many emerging advisors aren’t fully prepared for: Form 13F. If your firm manages $100 million or more in Section 13(f) securities, federal law requires you to file quarterly disclosures with the SEC. The challenge for newly required filers isn’t understanding what the form is — it’s figuring out exactly when you need to start, and how to build the infrastructure to file correctly going forward.
How the $100 Million Threshold Works
If an institutional investment manager exercises investment discretion over $100 million or more in Section 13(f) securities on the last trading day of any month during a calendar year, its first report generally covers the December quarter of that same calendar year, followed by reports for March, June, and September of the next year. Reports are due within 45 days after quarter-end, with applicable weekend and holiday adjustments.
Only Section 13(f) securities count toward this threshold; do not substitute total regulatory AUM. Crossing the threshold mid-year does not generally start a first-time filer with that year’s March, June, or September report. The first report generally covers December of that year. Continue monitoring monthly to determine whether another annual filing cycle is triggered.
Example: A manager first reaches $112 million in discretionary Section 13(f) securities on the last trading day of June 2026. Its first report generally covers December 31, 2026, due February 16, 2027 under the SEC’s published calendar. It must also report for March, June, and September 2027, even if its holdings subsequently fall below $100 million. See the SEC-listed filing calendar.
What You Need to Set Up Before Your First Filing
Many first-time filers are surprised by the infrastructure required before a 13F can even be submitted. None of this can be assembled at the last minute.
Step 1 — Confirm Your EDGAR Filer Account. Every filer needs a Central Index Key (CIK) issued by the SEC. Form ADV registration does not by itself establish EDGAR access. Confirm whether your firm already has an EDGAR account; if it does not, follow the SEC’s Form ID process.
Step 2 — Set Up EDGAR Next Access. Authorized individuals use their own Login.gov credentials and multi-factor authentication. Account administrators manage filer roles and any filing-agent delegation. Do not share passwords or verification codes. See our EDGAR Next signup and delegation guide.
Step 3 — Map Your Data Sources. Identify which custodians and portfolio management systems hold the data you’ll need, and what export formats are available.
Step 4 — Understand Your Discretion Arrangements. Review your investment management agreements to understand which accounts are fully discretionary, non-discretionary, or shared. This directly affects what must be reported and how.
Step 5 — Plan for XML Preparation. Form 13F must be submitted in SEC-specified XML format. Unless your portfolio management system generates compliant 13F XML directly, you’ll need a purpose-built tool or a professional service provider.
Common Questions from First-Time Filers
Do I have to file even if I cross $100M mid-year? Yes. The threshold is tested on the last trading day of any month, not only at year-end. If an institutional investment manager exercises investment discretion over $100 million or more in Section 13(f) securities on the last trading day of any month during a calendar year, its first report generally covers the December quarter of that same calendar year, followed by reports for March, June, and September of the next year. Reports are due within 45 days after quarter-end, with applicable weekend and holiday adjustments.
Does each portfolio manager have to file separately? No. The obligation falls at the firm level — your firm files one consolidated 13F covering all discretionary positions across all accounts it manages.
What if my AUM drops below $100M? A later decline does not cancel the four-report cycle already triggered. If the threshold is not reached on the last trading day of any month in the following year, the December report for that following year may not be required. Consult qualified counsel before stopping, and review SEC FAQs 25, 27, and 28.
First-time filers are not given a grace period by the SEC. The firms that struggle most with their initial 13F filings are those that treat it as a last-minute task. Start building your workflow now. Contact File|13F — we specialize in helping newly required advisors get their first 13F right.