AI has emerged as the overwhelming top compliance priority for investment adviser firms, according to the 2026 Investment Management Compliance Testing (IMCT) Survey, released today by the Investment Adviser Association (IAA), ACA Group (ACA), and Yuter Compliance Consulting (YCC). The survey found that 85% of respondents identified AI as the hottest compliance topic for 2026, a 28-percentage-point increase from 2025, and the most dominant single response in the survey’s 21-year history.
The IMCT Survey remains the industry’s most comprehensive benchmark for compliance testing practices and priorities among investment adviser firms. The full list of top compliance topics for 2026 includes:
- AI (85%)
- Cybersecurity (37%)
- Privacy/Regulation S-P (35%)
- Advertising and Marketing (19%)
- Prediction Markets (14%)
Notable Findings
The 2026 IMCT Survey, conducted online from late April through May 2026, covered a broad range of compliance topics. The survey produced notable findings across several key areas:
- AI dominates compliance testing priorities. In prior years, AI consistently ranked among the most-watched compliance topics, while firms were still in the early stages of implementing AI and related testing programs. The 2026 survey marks a measurable shift: 72% of firms reported increasing their compliance testing around AI, the single largest year-over-year increase of any topic tracked. This reflects a growing recognition that implementation of tools, policies, and governance frameworks must be matched by active testing and validation programs. Other top areas of increased testing include cybersecurity (58%), Privacy/Reg S-P (58%), and vendor due diligence (48%). Notably, ESG was the rare area to see a decrease in testing, with 15% of firms reducing testing in that category.
- The progress on AI policy adoption has been significant. 80% of firms have now formally adopted AI tools. 86% have acceptable use policies (AUPs) in place, up from approximately 64% in a comparable survey conducted in fall 2025, and 86% maintain an inventory of AI tools used by their firm. Additionally, 59% of firms have established a formal AI governance committee.
- Firms have opportunities to continue to evolve their AI policies. These include: 48% of firms have a formal policy, plan, or procedure for human-in-the-loop oversight of AI outputs, and 37% have policies and procedures governing the testing and validation of AI outputs. Less than a third (30%) have policies addressing third-party AI use. And 14% have updated their incident response plans to account for AI-related disruptions. As AI adoption matures, these policies represent the next frontier for compliance programs seeking to align governance frameworks with operational reality.
- SEC exam focus areas remain remarkably consistent. Despite a new SEC administration and shifting regulatory climate, the topics most frequently examined have held steady year over year and remain broadly consistent with examination priorities seen throughout prior SEC administrations. The top focus areas in recent exams include Advertising and Marketing (57%), Books and Records (53%), Conflicts of Interest (53%), Fee Calculation and Billing (48%), and Personal Trading/Code of Ethics (36%).
- Compliance program structure and resourcing hold steady from 2025. 45% of firms have between two and five staff in their compliance program. Approximately 60% of CCOs hold multiple responsibilities, including CCO/CFO (19%) and CCO/General Counsel (17%) combinations – a pattern that reflects compliance programs continuing to do more with less. Compliance budgets have likewise remained broadly consistent year over year, though the range is wide, with an equal number of firms reporting budgets below $100,000 and above $2 million.
- Third-party risk management is evolving in response to regulatory scrutiny. 39% of respondents have made significant changes to their third-party risk management (TPRM) programs in response to increased regulatory focus and registrants’ focus on Regulation S-P requirements, and another 22% plan to do so. These updates most commonly include revised policies and procedures (69%), updated vendor risk-tiering (58%), and expanded due diligence requirements (54%). Fourth-party risk remains a significant gap: only 7% of firms have a formal process to assess risks posed by fourth parties used by key service providers.
“In 21 years of this survey, we have never seen a single topic command this kind of separation from everything else on the agenda,” said Carlo di Florio, President of ACA. “What makes this year’s results particularly meaningful is that firms are no longer just naming AI as a concern; they are allocating compliance resources, standing up governance committees, and increasing testing. But the gaps in human oversight, output validation, and third-party AI policies tell us the work is far from done.”
“Investment advisers are taking the challenge of AI governance seriously, and this survey captures that shift in real time,” said Karen Barr, President & CEO of the IAA. “At the same time, the consistency we see in SEC examination focus areas – advertising, books and records, conflicts of interest – is a reminder that firms must address emerging technology risks while continuing to deliver on their core compliance obligations. For the compliance officers bearing those dual responsibilities, this survey remains one of the most valuable benchmarking tools available.”
“The IMCT Survey continues to be the resource compliance professionals rely on to understand where their peers stand and what regulators expect,” said Amy Yuter, Managing Principal of Yuter Compliance Consulting. “This year’s data tells a clear story: AI has moved from the watchlist to the work plan. Firms are focused on drafting policies, forming governance committees, and expanding testing programs as regulatory scrutiny intensifies. The Survey gives compliance teams the clarity they need to build practical, business-aligned frameworks.”
About the Survey Respondents
Compliance professionals at 411 investment adviser firms participated in the 2026 IMCT Survey, which was conducted online from late April through May 2026. The survey was distributed to IAA members, ACA Group clients, and YCC contacts.
Full results of the 2026 Investment Management Compliance Testing Survey are available on the IAA’s, ACA’s, and YCC’s websites or can be viewed here.
About the Investment Adviser Association
The Investment Adviser Association (IAA) is the leading organization dedicated to advancing the interests of fiduciary investment advisers. For nearly 90 years, the IAA has been advocating for advisers before Congress and U.S. and global regulators, promoting best practices and providing education and resources to empower advisers to effectively serve their clients, the capital markets, and the U.S. economy. Our members range from global asset managers to the medium- and small-sized firms that make up the majority of our industry. Together, the IAA’s member firms manage more than $57 trillion in assets for a wide variety of institutional and individual investors, including pension plans, trusts, mutual funds, private funds, endowments, foundations, and corporations. The IAA also provides extensive practical and educational resources to its membership. For more information, visit www.investmentadviser.org or follow us on LinkedIn and YouTube.
About ACA Group
ACA is the leading governance, risk, and compliance (GRC) partner in financial services. For more than 20 years, ACA has empowered clients to launch, grow, and protect their businesses through an innovative combination of advisory, managed services, distribution solutions, and analytics with its ComplianceAlpha® technology platform. CNBC recognized ACA as one of the World’s Top Fintech Companies in 2026, reflecting its commitment to delivering technology-enabled compliance and risk solutions. ACA’s global team of 1,700 professionals includes former regulators and industry practitioners. For more information, visit www.acaglobal.com.
About Yuter Compliance Consulting
Yuter Compliance Consulting (YCC) is a leading, boutique compliance consulting firm, specializing in tailored consultation and support services for registered investment advisers, including asset managers, private equity firms and hedge funds. Amy Yuter, Managing Principal of Yuter Compliance Consulting, has over three decades of industry experience, including as a regulator in the Division of Examinations at the U.S. Securities and Exchange Commission. As a thought leader in the compliance industry, Amy has made significant contributions. Amy is the founder of The Philadelphia Compliance Roundtable and the Investment Management Compliance Testing Survey. YCC partners with clients to provide personalized consultation and support to enhance compliance resources and improve compliance programs. Our deep industry knowledge and regulatory expertise helps us in guiding clients to navigate the complex landscape of financial regulations. For more information, visit www.yutercompliance.com.
Note: Due to rounding, the sum of results may not equal 100%.
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