Washington, D.C. (July 29, 2026) – Artificial Intelligence (AI) has extended its lead as the leading compliance priority for investment adviser firms, according to the 2026 Investment Management Compliance Testing (IMCT) Survey, released today by Investment Adviser Association, ACA Group, and Yuter Compliance Consulting.
Now in its 21st year, the IMCT Survey remains the industry’s most comprehensive benchmark for compliance testing practices and priorities.
This year’s results reflect a compliance function undergoing significant change, with AI, cybersecurity, and privacy/Regulation S-P emerging as the top three “hot” compliance topics. These areas closely align with the SEC’s 2026 Examination Priorities and ongoing regulatory focus on data protection, third-party oversight, and operational resilience. The full list of hot compliance topics for 2026 includes:
- Artificial Intelligence (85%)
- Cybersecurity (37%)
- Privacy/Regulation S-P (35%)
- Advertising/Marketing (19%)
- Prediction Markets (14%)
- Vendor Due Diligence (10%)
- Digital Assets (9%)
- Conflicts of Interest (9%)
- Alternative Investments for Retail Investors (8%)
- Valuation (7%)
Notable Findings
The 2026 IMCT Survey, conducted online during April and May 2026, covered a wide range of topics. In addition to the top compliance hot topics, the survey provided notable findings on subjects such as:
- AI takes the lead by a wide margin. 85% of respondents identified AI as their “hottest” topic for 2026, a 28 percentage-point increase from the previous year and nearly 50 percentage points ahead of the second-ranked topic. AI adoption has also expanded: 80% of firms are now using AI in some capacity, with 70% limiting AI to internal use cases, 10% permitting internal and external use, and 18% still exploring. Firms have made real progress on governance, with 86% establishing AI policies and procedures, 86% maintaining an inventory of approved AI tools, 72% updating training to cover AI risks, and 72% increasing compliance testing for AI. Even so, opportunities remain around incident response planning, third-party AI oversight, and formal validation of AI outputs.
- Regulation S-P readiness dominates the privacy agenda. With the amendments’ compliance dates falling on December 3, 2025 and June 3, 2026, firms have been focused on meeting the new safeguarding, disposal, and incident notification requirements. 83% of firms have updated their information security policies and procedures, and 53% have formalized their incident response plans. Implementation has not been friction-free, however: 67% of firms cited difficulty securing confirmation that service providers will notify them within the required 72-hour window, 48% flagged challenges negotiating vendor oversight arrangements, and 39% pointed to data mapping as an ongoing hurdle.
- Third-party risk management is being rebuilt across the industry. 60% of firms have made or are making significant changes to their third-party risk management programs, and 48% have increased compliance testing around vendor due diligence. The most common enhancements include updated TPRM policies and procedures (69%), revised vendor risk-tiering criteria (58%), expanded due diligence for key service providers (54%), and clearer internal ownership of vendor relationships (49%). Firms are also using contractual mechanisms to lock in Reg S-P’s 72-hour incident notification requirement across their vendor base.
- Compliance teams continue to do more with less. Even as responsibilities expand, staffing and budgets have held steady. 60% of CCOs serve in multiple executive roles (with 19% also serving as COO, 17% as GC, and 12% as CFO). 61% of firms spend between $100,001 and $999,999 annually on compliance, and 45% of compliance departments operate with just two to five employees, including the CCO. Compliance leaders are increasingly leaning on risk-based approaches and technology to close the gap.
About the Survey Respondents
Compliance professionals at 411 investment adviser firms participated in the survey. All firm sizes were represented, with 23% of respondents managing less than $1 billion in assets, 37% managing $1 billion to $10 billion, and 40% managing more than $10 billion. Close to 40% of responding firms reported having between 11 and 50 employees, consistent with industry data showing that most investment advisers are small- to mid-sized businesses. This year’s survey also revealed that 60% of CCOs continue to wear more than one hat, with 17% also serving in some legal capacity as General Counsel.
Services provided by responding firms spanned the full range of client types, including private funds (58%), institutional clients (56%), high net worth individuals with a typical account size of $1 million or more (54%), ERISA assets/pension consultants (38%), registered investment companies (37%), retail individuals with a typical account size of $1 million or less (34%), and family offices (24%).
Full results of the 2026 Investment Management Compliance Testing Survey are available on the IAA’s, ACA’s, and YCC’s websites and 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. The IAA’s member firms manage more than $57 trillion in assets for a wide variety of institutional and individual investors. 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 over 20 years, ACA has empowered clients to launch, grow, and protect their businesses. Its global team of 1,700 professionals includes former regulators and industry practitioners. CNBC recognized ACA as one of the World’s Top Fintech Companies in 2026. ACA’s innovative approach integrates advisory, managed services, distribution solutions, and analytics with its ComplianceAlpha® technology platform. 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. She 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. For more information, visit www.yutercompliance.com.
Press Contacts
At the IAA, please contact Janay Rickwalder at janay.rickwalder@investmentadviser.org. At ACA Group, please contact Gregory FCA at aca@gregoryfca.com. At Yuter Compliance Consulting, please contact Amy Yuter at ayuter@yutercompliance.com.
