Gana Misra
By Gana MisraCEO, Finrep
Thu Sep 17 2026

13F Filing Dates 2026: Every Deadline, the Adjustment Logic, and What to Do Now

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13F Filing Dates 2026: Every Deadline, the Adjustment Logic, and What to Do Now

13F Filing Dates 2026: Every Deadline, the Adjustment Logic, and What to Do Now

If your firm exercises investment discretion over $100 million or more in Section 13(f) securities, you have four hard filing dates in 2026. Two of them are not the dates a raw calendar calculation produces, and that gap between the statutory 45-day window and the operative business-day-adjusted deadline is exactly where compliance teams get caught out.

This walkthrough gives you the exact dates, shows the arithmetic behind each one, flags the 2022 form amendments that are still causing EDGAR rejections, and closes with a practical pre-filing checklist.

Key takeaway: The four 13F filing dates for 2026 are February 17, May 15, August 14, and November 16. Two of those dates (February 17 and November 16) are adjusted from a Saturday, so if your compliance calendar still shows February 14 or November 14, fix it today.

What Are the 13F Filing Dates for 2026?

All four operative deadlines are listed below, alongside the quarter-end period each covers, the raw 45-day calculation, and the adjustment applied.

Rule 13f-1(a)(1) requires institutional investment managers to file no later than 45 calendar days after the last day of each calendar quarter. When that 45th day lands on a Saturday, Sunday, or federal holiday, the deadline rolls forward to the next business day.

Quarter-End PeriodRaw 45-Day DateAdjusted Operative DeadlineWhy Adjusted?
December 31, 2025 (Q4 2025)February 14, 2026February 17, 2026February 14 is a Saturday
March 31, 2026 (Q1 2026)May 15, 2026May 15, 2026No adjustment needed
June 30, 2026 (Q2 2026)August 14, 2026August 14, 2026No adjustment needed
September 30, 2026 (Q3 2026)November 14, 2026November 16, 2026November 14 is a Saturday

The SEC's own FAQ makes the February adjustment explicit: "the deadline for the December 31, 2025 Form 13F report will be no later than February 14, 2026, a Saturday" -- which means the operative filing deadline is Monday, February 17. Day Pitney LLP's 2026 investment manager compliance calendar confirms all four dates, each "as adjusted to the next business day."

How the Business-Day Adjustment Works: Step by Step

Most deadline lists just publish the adjusted date without showing the work. Here is the three-step logic so you can verify any future quarter yourself.

  1. Count 45 calendar days from the last day of the quarter. For Q4 2025: December 31 plus 45 days lands on February 14, 2026.
  2. Check whether that date is a Saturday, Sunday, or federal holiday. February 14, 2026 is a Saturday. November 14, 2026 is also a Saturday.
  3. Roll forward to the next business day. Saturday February 14 becomes Monday February 17. Saturday November 14 becomes Monday November 16.

For Q1 and Q2 2026, the raw calculation already lands on a weekday with no federal holiday conflict, so no adjustment applies.

This logic matters year to year because the calendar shifts. WhalewWisdom's filing date table illustrates this clearly: the Q1 2027 deadline moves to May 17, not May 15, because the 45-day count falls differently in 2027. Never carry forward prior-year dates without rerunning the arithmetic.

Who Must File Form 13F?

An institutional investment manager that exercises investment discretion over $100 million or more in Section 13(f) securities must file, under Section 13(f) of the Securities Exchange Act of 1934. Three mechanics matter in practice.

The $100 Million Threshold Is Measured Monthly, Not Annually

The threshold is assessed on the last trading day of any month of any calendar year. Cross $100 million in Section 13(f) securities in a single month and you have triggered the filing obligation for the next calendar year, even if your holdings fall back below that level in subsequent months. This catches first-time filers off guard more than almost any other rule.

The Threshold Applies to Section 13(f) Securities, Not Total AUM

Section 13(f) securities are exchange-traded equities, certain equity options and warrants, shares of closed-end investment companies, and certain convertible debt securities. A manager with $300 million in total AUM but only $90 million in Section 13(f) securities does not file. Fixed income, private equity, and most derivatives do not count toward the threshold. The SEC publishes the official list of Section 13(f) securities shortly after each quarter-end.

Foreign Managers and Government Entities Are Not Exempt

Foreign institutional investment managers must file if they use any means or instrumentality of U.S. interstate commerce and exercise investment discretion over $100 million or more in Section 13(f) securities, per SEC Release No. 34-14852 (June 15, 1978). Municipal pension funds, sovereign wealth funds, and other government-related entities are also institutional investment managers for 13F purposes. The SEC FAQ is explicit that "person" for these purposes includes "a natural person, company, government, or political subdivision, agency, or instrumentality of a government."

For a deeper look at threshold mechanics and what counts as investment discretion, see Finrep's SEC 13F reporting requirements compliance guide.

What the 2022 Form Amendments Mean for Your 2026 Filing

The SEC adopted amendments to Form 13F on June 23, 2022 (SEC Release No. 34-95148), effective January 3, 2023. These are not new for 2026, but they are still generating EDGAR errors and compliance questions for managers who have not fully updated their workflows.

Here is what changed and what it means operationally:

  • Dollar-level rounding. Report dollar values to the nearest dollar, not the nearest $1,000 as under the old form. If your data vendor or internal system is still outputting thousands-rounded figures, your XML will be wrong.
  • CRD number and SEC file number. The amended form requires managers to report their Central Registration Depository (CRD) number and SEC file number as additional identifiers. If your firm is not SEC-registered, confirm whether a CRD number applies.
  • FIGI option. You may now include a Financial Instrument Global Identifier (FIGI) for each reported security in addition to the CUSIP. This is optional, not mandatory, but some data providers now supply it automatically.
  • Confidential treatment checkbox. The Summary Page now includes a checkbox indicating when confidential treatment is being requested for any portion of the filing. Failing to check it when a confidential treatment request (CTR) is pending creates a mismatch the SEC will flag.
  • Electronic CTRs only. Since February 28, 2023, all Form 13F confidential treatment requests must be filed electronically on EDGAR. Paper CTRs are no longer accepted. If your process still routes CTRs to paper, it is broken.

Key takeaway: The 2022 amendments are live and have been mandatory since January 2023. If your EDGAR XML template predates January 3, 2023, rebuild it before your next filing.

How to File Form 13F on EDGAR: The Mechanics

All 13F filings must be submitted via EDGAR in XML format. The text-based ASCII format was discontinued on May 20, 2013. There are two paths:

  1. Use the EDGAR online form and construct the Information Table according to the EDGAR XML Technical Specification.
  2. Construct the entire filing in XML per the Technical Specification and upload it directly.

Either way, the EDGAR system accepts filings from 6:00 a.m. to 10:00 p.m. ET on weekdays, excluding federal holidays. The critical trap: filings submitted after 5:30 p.m. ET receive the next business day's filing date. A 13F uploaded at 5:45 p.m. on August 14 is technically filed August 17 and is late. Form 13F is not one of the exceptions (Schedules 13D/13G and Section 16 filings get the actual filing date up to 10:00 p.m.; 13F does not).

Build your internal deadline around 5:00 p.m. ET, not 10:00 p.m. That buffer absorbs last-minute EDGAR system issues, reviewer sign-offs, and XML validation errors that only surface when you are rushing.

For a detailed walkthrough of the EDGAR submission process and the five operational traps that turn a timely filing into a late one, see Form 13F filing deadline: 5 operational traps beyond the 45-day rule.

What Happens If You Miss a 13F Deadline?

The SEC does not grant extensions for Form 13F. The SEC FAQ directs a manager that misses a deadline to file as soon as possible and not to submit a misleading or incorrect filing. In practice, the SEC typically sends deficiency letters to late filers and may refer persistent or egregious non-filers to the Division of Enforcement. Section 13(f) violations can result in civil penalties under the Securities Exchange Act.

The practical compliance posture: file late rather than not at all, document the reason for the delay, and consult counsel about whether voluntary disclosure or a no-action inquiry is appropriate.

Other Obligations That Cluster on the Same Dates

The four 13F filing dates in 2026 are not the only deadlines landing on February 17, May 15, August 14, and November 16. Two other obligations share the same calendar.

Schedule 13G Quarterly Assessments

Per amendments effective September 30, 2024, qualified institutional investors must now assess Schedule 13G filing obligations at the end of each calendar quarter rather than annually. The 2026 quarterly assessment deadlines for Schedule 13G are February 17, May 15, August 14, and November 16 -- the same four business-day-adjusted dates as Form 13F. Many 13F filers also hold positions that trigger 13G obligations, so these dates create a compliance cluster that requires coordinated resourcing. See Finrep's Schedule 13G passive investor eligibility walkthrough for the threshold and amendment mechanics.

Form 13H Annual Update

Large traders -- those effecting transactions in National Market System securities of 2 million shares or $20 million in any calendar day, or 20 million shares or $200 million in any calendar month -- must file an annual Form 13H update within 45 days after calendar year-end. For calendar year 2025, that deadline is February 17, 2026, the same date as the Q4 2025 Form 13F. If your firm qualifies as both a 13F filer and a large trader, February 17 carries two separate EDGAR submissions.

Form N-PX

Institutional investment managers that file Form 13F should also assess their Form N-PX obligations. Form N-PX requires annual reporting of proxy voting records and is due no later than August 31 of each year. The N-PX obligation is not automatic for all 13F filers, but the overlap in filer population is significant. If your firm votes proxies on any of the securities reported in your 13F, N-PX likely applies.

2026 13F Compliance Checklist

Use this checklist to structure your quarterly 13F workflow. Build in at least five to ten business days before each SEC deadline for data aggregation, review, and EDGAR testing.

Threshold and scope (ongoing)

  • Confirm whether the firm crossed $100 million in Section 13(f) securities on the last trading day of any month in the prior calendar year
  • Pull the current SEC Official List of Section 13(f) Securities for the relevant quarter-end
  • Identify all accounts over which the firm exercises investment discretion (including sub-advised and model portfolios)
  • Assess whether foreign accounts using U.S. interstate commerce are in scope

Data preparation (10+ business days before deadline)

  • Aggregate position data as of the quarter-end date
  • Reconcile holdings against the Section 13(f) securities list
  • Confirm dollar values are rounded to the nearest dollar (not thousands) per the 2022 amendments
  • Verify CUSIP numbers; add FIGI identifiers if your data provider supplies them
  • Confirm CRD number and SEC file number are populated in the filing header

Confidential treatment (if applicable)

  • Determine whether any holdings warrant a confidential treatment request
  • Check the Summary Page checkbox for confidential treatment
  • Prepare and file the CTR electronically on EDGAR (paper CTRs are not accepted since February 28, 2023)

EDGAR submission (by 5:00 p.m. ET on the deadline date)

  • Validate the XML against the EDGAR XML Technical Specification before submission
  • Submit via EDGAR by 5:00 p.m. ET to avoid the next-business-day filing date trap
  • Retain the EDGAR acknowledgment and filing confirmation
  • Assess Form N-PX obligation for the August 31 annual deadline
  • Assess Schedule 13G quarterly assessment obligation for the same deadline date

FAQ

What are the due dates for Form 13F reporting in 2026? The four operative deadlines are February 17 (Q4 2025 holdings), May 15 (Q1 2026), August 14 (Q2 2026), and November 16 (Q3 2026). February 17 and November 16 are adjusted from Saturdays (February 14 and November 14, respectively) to the next business day.

How often do 13F filings come out? Form 13F is a quarterly filing. Managers must file within 45 calendar days after the end of each calendar quarter, producing four filings per year covering holdings as of December 31, March 31, June 30, and September 30.

How delayed are 13F filings? The statutory window is 45 calendar days after each quarter-end. That means the public sees Q4 holdings in mid-to-late February, Q1 holdings in mid-May, Q2 holdings in mid-August, and Q3 holdings in mid-November. The data reflects positions from six to seven weeks prior to publication.

Is February 14 or February 17 the Q4 2025 13F deadline? February 17, 2026 is the operative deadline. The raw 45-day calculation from December 31, 2025 produces February 14, which is a Saturday. The SEC FAQ explicitly confirms the deadline rolls to Monday, February 17.

What happens if a 13F is filed late? The SEC does not grant extensions. Late filers should submit as soon as possible. The SEC typically issues deficiency letters and may refer persistent non-filers to enforcement. Civil penalties under the Securities Exchange Act are possible for Section 13(f) violations.

Does filing Form 13F trigger Form N-PX obligations? Not automatically, but the filer populations overlap significantly. If your firm votes proxies on securities reported in your 13F, Form N-PX likely applies. The annual N-PX deadline is August 31 each year.

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