SEC Form 13F Filing Deadline: The 45-Day Rule Explained (2026)

If you manage $100 million or more in Section 13(f) securities, the Form 13F filing deadline is one of the most operationally unforgiving dates on your compliance calendar. The rule is simple on its face. The traps are not.

This walkthrough covers the official 45-day rule, exactly how to count it, the 2026 calendar dates, the EDGAR cutoff that catches filers off guard, and the mistakes that turn a timely submission into a late one.

What Is the Official SEC Form 13F Filing Deadline?

The official deadline is 45 calendar days after the end of each calendar quarter, as codified in Rule 13f-1(a) under Section 13(f) of the Securities Exchange Act of 1934. The SEC's own Form 13F General Instructions state it plainly:

"Rule 13f-1(a)(1) provides that a Manager must file a Form 13F report with the Commission within 45 days after the end of the calendar year and each of the first three calendar quarters of the subsequent calendar year."

The four reporting periods and their nominal 45th days are:

• Q4 (December 31): 45 days lands on February 14
• Q1 (March 31): 45 days lands on May 15
• Q2 (June 30): 45 days lands on August 14
• Q3 (September 30): 45 days lands on November 14

When the 45th calendar day falls on a weekend or federal holiday, the deadline rolls forward to the next business day. Two of the four 2026 dates trigger that roll-forward.

Key takeaway: The 45-day period is measured in calendar days, not business days. Counting business days will give you the wrong date every time.

2026 Form 13F Filing Deadlines: The Exact Dates

Here are the four confirmed deadlines for 2026, with the arithmetic shown:

The SEC's Division of Investment Management FAQ makes the February date explicit: "the deadline for the December 31, 2025 Form 13F report will be no later than February 14, 2026, a Saturday", meaning the actual filing deadline is Monday, February 17, 2026.

If your compliance calendar still shows February 14 or November 14, correct it now. These are not close calls; they are confirmed late filings.

For the full 2026 SEC filing calendar across all form types, see SEC Filing Deadlines 2026: Complete Calendar by Filer Type.

The EDGAR 5:30 p.m. ET Cutoff: The Trap Nobody Warns You About

EDGAR accepts filings from 6:00 a.m. to 10:00 p.m. ET on weekdays, but there is a critical distinction buried in the submission rules: any filing submitted after 5:30 p.m. ET receives the next business day's filing date.

This means a Form 13F submitted at 5:31 p.m. on August 14 is technically filed on August 17. That is a late filing.

Form 13F is not among the exceptions to this rule. Schedules 13D and 13G, Section 16 filings, and Rule 462(b) registration statements receive the actual filing date regardless of submission time. Form 13F does not get that treatment.

Key takeaway: Your operational deadline is 5:30 p.m. ET, not 10:00 p.m. Build your internal cutoff around 5:00 p.m. ET to absorb last-minute EDGAR errors, reviewer sign-offs, and submission issues.

One additional note for filers watching the August 14, 2026 deadline: the SEC announced on June 1, 2026 that the June 2026 EDGAR release was cancelled. Monitor the EDGAR submissions page for any system notices ahead of that date.

Who Must File: Does the $100M Threshold Apply to Total AUM?

No. The $100 million threshold applies specifically to Section 13(f) securities, not total assets under management. This distinction trips up more managers than the deadline arithmetic does.

Section 13(f) securities include exchange-traded equities, certain equity options and warrants, shares of closed-end investment companies, and certain convertible debt securities. Open-end mutual fund shares are not on the list.

A worked example: a manager with $300 million in total AUM but only $90 million in Section 13(f) securities has no Form 13F filing obligation. A manager with $150 million in total AUM but $110 million in exchange-traded equities does.

The threshold is measured by the aggregate fair market value of Section 13(f) securities on the last trading day of any month of any calendar year. Crossing $100 million in a single month triggers the filing obligation for the subsequent calendar year, even if the portfolio drops below that level in later months.

Three categories of filers that frequently assume they are exempt:

• Foreign managers: Required to 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. Many non-U.S. managers with U.S. equity exposure fall squarely in scope.
• Governmental entities: Municipal pension funds, sovereign wealth funds, and other government-related entities are institutional investment managers for 13F purposes. The SEC FAQ is explicit that "person" includes "a natural person, company, government, or political subdivision, agency, or instrumentality of a government."
• Banks: Insured depository institutions must file a copy of every Form 13F with the appropriate regulatory agency for the bank, in addition to filing with the SEC, as required by Section 13(f)(5) of the Exchange Act.

For a deeper look at what counts as investment discretion and how to map your holdings against the 13F List, see SEC 13F Reporting Requirements: 2026 Compliance Guide.

First-Time Filers: When Is Your Initial 13F Due?

First-time filers do not file for the quarter in which they crossed the $100 million threshold. The initial Form 13F is due within 45 days after the end of Q4 (December 31) of the calendar year in which the manager first crossed the threshold.

So if your portfolio crossed $100 million in Section 13(f) securities in, say, July 2026, your first filing is due by February 16, 2027 (45 days after December 31, 2026, adjusted for any weekend). You then file for each of the first three calendar quarters of 2027, regardless of whether your holdings stay above $100 million during that year.

This rule is buried in the SEC FAQ and is one of the most commonly missed obligations for new entrants to the threshold.

How to File Form 13F on EDGAR: The Operational Steps

Form 13F must be filed electronically on EDGAR. Paper filing is only permitted if the SEC has granted a hardship exemption. The text-based ASCII format was discontinued on May 20, 2013; all filings must now use either the online EDGAR form with XML Technical Specification or a filing constructed entirely according to the EDGAR XML Technical Specification.

Here is the practical sequence:

1. Confirm your threshold. Run your holdings against the current SEC 13F List, updated quarterly. Only securities on that list count toward the $100 million threshold and must be reported.
2. Pull your quarter-end positions. Aggregate fair market value of each Section 13(f) security as of the last day of the reporting quarter.
3. Apply the 2022 amendment rounding rules. Dollar values must be rounded to the nearest dollar, not the nearest $1,000. If your process still rounds to thousands, it is non-compliant under the amendments effective January 3, 2023 (SEC Release No. 34-95148).
4. Add identifiers correctly. CUSIP is required. FIGI (Financial Instrument Global Identifier) is now an optional additional identifier under the 2022 amendments. FIGI does not replace CUSIP.
5. Check for duplicative reporting. If another manager reports the same holdings on your behalf under the duplicative reporting exemption (Special Instruction 5 of the form), you must identify that manager in your filing. You still have an independent deadline obligation to file the notice; the exemption covers the holdings data, not the filing itself.
6. Prepare the XML submission. The filing has three components: a cover page, a summary page, and an information table in XML format. Validate the XML against the EDGAR Technical Specification before submission. Common errors include malformed XML and incorrect CUSIP numbers.
7. Submit before 5:30 p.m. ET on the deadline day. Log into EDGAR, submit, and retain the confirmation notice with the filing date stamp. If you are requesting confidential treatment for any holdings, that request must also be filed electronically on EDGAR under Rule 24b-2(i).
8. File a copy with your bank regulator if applicable. Banks with FDIC-insured deposits must send a copy of every 13F to the appropriate regulatory agency under Section 13(f)(5) of the Exchange Act.

Key takeaway: Build a pre-submission checklist that includes dollar rounding verification, CUSIP validation, and an EDGAR test submission at least two business days before the deadline. EDGAR system issues on deadline day are your problem, not the SEC's.

What Happens If You Miss the Form 13F Deadline?

There is no extension mechanism for Form 13F. Unlike Form 10-Q or Form 10-K, where a filer can buy additional time by submitting Form 12b-25, no equivalent exists for 13F. The SEC directs late filers to submit as soon as possible rather than holding back an incomplete filing.

The consequences of a late or missed filing include:

• SEC examination risk. The SEC's Division of Examinations has flagged 13F compliance as an exam priority. A late filing is a visible data point on EDGAR that can trigger a targeted review.
• Civil penalties. Under Section 13(f) of the Exchange Act, the SEC can seek civil money penalties for non-compliance. Persistent or egregious late filers have faced penalties exceeding $750,000.
• Reputational exposure. Form 13F filings are public. Investors, counterparties, and competitors can see both the holdings and the filing date. A pattern of late filings signals a compliance function under strain.

If you discover an error in a previously filed Form 13F, file an amendment on EDGAR immediately. Do not wait for the next quarterly cycle.

The June 2022 Amendments: What You Still Need to Update

The SEC adopted amendments to Form 13F on June 23, 2022 (SEC Release No. 34-95148), effective January 3, 2023. If your filing process has not been updated since then, here is what needs to change:

ChangeOld RequirementNew Requirement (Effective Jan 3, 2023)Dollar value roundingRound to nearest $1,000Round to nearest dollarSecurity identifiersCUSIP onlyCUSIP required; FIGI optional additionConfidential treatment checkboxNot requiredCheckbox added to Summary PageConfidential treatment requestsPaper or electronicElectronic on EDGAR only (from Feb 28, 2023)Manager identifiersNot requiredCRD number and SEC file number must be included if applicable

Filers who have not audited their process against these changes since early 2023 should do so before the next deadline.

Form SHO: The Parallel Obligation Running Alongside 13F

Starting in 2026, certain institutional investment managers face a second quarterly-adjacent obligation: Form SHO under Rule 13f-2.

Form SHO is not the same as Form 13F. It applies to managers with significant short positions, not all 13F filers. It must be filed within 14 calendar days after the end of each calendar month, making it a monthly obligation rather than a quarterly one.

The first Form SHO deadline was February 17, 2026, covering the January 2026 reporting period. That date coincided with the Q4 2025 Form 13F deadline, meaning large managers with short positions had two separate EDGAR submissions due on the same day.

Rule 13f-2 was originally set to take effect January 2, 2025. The SEC granted a temporary exemption in February 2025 because the technical compliance standards were only released on December 16, 2024. As SEC Acting Chairman Mark Uyeda stated at the time: "This exemption gives filers more time to implement the technical updates required for compliance according to standards that were released only on Dec. 16, 2024, immediately prior to the holidays." The exemption was not a repeal. The rule went live with the February 17, 2026 deadline.

Skadden has noted that "industry participants have highlighted certain ambiguities and compliance questions regarding the scope of Rule 13f-2." If your firm holds significant short positions, get legal counsel on whether you are in scope before the next monthly deadline.

For a full breakdown of the 2026 13F deadline calendar and the Form SHO interaction, see 13F Filing Deadlines 2026: Every Date, Rule, and Trap.

Form 13F Compliance Checklist: Before Every Deadline

Use this before each of the four 2026 deadlines:

• [ ] Confirm the adjusted deadline date (not just the nominal 45th day)
• [ ] Set internal submission cutoff at 5:00 p.m. ET on the deadline day
• [ ] Pull the current SEC 13F List for the reporting quarter
• [ ] Verify all dollar values are rounded to the nearest dollar (not nearest $1,000)
• [ ] Confirm CUSIP numbers against the current 13F List
• [ ] Add FIGI identifiers if your process supports them (optional but permitted)
• [ ] Check for any holdings subject to duplicative reporting; identify the reporting manager in Special Instruction 5
• [ ] File confidential treatment requests electronically on EDGAR if applicable
• [ ] If your firm is a bank, prepare a copy for the appropriate regulatory agency
• [ ] Check EDGAR system notices for any announced maintenance windows
• [ ] Assess whether short positions trigger a separate Form SHO obligation
• [ ] Retain the EDGAR confirmation notice with the filing date stamp

FAQ

Is the 45-day Form 13F deadline measured in calendar days or business days?Calendar days. The rule under 17 CFR 240.13f-1 counts 45 calendar days from the last day of the calendar quarter or calendar year. Counting business days will produce the wrong date.

What are the Form 13F filing deadlines for 2026?February 17 (Q4 2025), May 15 (Q1 2026), August 14 (Q2 2026), and November 16 (Q3 2026). February 17 and November 16 are roll-forwards from February 14 and November 14, both of which fall on Saturdays.

What time does EDGAR stop accepting Form 13F filings on the deadline day?EDGAR accepts filings until 10:00 p.m. ET, but any submission after 5:30 p.m. ET receives the next business day's filing date. For Form 13F, that means a filing submitted at 5:31 p.m. on the deadline is technically late. Treat 5:00 p.m. ET as your hard internal cutoff.

Can you get an extension on the Form 13F deadline?No. There is no Form 12b-25 equivalent for Form 13F. The SEC has no formal extension mechanism for this filing. If you miss the deadline, file as soon as possible.

Does the $100 million threshold apply to total AUM or only certain securities?Only Section 13(f) securities. A manager with $300 million in total AUM but $90 million in Section 13(f) securities is not required to file. The threshold is measured on the last trading day of any month of any calendar year.

When does a first-time filer have to submit their initial Form 13F?Within 45 days after the end of Q4 (December 31) of the year in which the manager first crossed the $100 million threshold, not the quarter in which the threshold was crossed.

Are foreign managers required to file Form 13F?Yes, 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. Many non-U.S. managers with U.S. equity exposure are in scope.