When Are 13F Filings Due? 2026 Deadlines, Deadline Arithmetic, and EDGAR Traps

If you manage $100 million or more in Section 13(f) securities, you have four hard filing dates in 2026. Miss one, and you are not just late on a form, 13F compliance is an active SEC examination priority, which means a late filing can land you in an exam queue fast.

This walkthrough gives you the exact dates, the arithmetic behind them, the EDGAR mechanics that catch filers off guard at 5:31 p.m., and the related filings that share the same deadlines.

When Are 13F Filings Due in 2026?

Form 13F is due 45 calendar days after the end of each calendar quarter. When the 45th 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.

The SEC's own FAQ is explicit on the February date: "the deadline for the December 31, 2025 Form 13F report will be no later than February 14, 2026, a Saturday", meaning the actual deadline is Monday, February 17. If your compliance calendar still shows February 14 or November 14, fix it now.

These four dates are confirmed by Day Pitney's 2026 investment manager compliance calendar.

Key takeaway: The two adjusted dates for 2026 are February 17 and November 16. Every other date lands on a weekday and requires no roll-forward.

How the 45-Day Deadline Arithmetic Works

Count 45 calendar days from the last day of the quarter, weekends and holidays included, then check whether day 45 is a business day.

Here is the step-by-step process:

1. Identify the quarter-end date (March 31, June 30, September 30, or December 31).
2. Count forward 45 calendar days, including weekends and federal holidays.
3. Check whether day 45 falls on a Saturday, Sunday, or federal holiday.
4. If it does, the deadline moves to the next business day.
5. If it does not, day 45 is your deadline.

This rule comes directly from Rule 13f-1(a)(1) under the Securities Exchange Act of 1934. The SEC FAQ represents staff views, not a formal Commission rule, but it is the authoritative practical guidance on how the SEC applies the arithmetic.

For future years, you can run this calculation yourself. The only variable is whether day 45 lands on a non-business day. For 2027, run the same count from each quarter-end and check the federal holiday calendar.

The EDGAR 5:30 p.m. ET Cut-Off Trap

EDGAR accepts filings from 6 a.m. to 10 p.m. ET on weekdays, but any filing submitted after 5:30 p.m. ET receives the next business day's filing date. For Form 13F, that makes it technically late.

A concrete example: a 13F submitted at 6:00 p.m. on August 14 is stamped August 17 by EDGAR, and is late.

This is not a minor technicality. The exceptions to the 5:30 p.m. rule are Schedules 13D and 13G, Section 16 filings, and Rule 462(b) registration statements. Form 13F is not one of those exceptions.

The practical fix:

• Set your internal submission deadline at 5:00 p.m. ET on the deadline day, not 10:00 p.m.
• That 30-minute buffer absorbs last-minute EDGAR system issues, reviewer sign-offs, and the submission errors that only appear when you are rushing.
• Build a pre-submission checklist that clears compliance review by noon on deadline day.

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

What Triggers a 13F Filing Obligation?

An institutional investment manager must file Form 13F if it exercises investment discretion over $100 million or more in Section 13(f) securities. Three details determine whether you are in scope.

The $100 Million Threshold Is Not Total AUM

The threshold applies specifically to Section 13(f) securities, a defined list that includes:

• Exchange-traded equities (including Nasdaq-listed stocks)
• Certain equity options and warrants
• Shares of closed-end investment companies
• Certain convertible debt securities

Mutual fund shares are not Section 13(f) securities. A manager with $300 million in total AUM but only $90 million in Section 13(f) securities does not file.

The threshold is measured by aggregate fair market value on the last trading day of any month in any calendar year. Crossing it in a single month triggers the filing obligation for the subsequent calendar year.

When Does the Obligation Begin for a New Filer?

If you cross the $100 million threshold for the first time, your first filing covers the quarter in which you crossed, but it is not due until 45 days after December 31 of that year. In other words, if you first crossed the threshold in, say, July 2026, your first Form 13F would cover Q3 2026 (the quarter in which you crossed) and would be due November 16, 2026. You then file for every subsequent quarter throughout the following calendar year.

The SEC FAQ is clear that once you cross the threshold in any month, the obligation runs for the full subsequent year, even if your Section 13(f) securities drop below $100 million during that period.

Foreign Managers Are Not Exempt

Non-U.S. managers are subject to Form 13F if they (1) use any means or instrumentality of U.S. interstate commerce in the course of their business and (2) exercise investment discretion over $100 million or more in Section 13(f) securities, per Section 13(f)(1) of the Securities Exchange Act and SEC Release No. 34-14852. Many non-U.S. managers with U.S. equity exposure assume the obligation does not apply to them. It does.

Governmental Entities File Too

Municipal pension funds, sovereign wealth funds, and other government-related entities are institutional investment managers for 13F purposes. The SEC FAQ is explicit: "person" includes "a natural person, company, government, or political subdivision, agency, or instrumentality of a government."

How Often Do 13F Filings Come Out?

Form 13F is filed quarterly, four times per year, within 45 days of each calendar quarter-end. There is no annual-only option. Every qualifying manager files four times per calendar year, covering Q4 of the prior year through Q3 of the current year.

The SEC publishes Form 13F data sets quarterly, with data released following the February, May, August, and November filing deadlines. As of March 2024, the SEC's 13F data sets are run for the prior three months following the end of those months.

How Delayed Are 13F Filings?

By the time a 13F filing is public, the positions it reports are up to 45 days old, and potentially older. A filing submitted on the last day of the window (say, August 14 for Q2) shows positions as of June 30. That is a 45-day lag at minimum. If a manager files early, the data is still as of June 30, the quarter-end date is fixed.

This lag matters for anyone using 13F data for investment research: the institution has had 45 days to add to, reduce, or exit positions entirely before the filing is visible. Treat 13F data as a historical snapshot, not a current position statement.

February 17, 2026: A Dual Deadline (Form 13F and Form SHO)

February 17, 2026 carried more weight than most filers realized. It was not just the Form 13F Q4 2025 deadline. It was also the first-ever filing deadline for Form SHO under Rule 13f-2, covering the January 2026 reporting period.

Here is the background. Rule 13f-2 was originally set to take effect January 2, 2025, with initial Form SHO filings due February 14, 2025. The SEC granted a temporary exemption in February 2025 because the technical compliance standards were released only on December 16, 2024, immediately before the holidays, leaving insufficient time for implementation. 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. Regardless of this exemption, abusive naked short selling as part of a manipulative scheme remains unlawful."

The exemption was not a repeal. Form SHO is live as of 2026, with filings due within 14 calendar days after the end of each calendar month under Rule 13f-2.

Form SHO is distinct from Form 13F. It applies to institutional investment managers that meet or exceed certain short-position thresholds, not all 13F filers are also Form SHO filers. But if you are a large manager with significant short positions, you faced two separate EDGAR submissions on February 17. Skadden has noted that "industry participants have highlighted certain ambiguities and compliance questions regarding the scope of Rule 13f-2", if you have short positions that might trigger Form SHO, get legal counsel on whether you are in scope.

Which Other Filings Are Due on the Same Dates as Form 13F?

Form 13F does not exist in isolation. The same four dates in 2026 also carry obligations under related forms. A compliance calendar that tracks only Form 13F is incomplete.

Schedule 13G now requires quarterly assessment under amendments effective September 30, 2024, qualified institutional investors must assess whether a filing or amendment is required at each quarter-end, not just year-end. Schedule 13G must also now be filed in structured, machine-readable data language. For a detailed walkthrough of Schedule 13G eligibility, see Schedule 13G passive investor eligibility: 2026 practitioner walkthrough.

Form 13H annual updates are due within 45 days after calendar year-end, the same 45-day rule as Form 13F, meaning the Form 13H annual update for calendar year 2025 was also due February 17, 2026.

What Changed with the 2022 Form 13F Amendments?

On June 23, 2022, the SEC adopted rule and form amendments to Form 13F under SEC Release No. 34-95148, effective January 3, 2023. If your team has not updated its filing process since then, you are filing on an outdated format.

Key changes:

• Rounding: Dollar values must now be rounded to the nearest dollar, not the nearest $1,000. This is the most common process gap for teams that built their Information Table templates before 2023.
• Additional identifiers: Managers must now report their Central Registration Depository (CRD) number and SEC file number, if any.
• FIGI option: Managers may now report a Financial Instrument Global Identifier (FIGI) for a security in addition to (not instead of) its CUSIP number.
• Confidential treatment checkbox: A checkbox was added to the Summary Page to indicate when confidential treatment is being requested.
• Electronic confidential treatment requests: All Form 13F confidential treatment requests must be filed electronically on EDGAR as of February 28, 2023. Paper filings are no longer accepted.

The text-based ASCII format for 13F filings was discontinued on May 20, 2013. Filers must now either use the online form on the EDGAR Filing Website or construct the entire Form 13F filing per the EDGAR XML Technical Specification.

For a full operational walkthrough of the filing process itself, see how to file Form 13F and Form 13F filing deadline: 5 operational traps beyond the 45-day rule.

Building Your Internal Compliance Calendar

The statutory deadline is the outer limit, not your target. Here is a practical internal timeline to build around each 13F deadline:

1. Quarter-end (day 0): Lock the position data as of the last trading day of the quarter.
2. Days 1-10: Run your Section 13(f) securities list against the SEC's official quarterly list. Confirm which positions are reportable.
3. Days 11-25: Construct the Information Table in XML format. Apply the nearest-dollar rounding convention. Verify CUSIP numbers and any FIGI entries.
4. Days 26-35: Internal compliance review. Check for any confidential treatment requests that need to be filed electronically on EDGAR alongside the public filing.
5. Days 36-40: Final sign-off. Load the filing into EDGAR and run the validation check.
6. Day 40 at latest (5:00 p.m. ET): Submit. Do not wait for day 45.

If you are also a Form SHO filer, your monthly obligation runs on a separate 14-day clock after each month-end. Map both calendars side by side, February is the month where both obligations converge.

FAQ

What is the Form 13F filing deadline for Q3 2026? November 16, 2026. The 45th day after September 30 is November 14, a Saturday, so the deadline rolls to the following Monday.

Does the $100 million threshold apply to total AUM or only certain securities? Only Section 13(f) securities count toward the threshold. These 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.

What time does EDGAR stop accepting 13F filings on the deadline day? EDGAR accepts filings until 10:00 p.m. ET, but any filing submitted after 5:30 p.m. ET receives the next business day's filing date. For Form 13F, that makes it late. Set your internal cut-off at 5:00 p.m. ET.

Are 13F filings public? Yes. Form 13F filings are publicly available on EDGAR immediately upon acceptance. Managers may request confidential treatment for specific holdings, but the request itself must now be filed electronically on EDGAR, and the SEC applies a harm-based standard before granting it.

What is Form SHO and does it affect my 13F deadline? Form SHO is a separate monthly short-position disclosure form under Rule 13f-2. It is not the same as Form 13F and does not change your 13F deadline. However, for managers with significant short positions, the first Form SHO deadline (February 17, 2026) coincided with the Q4 2025 Form 13F deadline, creating a dual filing obligation on the same day.

What happens if I drop below the $100 million threshold during the year? If you crossed the threshold at any point during the prior calendar year, you must file for all four quarters of the current year, even if your Section 13(f) holdings fall below $100 million during that period. The obligation does not lapse mid-year.

Which companies are included in the 13F securities list? The SEC publishes an official list of Section 13(f) securities quarterly. It includes exchange-listed equities, certain options and warrants, closed-end fund shares, and certain convertible debt. The list is available on the SEC's website and is updated each quarter. Mutual funds are excluded.