General information, not legal or compliance advice. Check with your CCO or counsel.

AI regulation timeline for financial advisors

Applies to RIABroker-dealerLast reviewed October 23, 2026

Short answer

There's no single AI law for advisors. The rules come from a string of separate actions: the SEC's fiduciary interpretation and Marketing Rule, FINRA's 2024 generative AI notice, the 2024 Regulation S-P amendments, the first AI washing cases, the 2025 withdrawal of the SEC's predictive analytics proposal, and the latest exam priorities and FINRA oversight report. This timeline lists each one with a link to the regulator's own page.

On this page

The timeline

June 5, 2019 · SEC
The SEC publishes its interpretation of the standard of conduct for investment advisers (Release IA-5248): a duty of care and a duty of loyalty.
Why it matters: It's the framework for deciding whether AI use is a material fact or conflict clients need to hear about. Source
May 4, 2021 · SEC
The modernized Marketing Rule, Rule 206(4)-1, takes effect (Release IA-5653). Advisers had to comply by November 4, 2022.
Why it matters: It's the rule behind the AI washing cases: no untrue statements of material fact and no claims you can't substantiate. Source
August 13, 2021 · FINRA
Regulatory Notice 21-29 reminds member firms that outsourcing to a third-party vendor doesn't relieve them of supervisory obligations.
Why it matters: It applies directly to AI vendors used by broker-dealers. Source
January 2023 · NIST
NIST releases the AI Risk Management Framework (AI RMF 1.0), a voluntary framework.
Why it matters: FINRA lists it as a resource, and many firms borrow its structure for AI governance. Source
July 26, 2023 · SEC
The SEC proposes rules on conflicts of interest from predictive data analytics used by broker-dealers and advisers (Release 34-97990).
Why it matters: It would have been the first SEC rule aimed at AI-type tools. It was later withdrawn. Source
February 8, 2024 · FCC
The FCC adopts a declaratory ruling that calls using AI-generated voices are "artificial" under the Telephone Consumer Protection Act.
Why it matters: AI voice outreach to clients or prospects falls under robocall rules. Source
March 18, 2024 · SEC
The SEC settles charges against Delphia (USA) and Global Predictions for false and misleading statements about their use of AI. $400,000 in total civil penalties.
Why it matters: The first AI washing cases against advisers. Every AI marketing claim needs support. Source
May 10, 2024 · FINRA
FINRA's advertising regulation FAQs include questions on supervising chatbot communications (B.4) and AI-created communications (D.8), the date FINRA cites for them.
Why it matters: Rule 2210's content standards apply to AI-written communications. Source
May 16, 2024 · SEC
The SEC adopts amendments to Regulation S-P: incident response programs, service-provider oversight with 72-hour vendor notice, and 30-day customer notice.
Why it matters: Most AI tools that touch client data are service providers under the amended rule. Source
June 27, 2024 · FINRA
Regulatory Notice 24-09 says FINRA's technology-neutral rules apply to generative AI, including AI embedded in third-party products.
Why it matters: FINRA's main statement on generative AI for member firms. Source
July 2024 · NIST
NIST publishes the Generative AI Profile of the AI RMF (NIST AI 600-1).
Why it matters: A voluntary checklist of generative AI risks that maps well to a firm AI policy. Source
August 2, 2024 · SEC
The Regulation S-P amendments become effective.
Why it matters: Starts the clock for the tiered compliance dates. Source
August 14, 2024 · SEC
Twenty-six firms agree to pay more than $390 million combined to settle recordkeeping charges over off-channel communications.
Why it matters: The recordkeeping lesson for AI chats and notetakers: capture what the rules say you must keep. Source
September 24, 2024 · SEC
Eleven firms agree to pay more than $88 million combined to settle recordkeeping charges.
Why it matters: Shows the off-channel sweep continuing into late 2024. Source
September 25, 2024 · FTC
The FTC announces Operation AI Comply, five actions against deceptive AI claims and schemes.
Why it matters: Outside securities law, the same message: there's no AI exemption from existing law. Source
November 6, 2024 · SEC
The acting enforcement director says fiscal 2024 recordkeeping cases brought over $600 million in penalties against more than 70 firms.
Why it matters: Context for why record capture matters for any new communication tool. Source
June 12, 2025 · SEC
The SEC withdraws the predictive data analytics proposal, with other proposals, effective June 17, 2025.
Why it matters: No AI-specific SEC conflicts rule is pending. Existing rules apply. Source
November 17, 2025 · SEC
The Division of Examinations publishes its fiscal 2026 priorities, including reviewing AI claims for accuracy and AI supervision policies.
Why it matters: Tells you what examiners plan to ask about AI this year. Source
December 3, 2025 · SEC
Compliance date for larger entities under the Regulation S-P amendments.
Why it matters: Larger firms' AI vendor oversight had to meet the new rule from this date. Source
December 9, 2025 · FINRA
FINRA publishes its 2026 Annual Regulatory Oversight Report with a new GenAI section, including AI agents and prompt and output logs.
Why it matters: FINRA's most detailed view of how firms use generative AI and what to consider. Source
June 3, 2026 · SEC
Compliance date for smaller entities under the Regulation S-P amendments.
Why it matters: From this date the amended rule applies to every covered firm. Source

How to read this timeline

Each entry has the date, the regulator, what happened and why it matters for an advisory or brokerage firm using AI. Every link goes to the regulator's own page or document. We include actions that aren't about AI as such (the off-channel recordkeeping cases, for example) when they set the rules AI tools have to fit into.

Dates are the date the regulator published or the date the action took effect, as labeled. Where a regulator gives only a month, so do we.

What the timeline shows

Regulators are applying existing rules, not writing new AI ones. FINRA's Notice 24-09 says its rules are technology neutral. The SEC withdrew the one AI-adjacent proposal it had. What's left is fiduciary duty, the Marketing Rule, books and records, supervision and Regulation S-P, all applied to AI.

Enforcement has focused on claims and records. The 2024 AI washing cases were about what firms said, and the off-channel cases were about what they failed to keep. Both are things a firm controls today.

Client data is where the hard deadlines are. The Regulation S-P compliance dates of December 3, 2025 and June 3, 2026 are the only firm deadlines on this list, and they reach most AI tools that touch client information.

What to watch next

Three documents are published on a regular schedule and are worth checking when they come out: the SEC Division of Examinations' annual priorities (the fiscal 2026 edition came out November 17, 2025), FINRA's Annual Regulatory Oversight Report (the 2026 edition came out December 9, 2025), and any SEC staff FAQs on Regulation S-P. We update this timeline when one of them changes the picture.

We don't list state AI laws here yet. Several states have passed or proposed AI laws, but how they apply to SEC-registered advisers varies, and we only add an entry when we can source it to the state's own site and explain how it applies to advisors.

What to do next

Put the next SEC exam priorities and FINRA oversight report on your compliance calendar.
Check your AI policy against each entry here that applies to your firm type.
Confirm your firm met the Regulation S-P compliance date for its tier.
Review public AI claims against the 2024 AI washing cases.

Questions to ask your CCO

Which of these actions have we mapped into our compliance manual?
Who watches for new SEC, FINRA and state AI guidance, and how do we hear about it?
Have we reviewed our AI tools against the fiscal 2026 exam priorities?

FAQ

Is there a federal AI law for financial advisors?

No. The rules that apply to advisors' AI use come from existing securities rules and guidance: fiduciary duty, the Marketing Rule, books and records, Regulation S-P and, for broker-dealers, FINRA's rules as described in Notice 24-09.

What was the SEC's predictive data analytics rule?

A July 26, 2023 proposal on conflicts of interest from predictive data analytics used by broker-dealers and advisers. The SEC withdrew it on June 12, 2025, effective June 17, 2025.

When did FINRA issue guidance on generative AI?

Regulatory Notice 24-09 on June 27, 2024, followed by a new GenAI section in the 2026 Annual Regulatory Oversight Report published December 9, 2025.

What are the Regulation S-P compliance dates?

December 3, 2025 for larger entities and June 3, 2026 for smaller entities. The amendments became effective August 2, 2024.

Sources

Primary sources first. Each was opened on October 23, 2026.