Last year, the SEC and CFTC pushed the compliance date for the amended Form PF to October 1, 2026. That’s the headline. But the more impactful changes will be in how Form PF is filed, validated, and consumed going forward.
This isn’t just a new deadline. It’s a structural shift toward more data-driven reporting.
The Updated Compliance Timeline
The amended version of Form PF will go live in FINRA Gateway on October 1, 2026.
Until then:
- All Form PF filings due before October 1, 2026 must continue to be filed through Classic IARD/PFRD
- The amended Form PF in FINRA Gateway becomes mandatory only for filings after this date
- There is no phased transition once the new version is live
This gives firms time to prepare, but the cutoff is firm.
FINRA’s XML Rollout Has Already Started
Even with the delayed compliance date, FINRA has moved ahead with the amended Form PF Sections 1–4 XML schema, which were updated as of January 5, 2026 for firms that submit Form PF via XML.
This is an important signal. The SEC is clearly moving Form PF toward structured, machine-readable data, meaning there will be less room for manual interpretation or late adjustments.
Key Milestones Leading to the October Deadline
FINRA has published a clear roadmap for the amended Form PF release:
- December 1: Existing XML testing access disabled due to development work
- January 5: Amended XML schema and documentation published
- January 20: QA testing environment reopened
- January 30: Deadline for submitting feedback on the amended schema
- February–September: QA environment remains open for testing
- March 2: Final XML schema locked, no further changes permitted
- October 1: Production deployment, all Form PF uploads must use the new schema
Technical questions go to FINRA. Policy and interpretation stay with the SEC.
The Latest Changes Introduced on January 5
Two additional nfaId fields have been updated to use the standardized nfaFirmIDType. This change helps ensure greater alignment across related data elements and improves consistency when working with NFA firm identifiers.
At the same time, the data types for several attributes have been revised. These updates are designed to better reflect real-world data usage and reduce validation issues.
Reporting Changes Are Still Coming
Keep in mind, the October deadline extension doesn’t soften the substance of the amendments.
Buy-side firms should still be planning for:
- More granular reporting across leverage, liquidity, exposures, and fund structures
- Event-driven reporting, including rapid disclosures for certain hedge fund stress events and expanded quarterly reporting for private equity advisers
- Greater data consistency, driven by XML validation and structured submissions
In other words, Form PF is moving away from a static filing and toward an operational reporting framework.
What This Really Means for Buy-Side Firms
The delay offers breathing room, but not relief.
Firms should be using the coming months to test against the amended XML schema, identify data gaps, and align risk, operations, and compliance workflows. Once the schema is locked in March, flexibility drops sharply.
Ultimately, Form PF is becoming more precise, more technical, and less forgiving. Firms that treat this as a serious data and systems exercise will be ready when October 2026 arrives.
Need help getting started?
Contact Indus Valley Partners to see how the IVP Regulatory Reporting Solution can help you meet these deadlines on time and on point.
