Form PF requirements 2026: what the April SEC/CFTC proposal means for your compliance programme

On April 20, 2026, the SEC and CFTC jointly proposed sweeping amendments to Form PF,  the confidential systemic risk reporting form that has been a fixture of private fund adviser compliance since 2012. If adopted, the proposal would represent a significant rollback of Form PF requirements since the form was introduced, potentially eliminating the filing obligation entirely for a large portion of advisers currently required to file.

For CCOs at hedge funds and private fund advisers, this is a development that demands careful attention. Not because the rules have changed, but because they have not yet changed, and the path from proposal to final rule is neither guaranteed nor quick.

What is being proposed

The April 20 proposal, published in the Federal Register on April 24, 2026, contains four headline changes:

1. A significant increase to the filing threshold

The baseline Form PF filing threshold would rise from $150 million to $1 billion in private fund assets under management. The SEC estimates this would eliminate the filing requirement for approximately 30% of advisers currently required to file, almost half of whom are smaller advisers that the Commissions acknowledge contribute minimally to systemic risk data. Importantly, advisers falling below the new threshold would not be exempt from all reporting obligations: they would still be required to disclose certain fund information on the publicly available Form ADV.

2. A substantial increase to the large hedge fund adviser threshold

The reporting threshold for classification as a “large hedge fund adviser” – which triggers quarterly filing, Section 2 reporting, and current event reporting obligations –  would rise from $1.5 billion to $10 billion in hedge fund assets under management. This is a meaningful change: many mid-sized hedge fund advisers currently subject to the more granular quarterly reporting regime would transition to annual filing if the proposal is adopted as written.

3. Elimination of quarterly event reporting for private equity fund advisers

Section 6 of the current form, which requires private equity fund advisers to submit quarterly reports following adviser-led secondary transactions, general partner removals, terminations of investment periods, and fund terminations, would be eliminated entirely. This has been one of the most operationally demanding elements of the 2024 amendments for PE-focused advisers.

4. Streamlining and simplification across the form

Beyond the threshold changes, the proposal would remove or narrow a range of specific reporting requirements, including performance volatility reporting, certain look-through requirements, certain counterparty exposure reporting for large hedge fund advisers, and some current event reporting triggers. The overall effect, if adopted, would be a considerably lighter and more targeted Form PF framework.

The critical context: nothing has changed yet

This point warrants emphasis, because it is easy to read a proposal of this scope and assume relief is imminent. It is not.

The proposal was issued on April 20, 2026. The public comment period closes on June 23, 2026. After that, the Commissions must review comments, publish a final rule, and allow a minimum 12-month transition period from Federal Register publication before compliance is required.

In the meantime, the 2024 amendments (including the October 1, 2026 compliance date) technically remain on the books. The Commissions have signalled that the proposal is intended to largely unwind those amendments before advisers are required to comply with them, but until a final rule is issued, the current framework governs. Advisers that have already invested in preparing for the 2024 amendments should reassess their implementation timelines, but should not assume that preparation work is wasted: the core Form PF filing obligation, in some form, is not going away.

Who is most affected

Smaller advisers (below $1 billion in private fund AUM): if the proposal is adopted as written, these advisers would exit the Form PF filing regime entirely. The relief would be significant, but the timeline is uncertain. Advisers in this category should continue current compliance preparations while monitoring the rulemaking process closely.

Mid-sized hedge fund advisers (between $1.5 billion and $10 billion in hedge fund AUM): these advisers stand to benefit most from the large hedge fund adviser threshold change, moving from quarterly to annual reporting. This would materially reduce operational burden for a significant cohort of hedge fund compliance teams.

Private equity fund advisers: the elimination of Section 6 quarterly event reporting would remove one of the most resource-intensive elements of the 2024 amendments for this segment. PE-focused CCOs should note, however, that this relief is contingent on the proposal being adopted. And the SEC has specifically invited comment on whether some event types, such as general partner removals, should be retained in some form.

Large hedge fund advisers (above $10 billion): these advisers remain firmly within scope. While they benefit from certain streamlining proposals (including the removal of the “as soon as practicable” language from current event reporting in favour of a clear 72-hour window),  the core quarterly and current reporting obligations remain. For these firms, the compliance programme does not change materially.

Private credit advisers: the proposal reflects an increased focus on the systemic risk implications of private credit strategies. Advisers in this space should review the proposal carefully and consider whether to submit comments.

What the comment period means and why it matters

The 60-day comment period, closing June 23, 2026, is not a formality. The SEC has explicitly invited comment on a number of open questions within the proposal, including whether certain eliminated reporting obligations should be retained in some form, whether the 72-hour current event reporting deadline is appropriately calibrated, and how the new thresholds interact with specific fund structures.

For CCOs and compliance teams, the comment period represents a meaningful opportunity to shape the final rule. Firms that have encountered specific operational difficulties with the 2024 amendments, around the event reporting triggers, the look-through requirements or the current reporting timelines, have a direct channel to communicate those experiences to the Commissions. Law firm guidance and industry association submissions (AIMA, MFA) will be worth reviewing as the comment period progresses.

What your compliance programme should do now

1. Do not stand down on current compliance preparations

The October 1, 2026 compliance date for the 2024 amendments remains in effect unless and until superseded by a final rule. Dismantling preparation work on the assumption that the proposal will be adopted as written or at all is a risk that is not justified by the current regulatory posture. Maintain your programme; adjust your priorities.

2. Map your firm against the proposed thresholds

Understand now where your firm falls relative to the proposed $1 billion and $10 billion thresholds. If you are in the band that would be materially affected by either change, model both scenarios: one in which the proposal is adopted substantially as written, and one in which the current framework persists.

3. Review the streamlining proposals for current reporting

Even if your firm remains a large hedge fund adviser under the new thresholds, the proposed changes to current event reporting, particularly the clarification of the 72-hour window and the narrowing of reportable events, may resolve interpretive issues your team has already encountered. Understanding these changes now allows you to prepare for them without waiting for a final rule.

4. Consider whether to submit a comment

If your firm has encountered specific compliance challenges with existing Form PF requirements, the comment period is the appropriate forum to raise them. This is particularly relevant for PE-focused advisers with concerns about Section 6, and for advisers with complex fund structures navigating the look-through and feeder fund provisions.

5. Monitor the rulemaking timeline actively

The minimum 12-month transition period means that even if a final rule is published in late 2026, compliance would not be required until late 2027 at the earliest. However, the final rule could also arrive later, or differ materially from the proposal. Building a clear monitoring protocol, with defined trigger points for updating your compliance programme, is more useful than assuming a particular outcome.

The bigger picture

The April 2026 proposal reflects a genuine shift in the SEC and CFTC’s approach to private fund reporting: from expansion and granularity, toward calibration and proportionality. SEC Chairman Paul Atkins has been explicit that restoring balance to disclosure obligations is a key agenda item, and the Form PF proposal is consistent with a broader deregulatory direction across multiple areas of investment adviser regulation.

For CCOs, this directional shift is worth understanding as a strategic context, not as grounds for reducing compliance vigilance. The form may become lighter. The obligation to file, for firms above the final threshold, is not going away. And the reputational and regulatory risk of a compliance gap in the transition period is as real as ever.