What Is a Form ADV Amendment Filing?

The annual amendment updates the firm’s entire Form ADV based on the prior fiscal year, and every registered adviser must file one regardless of whether anything changed. A material amendment, by contrast, is triggered by specific events — such as a change in ownership, a significant AUM shift, a new disciplinary disclosure, or a change to the firm’s advisory business — and generally must be filed promptly rather than waiting for the annual cycle.

Firms should have a process for recognizing when a mid-year change qualifies as “material” under the rule, since delaying a required amendment until the annual filing can itself be a compliance issue, separate from whatever the underlying change was.