If you’re an investment adviser representative (IAR), you may owe IAR CE requirements. These are straightforward once you know the rules, but failing to remain compliant can result in major consequences for your career. Find out if you owe IAR CE requirements, how to fulfill them, and what happens if you don’t.
Summary
IARs in a jurisdiction that has adopted the NASAA IAR CE Model Rule must complete 12 continuing education credits every calendar year, made up of 6 credits of Ethics and Professional Responsibility and 6 credits of Products and Practice. The credits must show up on your FINRA Central Registration Depository (CRD) record by the end of the year.
What Is the IAR CE Model Rule?
Officially taking effect with its early adopters on January 1, 2022, the NASAA IAR CE Model Rule requires that IARs registered in implementing states complete annual IAR CE requirements. This rule, developed by the North American Securities Administrators Association (NASAA), was built to ensure that securities professionals remain up to date on best practices and industry developments to better serve their clients.
Since IAR professionals register through state regulators, the NASAA IAR CE Model Rule serves as a guideline that states can choose to adopt as mandatory or not. As of September 2026, 25 jurisdictions have implemented the IAR CE requirement. 24 are already in effect, and Indiana joins on January 1, 2027.
What Are the IAR CE Requirements?
Under NASAA’s Model Rule, every IAR registered in an adopting jurisdiction must earn 12 approved CE credits each calendar year. NASAA defines one credit as at least 50 minutes of educational instruction.
The 12 credits must be split exactly this way:
- 6 credits of Ethics and Professional Responsibility: courses on your duties to clients, including fiduciary duty. At least half of every course in this category must cover ethical responsibility.
- 6 credits of Products and Practice: courses on investment products, strategies, standards, and compliance practices in the advisory business.
The split is not flexible. NASAA is explicit that an IAR who completes 8 Products and Practice credits and 4 Ethics credits has not met the requirement, even with 12 total credits.
Other core rules to know:
- Approved courses only: Credits count only if both the course and the provider are approved by NASAA.
- You choose the topics: You can pick any approved courses that fit your practice and the topic allocations, unless your firm gives you different internal guidance.
- Self-study counts: There’s no cap on on-demand or self-study credits, as long as the courses are approved.
- Every on-demand course has an assessment: You need a score of at least 70% within three attempts to earn the credit.
- Noncompliance can end your registration: Missing the requirement doesn’t end your registration right away, but missing it two years in a row does.
Who Has to Complete IAR CE?
Every IAR registered in an adopting jurisdiction is subject to the requirement. That includes IARs of both state-registered advisers and federal-covered (SEC-registered) advisers.
Note that the trigger is where you are registered as an IAR, not where you live or where your firm is registered or notice filed. If you live in a state that hasn’t adopted the rule, but you’re registered as an IAR in one that has, you must comply.
That said, you only need to complete 12 credits once per year, no matter how many IAR CE jurisdictions you’re registered in. If you add a new IAR CE state mid-year, the credits you complete that year count for both.
There are no exemptions based on age, years of experience, or professional designations. Waivers exist but are granted only in extraordinary circumstances and only apply in the state that grants them.
When Do IAR CE Requirements Start for New IARs?
If you register as an IAR in an IAR CE jurisdiction for the first time, your requirement begins on January 1 of the following year. For example, an IAR first registered in an IAR CE state in March 2026 would owe their first 12 credits for the 2027 calendar year.
Likewise, when a jurisdiction adopts the rule, the requirement begins on January 1 of the calendar year after adoption.
IAR CE for Dually Registered Reps
If you’re also registered as a broker-dealer agent with a FINRA member firm, your FINRA Regulatory Element CE can satisfy the full 6-credit Products and Practice component. You would then need only the 6 Ethics and Professional Responsibility credits from a NASAA-approved provider.
Two details matter here:
- The Regulatory Element doesn’t apply automatically: Your broker-dealer can report it on your behalf, or you can self-report it in FinPro and pay the $18 reporting fee ($3 per credit times 6 credits). Check with your firm before you pay. NASAA notes these fees are not refundable.
- FINRA MQP CE also counts toward Products and Practice: It uses the same FinPro self-reporting process and $18 fee.
Firm Element training counts toward IAR CE only if the course is approved by NASAA. Some firms use NASAA-approved Firm Element courses so that one training program works for both.
Which States Require IAR CE?
The table below reflects the jurisdictions listed on NASAA’s IAR CE map, which NASAA last updated in March 2026.
| Jurisdiction | IAR CE Effective |
|---|---|
| Arkansas | 2023 |
| California | 2024 |
| Colorado | 2024 |
| Florida | 2024 |
| Hawaii | 2024 |
| Illinois | 2026 |
| Indiana | 2027 |
| Kentucky | 2023 |
| Maryland | 2022 |
| Michigan | 2023 |
| Minnesota | 2025 |
| Mississippi | 2022 |
| Nebraska | 2025 |
| Nevada | 2024 |
| New Jersey | 2025 |
| North Dakota | 2024 |
| Oklahoma | 2023 |
| Oregon | 2023 |
| Rhode Island | 2025 |
| South Carolina | 2023 |
| Tennessee | 2024 |
| U.S. Virgin Islands | 2025 |
| Vermont | 2022 |
| Washington, D.C. | 2023 |
| Wisconsin | 2023 |
Effective dates reflect NASAA’s IAR CE map as of time of writing; confirm the current list on NASAA.org.
IAR CE Requirements Stick with You
It’s important to know that once you have an IAR CE requirement, NASAA treats it as permanent. It continues even if you withdraw from the state that triggered it, and an unmet shortfall keeps building up to a maximum of 36 credits. That shortfall won’t affect registrations in states without IAR CE. But if one of those states adopts the rule later, your registration there will be affected on the effective date. The simplest protection is to stay current every year.
When Is the IAR CE Deadline?
IAR CE is due by the end of each calendar year, but the practical deadline is earlier. Your credits count only once they appear on your IAR CE transcript in the CRD system. That requires three things to happen: you finish the course, your provider reports it, and FINRA processes the roster.
FINRA shuts down the CRD system for year-end processing during the last week of December, and completions that aren’t processed before the shutdown are not applied to that year. Some providers may set their own cutoffs even earlier, so aim to finish your IAR CE by early December, not December 31, so you don’t miss the deadline.
What Happens If You Miss the IAR CE Deadline?
Missing one year puts you on notice. Missing two years in a row costs you your registration.
1. First Missed Year: CE Inactive
If you haven’t completed your 12 credits by the annual deadline, you still pay your registration renewal fee, and CRD sets your IAR CE status to “CE Inactive.” That status applies in every IAR CE jurisdiction where you’re registered, and your registration status can display as “Approved – Pending IAR CE.” A CE Inactive status can also be visible on public tools like BrokerCheck and the SEC’s Investment Adviser Public Disclosure (IAPD) site.
You can keep doing business while CE Inactive, but you now owe the missed 12 credits plus the current year’s 12.
2. Catching Up
Credits you complete are applied first to your oldest shortfall, then to the current year. Once you’ve earned enough to clear the deficiency, your status updates to “Satisfied” automatically.
3. Second Consecutive Missed Year: Fail to Renew
If you’re still CE Inactive at the end of the following year and haven’t completed your credits before the CRD System Shutdown Date, you are not eligible to register or renew as an IAR. Your registration fails to renew in all IAR CE jurisdictions. You’ll need to make up your deficient credits before your firm can resubmit your Form U4.
Can You Carry Over or Repeat IAR CE Credits?
You cannot carry over or repeat IAR CE credits. This means that any extra credits you earn during a calendar year don’t roll over into the following year. Likewise, taking the same course twice (at any point in your career, even in a later year) will not qualify for IAR CE. Each course needs a unique ID to count.
However, a few related rules work in your favor. If you change firms mid-year, the credits you already earned stay on your CRD transcript and still count. And CE courses taken for professional designations, like the CFP®, can also count toward your IAR CE requirements if the course and provider are also approved by NASAA.
Stay Ahead of Your IAR CE Deadline
IAR CE requirements come down to a simple annual routine: know where you’re registered, take 6 Ethics credits and 6 Products and Practice credits from NASAA-approved courses, and finish early enough for your credits to post before the CRD shutdown. Staying current each year keeps a missed deadline from turning into a lapsed registration.
STC is a NASAA-approved IAR CE provider with more than 60 courses in both the Products and Practice and the Ethics and Professional Responsibility categories. Each course is worth 1.0 credit, so it’s easy to see exactly where you stand against your 6 and 6.
STC’s IAR CE options include:
- 6-hour and 12-hour bundles: Buy the full 12 credits at once or just the 6 you still need, updated annually and featuring unique course IDs for the current year’s requirements.
- Automatic reporting to FINRA: STC reports your completions for you, so you don’t have to self-report courses.
- Built-in assessments and certificates: Each bundle includes the required course assessments and a Certificate of Completion.
- 24/7 tech support: Help is available whenever you’re working through your courses.
- Individual courses: Fill a specific gap without buying a full bundle.
STC’s NASAA-approved courses and automatic FINRA reporting make it easy to stay compliant and finish your IAR CE requirements well before your December deadline.
Explore STC’s IAR CE Packages and Courses
Frequently Asked Questions
What are the IAR CE requirements?
IAR CE requirements call for every investment adviser representative registered in an adopting jurisdiction to complete 12 NASAA-approved CE credits each calendar year. The credits must include exactly 6 in Ethics and Professional Responsibility and 6 in Products and Practice.
How many states require IAR CE?
As of September 2026, 25 jurisdictions have an IAR CE requirement on NASAA’s list: 23 states, Washington, D.C., and the U.S. Virgin Islands. Twenty-four are in effect now, and Indiana’s requirement takes effect January 1, 2027.
When is the IAR CE deadline?
IAR CE credits must appear on your CRD transcript by the end of each calendar year. Because FINRA shuts down the CRD system for year-end processing in late December, IARs should finish all courses by early December to make sure their credits post in time.
Does IAR CE apply if my home state hasn’t adopted the rule?
Regardless of your state of residence, you must complete IAR CE if you’re registered as an IAR in any jurisdiction that has adopted it. IAR CE is based on registration, not where you live or where your firm is registered.
Do new IARs have to complete IAR CE in their first year?
No. An IAR who registers in an IAR CE jurisdiction for the first time doesn’t owe IAR CE until January 1 of the following calendar year.
Can dually registered reps use FINRA CE for IAR CE?
Yes. A dually registered IAR can apply FINRA Regulatory Element CE toward the 6-credit Products and Practice component, then complete 6 Ethics and Professional Responsibility credits. The firm or the IAR must pay the $18 reporting fee for the Regulatory Element credits.
Does FINRA Firm Element training count toward IAR CE?
Firm Element training counts toward IAR CE only if the course has been approved by NASAA for IAR CE.
Can extra IAR CE credits carry over to the next year?
No. IAR CE credits beyond the 12 required in a year do not carry forward to the following year.
Can I retake the same IAR CE course for credit?
No. Duplicate courses don’t count toward the IAR CE requirement, even if you take them in a later year. Each course must have a unique course ID to earn credit.
What happens if I miss my IAR CE requirement?
If you miss the IAR CE deadline, your IAR CE status becomes “CE Inactive” in all IAR CE jurisdictions where you’re registered, and you must make up the missed credits plus the current year’s. If you’re still deficient by the CRD System Shutdown Date the following year, your IAR registration fails to renew.
How much does IAR CE reporting cost?
NASAA charges a reporting fee of $3 per credit per person. Some providers include this fee in their course price, and dual registrants who self-report Regulatory Element credits pay $18 through FinPro.
How do I check my IAR CE status?
You can check your IAR CE status and credits in FINRA’s Financial Professional Gateway (FinPro). Make sure every provider has your correct CRD number and name, so your completions are reported accurately.


