The compliance landscape for investment managers is shifting faster than it has in years. At ACA Group’s recent spring media roundtable, the firm’s experts laid out the regulatory developments, enforcement trends, and operational pressures that compliance leaders need to be across right now.
According to ACA Group, five priorities emerged as the most pressing areas of focus for chief compliance officers heading into the rest of the year.
ACA Group recently detailed five things every CCO needs to know, whilst providing insights from its spring 2026 media roundtable.
Deregulation is not a green light
Despite the loosening regulatory tone coming out of Washington, the pressure on compliance teams is not easing — it is just coming from a different direction. Capital raising has fallen to its lowest point since 2020, and the limited partners allocating scarce capital are asking sharper questions about governance, risk management, and compliance infrastructure. Firms that interpret deregulation as an invitation to scale back their compliance efforts are, according to ACA’s experts, reading the situation backwards.
The SEC’s enforcement focus is both narrower and broader
The previous administration’s enforcement approach produced more than $4bn in fines tied to books-and-records violations, and that era appears to be over — but the recordkeeping rules themselves have not changed. A future administration could take a very different view of firms that failed to tighten up their processes in the interim.
The SEC has signalled that its enforcement resources will now be directed at fraud and direct investor harm. However, recent cases have demonstrated that investor harm can flow from negligence, conflicts of interest, and valuation irregularities in private credit.
Jay Clayton, the former SEC chair now heading the Southern District of New York, has publicly questioned whether valuations on firms’ books reflect market reality. For firms operating in private credit or private equity, valuation governance must be defensible, documented, and independently tested.
AI adoption is outpacing AI governance
ACA’s proprietary research found that more than 80% of investment management firms are now using AI in some capacity, up from roughly 20% three years ago. Most usage remains surface-level — desktop tools, drafting assistance, basic query functions — with only around 8% of firms having integrated AI into client-facing workflows.
The more urgent problem is governance. Business units across many firms have already deployed AI tools before formal compliance oversight was in place, and the infrastructure to manage those tools has not caught up. Regulators and LPs are now testing firms across five areas: whether they have an authorised use policy; a governance framework; model testing and validation; cybersecurity controls around AI; and oversight of how vendors are using firm data. Gaps in any of these areas represent meaningful risk.
Cybersecurity exams have shifted from checkbox to evidence
Regulators are no longer satisfied with a risk assessment alone. SEC examiners have moved on from reviewing documentation of process to demanding evidence of action. Firms that can produce a clear audit trail — identifying an issue, escalating it, remediating it, and evidencing each step — are in a materially stronger position than those presenting a high-level checklist with every box ticked. The same shift is now visible in LP operational due diligence.
The retail alternatives door is open, but the education gap is real
The regulatory infrastructure enabling retail access to alternative investments is advancing on multiple fronts. The Department of Labour’s proposed fiduciary safe harbour, the SEC’s removal of the 15% illiquid asset cap for closed-end funds, and co-investment relief for registered vehicles have together opened a path that was previously closed to most retail investors.
What has not kept pace is the adviser education infrastructure needed to support the sale of these products to clients who may not fully understand what illiquidity means when markets move. Marketing rules for retail investors are substantially more demanding, particularly around performance information, and the SEC’s examination sweep of interval funds and private credit vehicles is widening. Private fund advisers looking to enter the retail market must consider not only product compliance but whether their distribution channels are ready to support it.
As ACA’s roundtable made clear, the compliance environment in 2026 is not simpler than it was — it is just different. The rules are evolving, the risks are shifting, and the expectations from LPs, regulators, and the broader market have never been higher.
Read the full ACA Group post here.
Copyright © 2026 RegTech Analyst
Copyright © 2018 RegTech Analyst
