Webinar Recap: A Roadmap to IAR CE Compliance

Understanding and implementing IAR CE requirements continues to be a critical focus for compliance teams in 2025. Quest CE recently hosted an industry webinar where we provided comprehensive insights into the current state of IAR CE requirements, implementation strategies, and best practices for firms. Here’s what you need to know:

Core Requirements

The IAR CE requirement applies to all IARs registered in states that have adopted the model regulation, impacting both state and federally registered advisers. The annual requirements include:

• 12 total credits required by December 31st6 credits in Products and Practices6 credits in Ethics and Professional Responsibility
• 70% minimum passing score on a 10-question exam per credit hour

An important consideration is that courses cannot be repeated for credit in subsequent years, so training providers should offer new content annually.

State Adoption Update

As of 2025, 23 states have adopted the IAR CE requirement, with Rhode Island, Nebraska, New Jersey, Minnesota, and the U.S. Virgin Islands being the most recent additions. When new states adopt the requirement mid-year, implementation typically begins the following January, giving firms time to prepare for the upcoming requirements.

Registration Status and Compliance

The consequences of non-compliance follow a clear progression through two critical stages:

1. First Year of Non-Compliance: Status changes to “CE Inactive” at year-end & must complete all deficient credits to return to “Satisfied” status
2. Second Year of Non-Compliance: Status changes to “Fail to Renew”, registration eligibility is lost & must complete all deficient credits (24 total) and submit a new Form U4

Important Registration Scenarios

Several key scenarios require special attention from compliance teams. New registrants who join an IAR CE state begin their requirement the following year. However, IARs must complete the full 12 credits for the year even if they drop their license, as the requirement remains in effect for the entire calendar year. Thanks to reciprocity agreements, credits apply across all states, simplifying compliance for IARs registered in multiple jurisdictions. It’s important to note that excess credits cannot be carried over to subsequent years.

CFP Dual Credit Opportunities

For IARs who also maintain CFP certification, there are valuable opportunities to earn dual credit for their continuing education efforts. Key considerations include:

• Verify the vendor you are using has their IAR CE courses approved for CFP credit- All of Quest CE’s courses are currently approved for CFP dual credit
• CFP numbers must be added to license numbers in user profiles
• 30-day deadline exists for requesting CFP dual credit after completing the course

Regulatory Element Integration

The Regulatory Element can be applied toward the Products and Practices credits through two implementation paths:

1. Individual Route: IARs transfer credits through their FinPro account; Individual processing fees of $18 apply
2. Firm Route: Opt-in through FINRA Gateway; Applies to all advisers’ firm-wide; fees drawn from Flex Funding account

Best Practices for Compliance Teams

Effective management of IAR CE requirements demands a comprehensive approach. For successful implementation, firms should focus on three key areas:

1. Documentation and Records: Incorporate detailed IAR CE procedures into WSPs; Maintain thorough completion records; Ensure accurate CRD numbers and legal names
2. Strategic Planning: Align IAR CE with other training deadlines; Consider consolidated training rollouts; Plan well ahead of year-end deadlines
3. Program Management: Choose between individual retail accounts or firm training accounts; Monitor credit processing through FinPro; Address reporting issues promptly

Looking Ahead

Industry experts anticipate continued adoption of IAR CE requirements across remaining states, following a pattern similar to state annuity requirements. Firms are advised to stay informed about new state adoptions and maintain flexible compliance strategies to adapt to evolving requirements.

The success of IAR CE compliance relies heavily on proactive management, clear communication with advisers, and robust tracking systems. Firms should regularly review their approach to ensure it effectively supports their advisers while maintaining regulatory compliance.

For more information about IAR CE requirements, visit our IAR CE page. To obtain a recording of the webinar, click here.