How State Requirements for IARs Work
Investment advisor representatives are registered and regulated by the states, so the requirements to become and remain an IAR are set state by state. In practice, most states follow the same model, drawn from the Uniform Securities Act and model rules from NASAA. That is why the core requirements look very similar everywhere, while details such as fees, continuing education and certain registration triggers differ.
The core requirements in almost every state are the same four steps. You qualify through the Series 65, the Series 66 with the Series 7, or a recognised waiver. You are associated with an investment adviser, which files your registration through Form U4, and the state approves it.
This guide sets out the common requirements first, then the areas where states differ, including the jurisdictions that now require annual continuing education. For the registration process step by step, see our guide to how IAR registration works.
The Requirements Every State Shares
Every state requires an IAR to be qualified, to be associated with an investment adviser and to be registered through the firm. Qualification is almost always the Series 65, the Uniform Investment Adviser Law Examination, which has 130 scored questions, a 180-minute limit and a pass mark of 92. Because the exam is uniform, the same result is accepted in every state.
Every state also expects honest, complete disclosure on Form U4, including criminal, regulatory, civil and financial history. States can deny, suspend or condition a registration for false statements or for disqualifying events listed in their securities law. Background checks, including fingerprinting, are a standard part of the process.
Finally, every state imposes the same broad duty once you are registered. As an IAR you owe clients a fiduciary duty and must follow state rules on ethical business practices, many of which are tested on the Series 65.
The Exam Accepted in All States
The Series 65 is accepted by every state that registers IARs, which makes it the single most portable qualification in advisory work. It is developed by NASAA and administered by FINRA, and the $187 fee is the same wherever you live. It needs no sponsoring firm and no prerequisite exam.
FRC’s Series 65 Exam Prep is $200, and each chapter must be assessed before the next unlocks, so you see where you stand before you book. Our guide to how much a Series 65 course costs sets out the full budget, including the exam fee.
The alternative is the Series 66 taken with the Series 7, which suits candidates who also want to act as a registered representative. Our guide to whether investment advisor representatives need the Series 65 explains when each route applies.
Where State Requirements Differ
States differ mainly in four areas: which individuals they require to register, which professional designations they accept in place of the exam, how much they charge, and whether they require annual continuing education. Each of these can affect how long registration takes and what it costs. None of them changes the core route through the Series 65.
The differences matter most for IARs who work across state lines or who serve clients in many states. An advisory firm’s compliance team usually handles each state’s requirements, because the firm files the registrations. Even so, an IAR who understands the differences can plan their career and their continuing education with fewer surprises.
When a State Requires You to Register
Whether a particular state requires you to register as an IAR depends partly on how your firm is regulated. For an adviser registered with the Securities and Exchange Commission (SEC), federal law generally allows a state to require IAR registration only from individuals who have a place of business in that state. Those individuals usually register only where their office is located.
For a state-registered adviser, the picture is broader. The IAR is generally registered in the firm’s home state and in other states where the firm and the individual do business, subject to limited exemptions for advisers with no place of business and very few clients in a state. These exemptions vary in detail, which is one reason firms check each state carefully.
The split between SEC and state registration depends mainly on the firm’s regulatory assets under management. Our guide on investment advisor representative vs registered investment adviser explains how that works.
Exam Waivers Accepted by States
Many states waive the Series 65 or Series 66 for individuals who hold certain recognised professional designations. NASAA maintains a model list, and states adopt it, sometimes with variations. The list has changed over time, so the current version in your state is what counts.
A waiver removes only the exam. The advisory firm still files the registration, the state still reviews the application, and the individual still owes the same duties. Candidates who are unsure whether a designation qualifies should ask the hiring firm’s compliance team before relying on it.
For most people entering the profession, the Series 65 remains the simplest route because it is accepted everywhere without exception. That certainty is valuable for anyone who expects to move firms or states during their career.
Registration Fees and Renewals
Each state sets its own IAR registration fee and annual renewal fee. The advisory firm usually pays these fees when it files Form U4 and when registrations renew at the end of each year. An IAR registered in several states generates a fee in each one.
Renewals run through the annual registration renewal programme. If a state’s renewal fee is not paid, the registration in that state can lapse, even if the IAR remains registered elsewhere. Firms track these deadlines closely because a lapse means the IAR cannot act in that state until the registration is restored.
Fees change from time to time, and they are not usually a barrier for individuals because firms cover them. They do matter to firms with many IARs across many states.
Which States Require IAR Continuing Education?
As of 2026, 25 jurisdictions have told NASAA that they have an IAR continuing education requirement in place or adopted. They are Arkansas, California, Colorado, Florida, Hawaii, Illinois, Indiana, Kentucky, Maryland, Michigan, Minnesota, Mississippi, Nebraska, Nevada, New Jersey, North Dakota, Oklahoma, Oregon, Rhode Island, South Carolina, Tennessee, Vermont, Washington, D.C., Wisconsin and the U.S. Virgin Islands. Indiana’s requirement is listed as starting in 2027.
Several large states, including New York, Texas, Pennsylvania, Ohio and Georgia, had not adopted the requirement at the time of writing. The list continues to grow, so IARs in any state should expect the requirement to reach them eventually. Firms often apply the same standard across all their IARs for simplicity.
The requirement follows NASAA’s model rule. Under it, IARs complete 12 credits each calendar year, 6 in ethics and professional responsibility and 6 in products and practice, and each half must be met on its own.
How the CE Requirement Works
Credits must be completed through approved providers and appear on the IAR’s continuing education record by the end of each calendar year. A single set of 12 credits satisfies every CE jurisdiction where the individual is registered. Courses cannot be repeated for credit, and excess credits do not carry forward to the next year.
An IAR who misses the requirement in a covered jurisdiction becomes CE inactive. Their registration does not renew there until the missing credits are completed, and they cannot act as an IAR in that jurisdiction in the meantime. Restoring the registration can involve completing the credits and having the firm file again.
New IARs are not caught out immediately. In general, an individual’s first year of required credits begins in the calendar year after they first register in a CE jurisdiction. Planning the first year’s credits early avoids a rush in December, when providers and registration systems are busiest.
What the CE Topics Cover
The ethics and professional responsibility credits focus on the conduct expected of a fiduciary. Typical topics include conflicts of interest, disclosure, suitability of advice, handling client complaints, cybersecurity and protecting senior and vulnerable investors. These mirror the ethical business practice rules that states enforce.
The products and practice credits focus on the technical side of advice. Typical topics include investment products, portfolio construction, retirement planning, tax considerations and new regulatory developments. They are designed to keep advisers current as products and markets change.
For candidates still preparing for the Series 65, the CE topics are a useful preview. The same areas that appear on the exam reappear every year in continuing education, so a deep understanding built now pays off for the whole career.
Dual Registrants and State Agent Requirements
IARs who also act as registered representatives of a broker-dealer must meet each state’s requirements for securities agents too. For agents, the usual state law exam is the Series 63, or the Series 66 for those combining both roles. Agent registration is filed through the same Form U4.
Dual registrants also follow FINRA requirements, including FINRA Rule 1210 on registration and FINRA’s own continuing education programme. That means two sets of continuing education, one for the brokerage registration and one for the advisory registration in CE states. Our comparison of investment advisor representative vs registered representative explains the two roles side by side.
The Series 63 course covers the agent exam for roles that need it. FRC’s Series 7 Exam Preparation can be started before a firm sponsors you.
Moving to a New State
An IAR who moves to a new state usually needs to be registered in that state if they will have a place of business there. The firm files an amendment to Form U4 to add the new state, and the state reviews the application. A valid Series 65 result carries across, because the exam is uniform.
If the move also involves changing firms, the old firm files Form U5 within 30 days and the new firm files a fresh Form U4. Exam results stay valid for two years after a registration ends, so a short gap between firms does not usually require retaking the exam.
Moving into or out of a CE jurisdiction changes the continuing education picture. An IAR moving into a CE state generally begins the requirement the following calendar year.
Common Questions About State Requirements
Do I need to pass the Series 65 again for each state? No. The Series 65 is a uniform exam, so one passing result is accepted by every state that registers IARs. Each state still requires its own registration through Form U4.
Can I be an IAR in a state without living there? Yes. Registration depends on where you have a place of business and where your firm does business, not on where you live. An IAR working from an office in one state can serve clients in others, subject to each state’s registration rules.
Does my state require CE if my firm is SEC-registered? The CE requirement attaches to the individual’s IAR registration in the state, not to the firm’s regulator. If you are registered as an IAR in a CE jurisdiction, the requirement applies whether your firm is SEC-registered or state-registered.
State Rules on Conduct and Ethics
Every state enforces rules on ethical business practices for investment advisers and their representatives, based largely on NASAA model rules. These cover areas such as unsuitable recommendations, undisclosed conflicts, misleading advertising, improper custody of client funds and unauthorised trading. State Blue Sky laws give regulators power to investigate and sanction breaches.
Federal rules apply alongside state rules for many firms. The Investment Advisers Act of 1940 governs SEC-registered advisers, including the compliance programme under SEC Rule 206(4)-7 and recordkeeping under SEC Rule 204-2. State regulators keep anti-fraud authority over advisers and IARs operating in their state.
These rules are the reason the Series 65 spends so much time on law, regulation and ethics. Mastering them is as important for the job as for the exam.
How Clients Check an IAR’s State Registration
Clients can check which states an IAR is registered in through the SEC’s Investment Adviser Public Disclosure records, which BrokerCheck also links to. The record shows current and past registrations, exams passed, employment history and any disclosures. State regulators also offer their own lookup services.
For an IAR, that public record starts the day the first registration is approved. Every state registration, every firm and every disclosure becomes part of it. Accurate filings from the start keep the record clean.
Clients who want to understand an adviser’s role in more depth can compare it with other titles. Our guide on investment advisor representative vs financial advisor explains why the registration matters more than the title.
The January 2027 Change Applies in Every State
From January 4, 2027, NASAA shortens the Series 65 retake wait after a third failed attempt from 180 days to 60, for exam windows opened on or after that date. Because the exam is uniform, the change applies to candidates in every state at once. The waits after a first and second failure remain 30 days.
Our guide to the Series 65 rule change explains how the enrollment window rule works. The best plan in any state is still to prepare thoroughly and pass the first time.
Practise the Terms With the FRC Dictionary
The free FRC dictionary explains the state and federal rules behind IAR registration, and signing in with Google unlocks on-page quizzes and interactive flash cards. Work through the entries linked here, from the Uniform Securities Act and Blue Sky laws to the Investment Advisers Act of 1940. They cover the law sections the Series 65 examines most closely.
The firm-level entries are useful too. Understanding registered investment advisor, investment adviser and Know Your Customer (KYC) helps you see how your registration fits inside your firm’s obligations.
Making Your Preparation Visible to Advisory Firms
FRC’s Digital Profile shows the courses you are actively studying, the chapters you have completed and your real-time assessed progress, verified by FRC. With Professional Membership, a QR code on your resume takes a hiring manager straight to that profile. Wherever you plan to register, an advisory firm can see your Series 65 preparation under way and how far it has gone.
The FRC Video Resume shows how you communicate before anyone meets you, which matters in a profession built on trust. Our guides to how the FRC Video Resume works and get seen before you get interviewed explain where it fits, and the Professional Membership page has the full detail at $39.99 a month.
The full list of FRC courses for USA candidates shows every programme in one place, and the membership and deals page lists combined pricing, paid in full.
One Exam, Many States
The good news for anyone entering advisory work is that the core IAR requirements are the same everywhere: pass the Series 65 or an accepted alternative, join an advisory firm, and let the firm register you. What varies by state is mostly administrative, from fees and registration triggers to continuing education. With 25 jurisdictions now requiring annual CE, staying current is becoming part of the job across the country.
For the full route into the profession, read how to become an investment adviser representative and our guide to what an investment advisor representative (IAR) is. The Investment Advisor Representative Pathway shows where the first registration can lead.
