SEC 2026 AI Examination Readiness Checklist | Polygraf AI

SEC 2026 AI Examination Readiness Checklist

The SEC named AI its #1 examination priority this year. Know exactly what examiners will request.

Chief Compliance Officers and operational leadership at SEC-registered investment advisers, broker-dealers, investment companies, and any registered entity using AI tools in client-facing or operational workflows.

The SEC’s 2026 examination priorities represent the most significant shift in examination focus in five years — AI has displaced cryptocurrency as the dominant risk concern. Most RIAs are not prepared for AI-specific examination questions, particularly around conflict-of-interest controls for AI advisory tools and model risk documentation.

A five-section examination readiness checklist covering: AI governance framework (Section A), fiduciary duty and client interest protections (Section B), data privacy and GLBA security controls (Section C), model risk management documentation (Section D), and algorithmic trading and market conduct controls (Section E). Each item identifies exactly what evidence to produce.