How to Keep Your Series 65 Active: CE, Firm Registration, and EVEP

To keep your Series 65 active, you need to complete 12 hours of continuing education each calendar year in states that require it, stay registered as an investment adviser representative through a registered investment adviser firm, and if you leave that firm, either re-register or enroll in an extension program before your exam credit expires two years later. Miss any of these and you can end up ineligible to work, or back in the testing center. The rules aren’t complicated, but the calendar is unforgiving.

The Annual CE Requirement

The NASAA IAR Continuing Education Model Rule requires 12 credit hours each calendar year, split evenly. Six credits cover Products and Practice (portfolio theory, specific investment products, the business side of advisory work). The other six cover Ethics and Professional Responsibility (fiduciary obligations, regulatory requirements, ethical issues in advisory relationships).¹

One caveat before you plan anything: as of early 2026, 24 jurisdictions have adopted the model rule, not all 50 states.² If you’re registered only in a state that hasn’t adopted the rule, you don’t have an IAR CE obligation through NASAA. Check with your state securities regulator to confirm.

First-Year Registrants

If you register as an IAR for the first time in an adopting state, you owe no CE credits until January 1 of the following year. Register in March 2026, and your first full 12-credit cycle starts January 1, 2027.³

Professional Designations Don’t Exempt You

Holding a CFA, CFP, or ChFC does not waive IAR CE. There are no experience-based or designation-based waivers. Courses you take to maintain a designation can count toward your IAR CE if the provider and specific course are NASAA-approved, but confirm any dual-credit claim directly with the provider, since NASAA relies on self-reported information.³

Reporting and Tracking Your Credits

NASAA publishes the list of approved CE providers, and it changes as providers are added or removed.⁴ You can also view available courses through FINRA’s Financial Professional Gateway (FinPro), which is the hub for your CE transcript and registration information.⁵

After you finish a course, the provider submits completion data to CRD. A $3-per-credit reporting fee applies, so the full 12-credit annual requirement carries $36 in reporting fees.³ If you use FINRA Regulatory Element CE for the six Products and Practice credits, the $18 fee is paid directly through FinPro.⁶

All credits must appear on your IAR CE transcript in CRD by the end of the calendar year.³ Log in to FinPro periodically. If a credit is missing, contact the provider right away; December is a bad time to be chasing corrections.

What Happens If You Miss the CE Deadline

Consequences escalate over two years. Miss the 12-credit deadline and CRD sets your status to “CE Inactive” in every adopting state where you’re registered. You’ll still pay your renewal fee, but the record flags you as non-compliant.³

Inactive status is a one-year warning. Any CE you complete in the following year is applied to the prior year’s deficiency first, then to the current year. Once you’ve cleared the backlog, your status automatically updates to “Satisfied.”³

Stay Inactive through a second consecutive year and fail to catch up by the CRD System Shutdown date, and you become ineligible for IAR registration or renewal. To come back, you have to complete all deficient credits before you can even resubmit Form U4.³ That can mean up to 24 backlogged credits plus the current year’s 12 before you can work again.

Keeping Your Firm Registration Current

Passing the Series 65 gives you exam credit, but it doesn’t make you an IAR. You have to be registered through a registered investment adviser firm, which files Form U4 on your behalf. Firms manage these filings through the Investment Adviser Registration Depository (IARD) system.⁷

Registration is renewed annually through IARD. The renewal window opens in November with preliminary statements, filings are due in late December, and the final payment deadline falls in late January.⁸ State fees vary, generally from nothing up to $285. Your firm handles the mechanics, but confirming the renewal went through in every state where you do business is on you. If a state renewal lapses, your authority to give advice in that state ends with it.

The Two-Year Clock When You Leave a Firm

When you leave, your firm files Form U5 to terminate your registration. From that termination date, your Series 65 exam credit stays valid for exactly two years, and your CRD record shows a specific “valid until” date.⁹ Register with a new firm inside that window and your exam credit carries over. No retest.

Let the window close and your exam shows “Expired” in CRD. You’ll generally have to retake and pass the Series 65 to work as an IAR again; the exam fee is $187. NASAA notes that individual states have discretion to waive the retesting requirement even when an exam shows as expired.¹⁰ A waiver isn’t guaranteed, but ask your state regulator before scheduling a retake.

Track the exact date your U5 was filed. It starts the clock, and no reminder is coming.

Extending Exam Validity With EVEP

NASAA’s Exam Validity Extension Program lets you keep your Series 65 exam credit valid indefinitely after leaving a firm, as long as you stay enrolled and meet the requirements. It’s the answer to the two-year expiration for people stepping away from the industry.

To enroll in the IAR EVEP, you must meet all of these:¹¹

You’re not currently registered as an IAR.
Your exam hasn’t yet expired; enroll before the two-year window closes, because there’s no way in once it lapses.
You were registered as an IAR for at least one year immediately before termination.
You have no CE deficiency; if you’re behind by 12 credits or fewer, clear it before enrolling.

Enrollment is through FinPro. The annual fee is $35 for the IAR EVEP. If you also need to maintain a Series 63 through the separate Agent EVEP, that’s another $35.¹¹

While enrolled, you complete the same 12 annual CE credits (six Products and Practice, six Ethics and Professional Responsibility) that active IARs complete.¹¹ For anyone who might return to advisory work later, $35 a year plus coursework is far cheaper than retaking the exam.

1
NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION™. Course Requirements
2
NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION™. NASAA Launches Comprehensive Online IAR Continuing Education Course Catalog
3
NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION™. IAR Continuing Education FAQ
4
North American Securities Administrators Association. Approved IAR CE Providers
5
NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION™. IAR Continuing Education
6
FINRA. Financial Professional Gateway (FinPro Gateway)
7
FINRA. Series 65 – Uniform Investment Adviser Law Exam
8
IARD. 2026 Investment Adviser Renewal Program
9
FINRA. Exam Credit and Exam Validity
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NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION™. Exam FAQs
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NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION™. EVEP FAQs