Beyond Wealth: A New Path to Accredited Investor Status

Following through on its stated priority of expanding retail access to private markets, the SEC is considering additional ways for individuals to qualify as accredited investors. The initiative would recognize financial knowledge and professional qualifications as additional pathways to investments traditionally restricted by income and net worth requirements.

On September 30, 2026, the Commission requested public comment on a potential accredited investor examination to be developed by FINRA and the recognition of additional professional credentials. These pathways remain under consideration and are not yet available.

A potential examination pathway

The examination would provide a non-financial pathway for individuals to demonstrate sophistication in securities, investing, and financial and business matters. The goal is to assess whether an investor has the knowledge needed to evaluate an investment’s merits and risks, without requiring the investor to meet an income or net worth threshold.

Additional professional qualifications

The SEC is also seeking comment on recognizing individuals who hold the following credentials in good standing:

• A U.S. Certified Public Accountant (CPA) license.
• A Chartered Financial Analyst (CFA) charter.
• A U.S. Certified Financial Planner (CFP) certification.
• The FINRA Investment Banking Representative license, Series 79.
• The FINRA Research Analyst license, Series 86 and Series 87.

These additions would build on the current framework, which already recognizes Series 7, Series 65, and Series 82 licenses held in good standing, alongside financial and other qualifying criteria.

Why this matters for investors and RIAs

The potential changes recognize that financial knowledge does not always correspond with wealth. If adopted, they could give knowledgeable individuals who fall below the financial thresholds greater access to private investment opportunities.

For RIAs, broader eligibility could expand the investment options available to certain clients. However, eligibility alone does not establish that an investment is appropriate. Advisers would still need to evaluate the investment in light of the client’s goals, liquidity needs, financial circumstances, and ability to bear losses. Their fiduciary obligations would continue to apply.

What comes next?

The public comment periods will remain open for 60 days following publication of the notices in the Federal Register. Until the SEC takes final action, firms should continue applying existing qualification requirements. The final outcome will determine whether, and under what conditions, the examination and additional credentials become recognized pathways.