Accredited Investor Requirements in 2026

Last reviewed: August 2026

Short version: the core thresholds did not move this year. Something adjacent to them did, and a bill that would move them is halfway through Congress.

Unchanged for 2026

• Net worth — more than $1 million, excluding primary residence. Set by Dodd-Frank in 2010, never indexed to inflation.
• Income — more than $200,000 individually or $300,000 jointly, in each of the two most recent years, with a reasonable expectation of the same in the current year.
• Professional credentials — Series 7, Series 65, Series 82, held in good standing. Added August 2020.
• Knowledgeable employees of the private fund being invested in.
• Entities — the $5 million asset test, family offices with $5 million under management, and the all-owners-accredited look-through.

The income and net worth figures date to 1982 and 2010 respectively and have never been indexed. The practical effect is that the accredited pool grows every year without any rule changing, because wages and asset prices move and the thresholds don't. The SEC's own four-year reviews have flagged this repeatedly.

What Actually Changed in 2026

The SEC’s five-year inflation adjustment to the qualified client thresholds under Advisers Act Rule 205-3. The final order — Release No. IA-6961, issued April 28, 2026 — raised the assets-under-management test from $1.1 million to $1.4 million, and the net worth test from $2.2 million to $2.7 million, excluding primary residence. The new figures took effect June 29, 2026.

Two things to note about how it applies. It is not retroactive: advisory contracts and fund subscriptions entered into before the effective date remain under the old thresholds, and existing investors can generally continue and add to existing positions without meeting the new numbers. And it bites at the investor level in 3(c)(1) funds, where each investor is treated as a client for this purpose — so every new investor in a fund charging carry must clear the new bar individually.

This does not change who can invest in a private offering. It changes who a registered investment adviser may charge performance fees. If you’re evaluating a vehicle with carry, this is the number that matters, and it is higher than it was in March.

What’s Pending

The INVEST Act (H.R. 3383) passed the House in December 2025 and is before the Senate. It would direct the SEC to add licensure-, education-, and experience-based qualification pathways, and to index the thresholds to inflation. It is not law. The Senate could amend it, pass it, or let it die.

The Accredited Investor Definition Review Act (H.R. 3348) would amend the Securities Act to require the SEC to maintain and expand the list of qualifying certifications and credentials — the mechanism by which a CFA, CFP, or a purpose-built SEC competency exam could become a qualifying pathway.

At the SEC, the current Commission has stated an intent to facilitate capital formation and broaden access to private markets. No rulemaking amending the accredited investor definition has been finalized.

Worth watching in both directions: a knowledge-based pathway would widen access, while indexing the thresholds to inflation would sharply narrow it. Indexed from 1982, the $200,000 income test would land somewhere north of $600,000. Those two reform tracks pull against each other, which is a large part of why neither has landed.

What to Do With This

If you qualify today under the income or net worth test, nothing about 2026 changes your status. If you’re a licensed professional who hasn’t crossed the wealth thresholds, the credential pathway is available now and is the most commonly missed one. If you’re evaluating a vehicle with a performance fee, check the qualified client numbers against the date you’d actually be subscribing.