Within 90 days of your fiscal year end. For calendar-year advisers (the most common setup for private fund managers), the deadline is March 31. You must file the annual amendment even if nothing about your business has changed.
The annual amendment updates your fund-level data in Schedule D (asset values, investor counts, service providers) and confirms that your firm-level information in Part 1A is still accurate. This is also the point where you report your current AUM, which matters if you rely on the private fund adviser exemption with its $150 million cap.
A common mistake is treating the annual amendment as optional during quiet years. The SEC expects it on time regardless. Late filings appear on your public IAPD record, and institutional LPs check filing dates during diligence. Set a calendar reminder for at least 30 days before your deadline to start gathering updated fund data.
See Form ADV Annual Amendments.
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