The SEC’s Proposed Accredited Investor Test Is Not Available Yet

As of October 7, 2026, the SEC has not opened a new accredited investor test or approved the additional credentials under consideration. On September 30, it issued notices seeking public comment on a potential FINRA-developed exam and additional professional qualifications. These are potential new routes—not eligibility that founders or investors can rely on today. The SEC’s exam notice sets a December 4, 2026 comment deadline.

For a technical operator considering angel investing, the distinction matters: a knowledge-based route could remove the need to meet an income or net-worth threshold. For a founder raising capital, it could broaden the eligible investor pool, but it does not change this round’s compliance requirements yet.

What the SEC actually did

The September 30 meeting agenda described consideration of notices under Rule 501(a)(10), the provision allowing the Commission to designate qualifying credentials by order after notice and public comment.

The subsequent SEC announcement confirms two distinct ideas:

• A new accredited investor exam developed by FINRA, with passage potentially qualifying an individual without meeting financial thresholds.
• Additional credentials held in good standing: a U.S. CPA license, CFA charter, U.S. CFP certification, Series 79 Investment Banking Representative license, or Series 86 and 87 Research Analyst license.

Holding one of those additional credentials does not, by itself, establish accredited status today. A notice requesting comment is not a final designation order.

What the proposed test would involve

The exam notice describes FINRA’s intended design. These specifications remain contemplated, rather than final:

Question	Intended approach
Who could take it?	Anyone aged 18 or older; no FINRA member-firm affiliation required
Format	Approximately 75 multiple-choice questions, in English, with approximately two hours to complete
Delivery	In-person testing through a third-party vendor
Cost	A fee anticipated to be similar to the SIE exam’s $100 fee cited in the notice—not a finalized price
Passing score	To be established through FINRA’s standard-setting process; no final score is specified
Validity	Ten years after passing, followed by another examination to continue relying on this route

The contemplated content covers securities definitions and structures, investment risks, disclosures and regulatory requirements, financial statements, conflicts of interest, and corporate governance. Investment risks would receive the largest weighting range, at 20%–28% of exam items. FINRA would also develop a way for issuers to independently verify passage and the validity period. Source: SEC exam notice.

This would be a separate exam, although its logistics would be modeled on the Securities Industry Essentials exam. Do not treat passing the SIE as passing an accredited investor test. Nor would the proposed exam itself authorize someone to conduct securities business or register with a FINRA member firm. Source: SEC exam notice.

What qualifies an individual today

The existing definition is not exclusively a wealth test. The SEC added a professional-license pathway in 2020; the September 2026 notice explicitly builds on that change. Source: SEC exam notice.

Current routes include:

• Net worth: more than $1 million, individually or jointly with a spouse or spousal equivalent, excluding the primary residence’s value and subject to the rule’s mortgage-debt treatment.
• Income: more than $200,000 individually, or $300,000 jointly with a spouse or spousal equivalent, in each of the previous two years, with a reasonable expectation of reaching the same level in the current year.
• Professional licenses: Series 7, Series 65 or Series 82 held in good standing.
• Role-specific categories: including directors and executive officers of the issuer, and certain knowledgeable employees of a private-fund issuer investing in that fund. These are not general-purpose credentials for investing in unrelated startups.

These categories are set out in the SEC’s notice and its accredited investor guide.

The common Series 65 shortcut needs particular care. You can take that exam without a sponsor, but passing alone is insufficient for accredited status. NASAA explains that the person must also be licensed as an investment adviser representative in their state and comply with state-specific requirements. Its exam FAQs distinguish exam enrollment from registration through an affiliated investment adviser firm.

What founders should do before accepting a check

Keep the investor’s claimed qualification separate from the offering’s assessment requirements:

1. Identify the current eligibility category. Do not substitute a proposed credential, course-completion certificate or anticipated exam result for a presently qualifying route.
2. Confirm the exemption with counsel. For investors treated as accredited, Rule 506(b) requires a reasonable belief in that status and prohibits general solicitation. Rule 506(c) permits general solicitation but requires all purchasers to be accredited and reasonable steps to verify them. Source: SEC exam notice. Rule 506(b) can also accommodate a limited number of non-accredited investors who meet its sophistication requirements, with additional disclosure obligations; accreditation is not the only possible route into a startup investment. Source: SEC Rule 506(b) guide.
3. Document the supporting information. The SEC warns that checking an accreditation box alone, without other knowledge of the investor’s circumstances or sophistication, does not satisfy either assessment standard. Source: SEC assessment guide.

For a private-fund commitment, also distinguish accreditation from the separate qualified-client analysis for performance fees.

Plan a closing around an investor’s established eligibility—not around the expected launch of a new test.