On September 30, 2026, the SEC proposed the broadest expansion in years of who can qualify as an accredited investor. Instead of only income or net worth, the Commission asked for public comment on six new ways to qualify based on a professional credential or demonstrated knowledge.
The coverage has been loud and, in places, loose. So here is the careful version: what was actually proposed, what it would change, and the part most write-ups skip — none of it is law yet, and the credential route already works today for three licenses.
What this is and is not. This is an operational summary, not legal advice, and we are not a law firm. The proposals are detailed; for how any of this applies to a specific offering, confirm with your own securities counsel. Primary source: the SEC's September 30, 2026 press release (2026-96) and the individual proposing releases, file numbers 4-931 through 4-935.
What the SEC actually proposed
Six new credential and knowledge pathways, set out across five proposing releases (file numbers 4-931 through 4-935) — the Series 79 and Series 86/87 licenses share one release — each seeking comment on designating a credential or exam as a qualifying basis for accredited-investor status:
A new FINRA-developed accredited-investor exam
A new examination, to be developed by FINRA, that an individual could pass to qualify. (File 4-931.)
A U.S. CPA license
Holding an active license as a U.S. Certified Public Accountant. (File 4-932.)
A CFA charter
Holding the Chartered Financial Analyst charter. (File 4-933.)
A CFP certification
Holding the Certified Financial Planner certification in the United States. (File 4-934.)
Series 79, and Series 86 and 87
The FINRA Investment Banking Representative license (Series 79) and the Research Analyst licenses (Series 86 and 87). (File 4-935.)
All six are part of what the Commission has framed as a "responsible retailization" agenda — widening access to private markets, but through demonstrated competence rather than a pure wealth test.
These are proposals, not law
This is the sentence to hold onto: nothing here qualifies anyone today. Each proposal is open for a 60-day public comment period that runs from the date it is published in the Federal Register. After comments, the SEC would still have to adopt final rules — and may change, split, or decline any of them. If you hold a CFA charter or a CPA license, you are not an accredited investor on that basis right now.
That is not a technicality. We have already seen coverage that blurs "proposed" into "available," and an issuer who lets an investor in on a credential that is not yet a qualifying basis has not taken reasonable steps to verify anything.
What qualifies today, and why it still stands
The credential pathway itself is not new. Since the SEC's 2020 order under Rule 501(a)(10), a natural person has qualified as an accredited investor — regardless of income or net worth — by holding an active, in-good-standing FINRA license of one of these kinds:
Series 7, Series 65, or Series 82
General Securities Representative (7), Investment Adviser Representative (65), or Private Securities Offerings Representative (82). A Series 66 holder qualifies too, because the Series 66 is held together with the Series 7.
The 2026 proposal would add to this list. It does not repeal or narrow the existing designation. So the practical takeaway is reassuring in both directions: if you already hold a 7, 65, or 82, nothing about your status changes — and if the proposals stall, nothing changes either. That existing route is exactly what our $49 verify-by-license service confirms today.
The exam is the one to watch
Of the six, the proposed FINRA exam is the furthest-reaching. The professional-credential proposals (CPA, CFA, CFP, the additional FINRA licenses) extend status to people who, by and large, already work in finance. The exam is different: as described in the proposing-release summaries, it would let an individual qualify by demonstrating knowledge rather than by meeting any income or wealth threshold — a route potentially open to people who hold no securities license at all.
If that is adopted as proposed, it would be the single largest expansion of the accredited pool in the definition's history. It also raises a practical question the final rule will have to answer: an exam result only helps an issuer if passage can be independently verified. A credential nobody can check cannot support reasonable steps — a point we think is worth making in the comment process.
What it means if you are an investor
If you hold one of the proposed credentials, the honest answer today is: wait and watch. The direction of travel is clearly toward credential-based access, but you cannot rely on a CPA, CFA, or CFP to get into a 506(c) deal until a final rule says so. If you hold a Series 7, 65, or 82, you already qualify and can be verified now.
One quiet advantage worth knowing: credential-based accreditation is easier and more private to prove than the income or net-worth route. There are no tax returns or bank statements to hand over — the basis is a credential sitting in an official registry, confirmed and signed off by a licensed professional.
What it means if you are raising a 506(c)
Even if every one of these is adopted, one thing does not change: you still have to take reasonable steps to verify that an investor is accredited. If the basis is a credential, reasonable steps means confirming the credential is genuinely held, currently active and in good standing, and — the step most often skipped — that the investor actually is the person who holds it. A matching name in a public registry is not the same as a verified investor; common-name collisions are more frequent than people expect.
Handled well, this is good news for issuers. Credentials are cheaper and faster to verify than a shoebox of financial documents, and they keep an investor's sensitive financials out of your deal room. The work shifts from reviewing tax returns to confirming a credential and an identity — which is exactly the kind of check a third-party verifier is built to document and stand behind.
Verify by license today — $49
Hold an active Series 7, 65, or 82? You already qualify. We confirm it on the FINRA/SEC registry and a licensed CPA signs your 506(c) letter — no financial documents.
See how license verification works →Where we stand
We verify the existing license pathway every day, so we have a view — and a stake, which we will state plainly. We think expanding credential-based access is good for investors and for the private markets. We also think the proposals are only as good as the verification behind them: a credential should convey status while it is active and in good standing, confirmed by a documented, independent check that includes the investor's identity — not an investor's say-so, and not an unreviewed database lookup. We intend to say exactly that in a comment to the SEC, and we are building so that the moment any new credential becomes a qualifying basis, we can verify it.
If you want to weigh in yourself, the comment windows are open for 60 days after each proposal publishes in the Federal Register, through the SEC's comment form for the relevant file number (4-931 through 4-935).
Frequently Asked Questions
What did the SEC propose for accredited investors in 2026?
On September 30, 2026 the SEC issued six proposals (press release 2026-96) seeking comment on new ways for a natural person to qualify as an accredited investor based on credentials or knowledge: passing a new accredited-investor exam to be developed by FINRA, holding a U.S. CPA license, holding a CFA charter, holding a CFP certification, or holding the FINRA Series 79 or Series 86 and 87 licenses. They are proposals open for public comment, not final rules.
Do the proposed new credentials qualify someone as an accredited investor now?
No. These are proposals open for a 60-day public comment period that runs from publication in the Federal Register. The SEC would then have to adopt final rules. Until that happens, none of the proposed credentials — CPA, CFA, CFP, Series 79, Series 86/87, or the new exam — qualifies anyone. The existing pathways, including the Series 7, 65, and 82 licenses, are unchanged.
Which professional licenses make someone an accredited investor today?
Since the SEC's 2020 order under Rule 501(a)(10), a natural person holding an active FINRA Series 7, Series 65, or Series 82 license in good standing is an accredited investor regardless of income or net worth. A Series 66 holder qualifies because the Series 66 is held together with the Series 7. The 2026 proposal would add to this list; it does not replace it.
Would issuers still have to verify accredited status if the credentials are adopted?
Yes. Rule 506(c) requires the issuer to take reasonable steps to verify each investor is accredited. If the basis is a credential, reasonable steps means confirming the credential is genuinely held, currently active and in good standing, and matched to the investor claiming it. Accepting an investor's unverified word is not reasonable steps.
How would a FINRA accredited-investor exam change things?
The exam is the furthest-reaching of the six proposals because, as described in the proposing release summaries, it would let an individual qualify by demonstrating knowledge rather than meeting an income or wealth threshold. If adopted, it would open accredited status to people who hold no professional license at all — subject to the exam being built and the final rule being adopted.