The accredited investor requirements that apply to an individual in the U.S. on November 4, 2026 are the same ones that applied at the start of the year, even though the SEC is now asking whether to widen them. On September 30, 2026, the SEC issued five notices asking whether to add a FINRA exam and several professional credentials as new ways to qualify. The notice on the exam appeared in the Federal Register on October 5, with comments due by December 4. A correction to its comment instructions followed on November 3.
None of those notices has become an order, so none of the new routes exists yet. An investor who wants to know whether they qualify today should test themselves against the current rule, which turns on income, net worth or a securities license. The question matters most in private markets, including private U.S. real estate, a field the U.S. real estate market guide describes by property type and risk. Many of those private offerings are open only to accredited investors.
What the Accredited Investor Definition Is For
The accredited investor definition sits in Rule 501(a) of Regulation D, the set of SEC rules for raising money without registering an offering. Registration brings a full disclosure document filed with the SEC. An exempt offering skips that step, so the SEC limits some exempt offerings to people it expects can evaluate the risks and bear a loss.
That is why the definition matters to anyone looking at private U.S. property. A sponsor raising money under Rule 506(c) may advertise the deal publicly, but every buyer must be an accredited investor, and the sponsor must check. The investor's status is checked at each purchase, even where an earlier verification can be relied on.
Accredited Investor Requirements by Income, Net Worth or License
The SEC's accredited investors page, last updated on April 24, 2026, sets out three main tests for individuals. Meeting any one of them is enough.
- Net worth above $1 million, alone or with a spouse or spousal equivalent, not counting the primary residence.
- Income above $200,000 in each of the two most recent years, or joint income above $300,000 with a spouse or spousal equivalent, with a reasonable expectation of the same level this year.
- A Series 7, Series 65 or Series 82 license held in good standing.
The net worth test treats the home in a specific way. It is left out as an asset, and so is the mortgage on it, up to the home's estimated value. Any increase in that mortgage in the 60 days before the investment counts as a liability, unless it was taken out to buy the home. A "spousal equivalent" is defined as a cohabitant in a relationship generally equivalent to a spouse.
The income test looks backward and forward at once. Two years above the line are not enough without a reasonable expectation of reaching it in the current year. Other routes exist for directors and executive officers of the issuer, knowledgeable employees of a private fund, and entities such as trusts and family offices with more than $5 million in assets.
The Accredited Investor Exam and Other Proposed Routes
The September 30 notices rest on Rule 501(a)(10), added in 2020. It lets the SEC designate professional certifications as qualifying, by order, after notice and public comment. The Series 7, 65 and 82 licenses were designated in 2020 under the same rule. The five new notices ask whether to add a FINRA exam to be developed for this purpose, a U.S. CPA license, the CFA charter, the CFP certification in the U.S., and the Series 79 and the Series 86 and 87 licenses.
The exam is the notice that departs furthest from the current rule, because it would not require a finance career. According to the notice, FINRA anticipates that the exam would be open to anyone 18 or older, with no link to a FINRA member firm required. It would have about 75 multiple choice questions and a time limit of about 2 hours. A pass would be valid for ten years, after which the holder would need to pass again. A holder would qualify only for their own purchases, never on behalf of another person.
The notice states that this description reflects what FINRA currently intends, so details could change before any order. The SEC's September 30 announcement called this a request for public comment on additional ways to qualify, and each notice says only that the SEC is considering whether to issue an order. Nothing is settled while the comment period runs, which closes on December 4, 2026.
How Issuers Verify Accredited Status Under Rule 506(c)
Self-certification is not enough in a 506(c) offering. The issuer must take reasonable steps to verify each buyer, and Rule 506(c) lists methods that the SEC treats as meeting that standard. For income, the issuer can review IRS forms that report income for the two most recent years, plus a written statement from the investor about the current year.
For net worth, the issuer can review bank, brokerage and similar statements dated within the prior three months. A consumer report from a nationwide credit bureau shows liabilities. Alternatively, a registered broker-dealer, an investment adviser registered with the SEC, a licensed attorney or a CPA can confirm in writing that they verified the investor within the prior three months. An investor that one issuer has verified can, for five years, give that issuer a written statement at each later purchase. This works only if the issuer has no information to the contrary.
Risks and Limits of Accredited Investor Status
Accredited status is a legal threshold. It does not show that a private investment is suitable, and an exempt offering has not been through SEC registration. A private real estate investment can lose capital, and distributions may not be paid. Property values can fall, tenants can leave, and debt magnifies losses when values drop.
Liquidity is a separate limit. Interests in a private property deal usually cannot be sold until the property is, as the guide to liquidity before a U.S. property is sold explains. A single deal also concentrates risk in one building, one market and one sponsor. Planning a purchase around a credential that may never be designated adds a further risk, because the notices could be changed or dropped.
A Status Measured Against Today's Rules
The proposals have changed the debate about who should count as accredited, but they have not changed the answer for any individual today. Until the SEC issues an order, the tests remain income, net worth and the Series 7, 65 and 82 licenses. An issuer running a 506(c) offering will verify against those tests at each purchase.
Confirmed status allows an investor to buy into certain private offerings, but it says nothing about any one of them. The property, the debt, the sponsor and the exit still need their own review, with help from the guide to U.S. property types and their risks. On Raveum, participation is limited to non-U.S. persons under SEC Regulation S and verified U.S. accredited investors under Regulation D Rule 506(c), and U.S. investors receive K-1s. Eligible investors can review how verified accredited investors invest through Raveum, including the property, sponsor, ownership structure, fees, risks and offering documents for each opportunity.
Frequently Asked Questions
Can You Become an Accredited Investor by Passing an Exam?
Not yet. On September 30, 2026, the SEC asked for public comment on whether passing a FINRA exam, still to be developed, should qualify an individual. Comments are due by December 4, 2026. Until the SEC issues an order, the only license route is a Series 7, 65 or 82 held in good standing.
Does Home Equity Count Toward the Accredited Investor Net Worth Test?
No. Under Rule 501(a), the primary residence is left out of the net worth calculation, and so is the mortgage on it up to the home's estimated value. Any mortgage increase in the 60 days before the investment, other than to buy the home, counts as a liability and reduces net worth.
Can a Spouse's Income Count Toward Accredited Investor Requirements?
Yes. Joint income with a spouse or spousal equivalent above $300,000 in each of the two most recent years qualifies, with a reasonable expectation of the same this year. A spousal equivalent is a cohabitant in a relationship generally equivalent to a spouse. Joint net worth above $1 million also qualifies.
How Do Issuers Verify That You Are an Accredited Investor?
In a Rule 506(c) offering, the issuer must take reasonable steps. Common methods are reviewing two years of IRS income forms, reviewing recent account statements with a credit report, or relying on a written confirmation from a CPA, attorney, registered broker-dealer or investment adviser registered with the SEC, dated within the prior three months.
Will a CPA, CFA or CFP Make You an Accredited Investor in 2026?
Not on current rules. The SEC issued notices on September 30, 2026 asking whether to designate a U.S. CPA license, the CFA charter, the CFP certification in the U.S., and the Series 79 and Series 86 and 87 licenses. They are requests for comment, and the SEC is only considering whether to issue orders.
Does Accredited Investor Status Mean a Private Investment Is Right for You?
No. Status is a legal threshold for buying certain exempt offerings, not a judgment that any investment suits you. Private real estate can lose capital, may not pay distributions and is usually hard to sell before the property is sold. Each offering's documents, debt and sponsor need their own review.
This article is for general education only and is not investment, tax or legal advice. Rules change and depend on individual circumstances. Investing in private real estate involves risk, including loss of capital, illiquidity, falling property values, distributions not being paid and currency movements. Participation is limited to non-U.S. persons under SEC Regulation S and verified U.S. accredited investors under Regulation D Rule 506(c), and offerings on Raveum are not open to the general public.
