A fund website can be a great marketing tool. It can also be a compliance headache, especially if all website requirements aren’t satisfied before launch.
This guide, organized by relevant rules, walks through the website requirements an adviser should satisfy before launching a new fund or ETF site. Save this as a reference sheet not just before you launch, but also going forward, as there are some recurring obligations that you need to remain aware of.
1. Fix your specified website addresses before documents go to print
Start here. Several rules require documents to be available not merely somewhere on your site, but at a specific address printed in another document:
- Under Rule 498, required online documents must be posted and made available at the website address listed on the cover page of the summary prospectus.
- Rule 30e-1(b) requires shareholder report materials to be publicly accessible at the address specified at the beginning of the shareholder report.
The SEC staff has been explicit that the address must lead investors directly to the documents. In ADI 2025-15, staff reported finding summary prospectuses with no usable address at all, and others pointing to a generic homepage. A central page with prominent links to each required document is acceptable; a homepage or a section where the documents aren’t directly accessible is not.
Settle your URL architecture before the prospectus is typeset, and choose paths you will not want to reorganize in a future redesign.
- Specified address decided, documented, and reflected in prospectus and shareholder report drafts
- Specified address resolves directly to the documents, not to a homepage or landing page
- Path chosen with an eye to surviving future site redesigns
2. Summary prospectus requirements (Rule 498)
If the fund is using a summary prospectus to satisfy delivery obligations, the following must be posted at the specified address, on or before the time the summary prospectus is provided to investors:
- Current summary prospectus
- Current statutory prospectus
- Current statement of additional information
- Most recent annual and semi-annual reports to shareholders
Formatting and navigation conditions apply to each:
- Human-readable, and printable on paper in human-readable form — not machine-readable code rendered in a browser
- Presented in a format convenient for both reading online and printing (two separate formats is one acceptable approach)
- Tables of contents in the statutory prospectus and SAI hyperlinked, permitting movement in both directions between the contents and the related sections
- Linking between the summary prospectus and the statutory prospectus/SAI — links positioned at both the beginning and end of the summary prospectus, or continuously visible
- Permanently retainable free of charge, with the retained version preserving both the format conditions and the internal table-of-contents linking
Staff observed real failures on each of the linking conditions: documents with no hyperlinked table of contents, summary prospectuses with no links to the statutory prospectus or SAI at all, and others with links at the beginning only rather than at both ends.
3. Shareholder report materials (Rule 30e-1(b))
Under the tailored shareholder report framework, information moved out of the shareholder report and into Form N-CSR must be available online:
- Form N-CSR Items 7 through 11 publicly accessible, free of charge, at the address specified at the beginning of the shareholder report. Posting the complete Form N-CSR is an accepted alternative.
- A separate shareholder report prepared for each series, and for each class within a multi-class series
- Hyperlinks provided for any online information the report references, giving immediate access
- Reports filed on Form N-CSR and tagged in Inline XBRL
4. ETF daily disclosure (Rule 6c-11)
For ETFs relying on the rule, five items must be disclosed publicly and prominently:
- Daily portfolio holdings before market open, with ticker, CUSIP or other identifier, description, quantity, and percentage weight
- NAV, market price, and premium or discount as of the prior business day
- Historic premium and discount information as both a table and a line graph
- 30-day median bid-ask spread, rolling, calculated on NBBO
- The 2% premium/discount disclosure, when triggered, with a discussion of contributing factors
ETFs operating under an exemptive order rather than Rule 6c-11 should work from the terms of their relief and Form N-1A instead. Non-transparent and semi-transparent funds carry additional conditions, including a distinguishing website legend.
We have covered these five items and the specific presentation failures the SEC staff observed in a companion Flash Report on ETF website disclosure requirements.
5. Proxy voting record (Form N-PX)
Often overlooked at launch, because the first filing deadline falls well after go-live:
- If the fund has a website, the information in its most recently filed Form N-PX is made publicly available, free of charge, on or through the site as soon as reasonably practicable after filing
- Presented in human-readable format — a direct link to the HTML-rendered Form N-PX on EDGAR satisfies this
- Registration statement (Form N-1A, N-2 or N-3) states the record is available both on or through the website and upon request, free of charge in both cases
- For Forms N-1A and N-3, the email address investors may use to request the record, if there is one
Form N-PX is filed annually by August 31 for the twelve-month period ending June 30. Build the page and the process now, so the first filing does not become a scramble. For more details on N-PX and its requirements, check out our related flash report here.
6. Recurring obligations — assign owners before launch
Everything above is a point-in-time condition. What follows is what determines whether the site is still compliant in three years.
- Daily publishing with a hard cutoff. Holdings must post before the opening of regular trading on the primary listing exchange. Establish the cutoff, and the escalation path when it is missed.
- Quarterly refresh of historic premium and discount data. Staff found this stale on live sites. It is the one item in a daily-updating suite that runs on a quarterly clock, which is precisely why it gets missed.
- Threshold monitoring for the 2% trigger. A conditional disclosure requires a control, not a template. Somebody or something must be counting consecutive trading days.
- Annual and semi-annual document rollover. Rule 498 requires the current A superseded prospectus left online is a live violation.
- Change control on the website itself. Any redesign, navigation change, or CMS migration should be re-tested against the prominence and linking conditions before it ships.
- Retention and evidence. Keep a record of what was posted and when. If a reviewer asks whether a disclosure appeared on the eighth trading day, you will want proof rather than recollection.
- A named owner for each line above. Diffused ownership between the adviser, administrator, and web vendor is the most common root cause of the failures the staff has documented.
7. On the horizon — but not yet a requirement
- The SEC proposed Regulation E-Delivery on July 16, 2026, published it in the Federal Register on July 21, and set a comment deadline of September 21, 2026. If adopted, it would make electronic delivery the default without affirmative investor consent, and would rescind Rule 30e-3.
- This is a proposal, not a final rule. It would take effect 60 days after publication of a final rule, followed by a two-year transition during which existing e-delivery guidance remains available. Nothing in it should be built into a site launching today.
Need Assistance?
We’re here to help. FilePoint builds and hosts fund and ETF websites for advisers and administrators, including the daily disclosure suite, document hosting, Form N-PX posting, and the monitoring controls behind them. We can also embed a plugin to existing sites that dynamically displays all required fund data in real time. If you are launching a fund and would like assistance building and maintaining a compliant website, let us know. You may also view our Fund Website services page to learn more.
This guide summarizes selected website-related requirements and reflects rules and staff guidance as of July 2026. ADI 2025-15 and the tailored shareholder report FAQs represent the views of the staff of the Division of Investment Management; they are not rules or statements of the Commission and carry no legal force. Nothing here is legal advice. Confirm applicable requirements, and any subsequent guidance or rulemaking, with counsel.
