MSBs

Money Transmitter Compliance Calendar: November 2026 to December 2027

By

Harry Khan advises payment, e-money and money transmission firms on licensing and compliance.

Published October 2026 · Last reviewed 27 October 2026 · 7 min read

Key takeaways

  • The NMLS renewal window runs from 1 November to 31 December 2026; updated disclosure questions and employment reporting must be completed first.
  • MSB Call Reports are due 14 November 2026, 14 February 2027, 15 May 2027, 14 August 2027 and 14 November 2027.
  • FinCEN Form 107 renews every two years by 31 December; your year depends on when you first registered.
  • In MTMA states, audited accounts are due within 90 days of year end: 31 March 2027 for a 31 December year end.
  • Event-driven deadlines run from 1 business day (bankruptcy) to 180 days (FinCEN re-registration).

This calendar lists every recurring compliance date for a US money transmitter from November 2026 to December 2027, federal and state, with the rule behind each. The busiest stretch is 1 November to 31 December 2026, when the NMLS renewal window, the third quarter MSB Call Report and, for some firms, FinCEN registration renewal all fall due.

State dates below follow the most common rules: call reports 45 days after quarter end, renewals between 1 November and 31 December, and audited accounts within 90 days of the financial year end in states that have adopted the Money Transmission Modernization Act (MTMA). Some states set their own dates, so confirm each state in your footprint. For what each obligation involves, see our guide to money transmitter compliance requirements.

November 2026 to December 2027

DateObligationApplies toSource
1 November 2026NMLS renewal window opens. Complete the updated disclosure questions and employment reporting first: NMLS will not accept a renewal request until they are doneEvery licenseeCSBS
14 November 2026Third quarter 2026 MSB Call ReportLicensees in states that use the reportGeorgia DBF
31 December 2026NMLS renewal deadline. Unrenewed licences expireEvery licenseeNMLS
31 December 2026FinCEN Form 107 renewalMSBs whose two-year registration period ends in 2026FinCEN
1 January 2027Agent list revised for the previous 12 monthsMSBs with agents31 C.F.R. 1022.380
January to February 2027Reinstatement of expired licences, only in states that allow it, usually with extra feesLicensees that missed 31 DecemberNMLS
18 January 2027GENIUS Act and the OCC's final rule take effectFirms issuing or offering payment stablecoinsGENIUS Act guide
14 February 2027Fourth quarter 2026 MSB Call Report, with annual destination country data for firms sending money abroadLicensees in states that use the reportGeorgia DBF
31 March 2027Annual report and audited accounts for a 31 December year endLicensees in MTMA statesMTMA 7.02
15 May 2027First quarter 2027 MSB Call ReportLicensees in states that use the reportGeorgia DBF
14 August 2027Second quarter 2027 MSB Call ReportLicensees in states that use the reportGeorgia DBF
1 November 2027NMLS renewal window opensEvery licenseeNMLS
14 November 2027Third quarter 2027 MSB Call ReportLicensees in states that use the reportGeorgia DBF
31 December 2027NMLS renewal deadlineEvery licenseeNMLS
31 December 2027FinCEN Form 107 renewalMSBs whose two-year registration period ends in 2027FinCEN

Your FinCEN renewal year depends on when you first registered. The calendar year of initial registration counts as the first year of a two-year period, so a firm registered in 2025 renews by 31 December 2026, and a firm registered in 2026 renews by 31 December 2027.

Deadlines triggered by events

These have no fixed date. They start when something happens in the business.

EventDeadlineRule
Suspicious transaction of USD 2,000 or more detectedSuspicious activity report within 30 days of initial detection31 C.F.R. 1022.320
Cash in or out of more than USD 10,000 in one business dayCurrency transaction report within 15 days31 C.F.R. 1022.310
More than 10% of voting power or equity transferred, or agents up by more than 50%Re-register with FinCEN within 180 daysFinCEN
Proposed change of control (25% presumed control in MTMA states)Prior written approval before the changeMTMA 6.01
New key individual appointedNotice within 15 daysMTMA 6.02
Bankruptcy filing or licence action in another stateReport within one business dayMTMA 7.04
Felony charge or conviction of the licensee or a key personReport within three business daysMTMA 7.04
Transaction volume in a state risesCheck the bond formula; file a rider if the required amount has increasedMTMA 10.02

Work to schedule across the year

Some obligations carry no fixed date in the rules but are tested in every examination. Firms that schedule them avoid the year-end crush.

WorkSuggested timingWhy
Independent AML reviewFieldwork in the second or third quarter; findings closed by OctoberRenewal attestations in November should rest on a clean review
Risk assessment refreshYearly, and whenever a product, corridor or customer type is addedFinCEN's 2026 proposal would make prompt updates a written requirement
Training for staff and agentsYearly, plus new joiners on arrivalTraining records are requested in every examination
Bond and net worth check against volumesEach quarter, with the call reportBoth move with the business
Permissible investments reconciliationDaily, evidenced monthlyThe requirement applies at all times, not only at quarter end
Sanctions list updatesContinuousOFAC lists change without notice

An independent AML review and licence maintenance can be booked against these dates so that each piece of work lands before the deadline that depends on it. Our MSB Call Report guide and NMLS renewal checklist cover the two biggest filings in detail.

Frequently asked questions

31 December 2026. The window opens on 1 November 2026 in most states. Licensees must first complete the updated NMLS disclosure questions and employment reporting, or NMLS will not accept the renewal request.

45 days after each quarter end: 14 February 2027 for the fourth quarter of 2026, 15 May 2027 for the first quarter, 14 August 2027 for the second quarter and 14 November 2027 for the third quarter.

By 31 December of the second year of your two-year registration period. The year of initial registration counts as year one, so a business registered in 2025 renews by 31 December 2026.

In states that follow the MTMA, within 90 days of the financial year end, which is 31 March for a 31 December year end. Other states set their own deadlines, so check each state where you hold a licence.

No. Frequency must match the firm's risk. Scheduling the review in the second or third quarter, with findings closed by October, means renewal attestations rest on a current review.

It expires and the firm loses its authority to transmit money in that state. Some states allow reinstatement in January and February with extra fees; others require a new application.

References

About Regulatory Counsel

Regulatory Counsel runs the yearly compliance cycle for licensed money transmitters and payment firms: BSA programme support, independent AML testing and licence maintenance across the full state footprint, from offices in New York and London. Every enquiry is answered the same business day with a written proposal: contact us.

This article is general information as at 27 October 2026 and is not legal advice.

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