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
| Date | Obligation | Applies to | Source |
|---|---|---|---|
| 1 November 2026 | NMLS renewal window opens. Complete the updated disclosure questions and employment reporting first: NMLS will not accept a renewal request until they are done | Every licensee | CSBS |
| 14 November 2026 | Third quarter 2026 MSB Call Report | Licensees in states that use the report | Georgia DBF |
| 31 December 2026 | NMLS renewal deadline. Unrenewed licences expire | Every licensee | NMLS |
| 31 December 2026 | FinCEN Form 107 renewal | MSBs whose two-year registration period ends in 2026 | FinCEN |
| 1 January 2027 | Agent list revised for the previous 12 months | MSBs with agents | 31 C.F.R. 1022.380 |
| January to February 2027 | Reinstatement of expired licences, only in states that allow it, usually with extra fees | Licensees that missed 31 December | NMLS |
| 18 January 2027 | GENIUS Act and the OCC's final rule take effect | Firms issuing or offering payment stablecoins | GENIUS Act guide |
| 14 February 2027 | Fourth quarter 2026 MSB Call Report, with annual destination country data for firms sending money abroad | Licensees in states that use the report | Georgia DBF |
| 31 March 2027 | Annual report and audited accounts for a 31 December year end | Licensees in MTMA states | MTMA 7.02 |
| 15 May 2027 | First quarter 2027 MSB Call Report | Licensees in states that use the report | Georgia DBF |
| 14 August 2027 | Second quarter 2027 MSB Call Report | Licensees in states that use the report | Georgia DBF |
| 1 November 2027 | NMLS renewal window opens | Every licensee | NMLS |
| 14 November 2027 | Third quarter 2027 MSB Call Report | Licensees in states that use the report | Georgia DBF |
| 31 December 2027 | NMLS renewal deadline | Every licensee | NMLS |
| 31 December 2027 | FinCEN Form 107 renewal | MSBs whose two-year registration period ends in 2027 | FinCEN |
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.
| Event | Deadline | Rule |
|---|---|---|
| Suspicious transaction of USD 2,000 or more detected | Suspicious activity report within 30 days of initial detection | 31 C.F.R. 1022.320 |
| Cash in or out of more than USD 10,000 in one business day | Currency transaction report within 15 days | 31 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 days | FinCEN |
| Proposed change of control (25% presumed control in MTMA states) | Prior written approval before the change | MTMA 6.01 |
| New key individual appointed | Notice within 15 days | MTMA 6.02 |
| Bankruptcy filing or licence action in another state | Report within one business day | MTMA 7.04 |
| Felony charge or conviction of the licensee or a key person | Report within three business days | MTMA 7.04 |
| Transaction volume in a state rises | Check the bond formula; file a rider if the required amount has increased | MTMA 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.
| Work | Suggested timing | Why |
|---|---|---|
| Independent AML review | Fieldwork in the second or third quarter; findings closed by October | Renewal attestations in November should rest on a clean review |
| Risk assessment refresh | Yearly, and whenever a product, corridor or customer type is added | FinCEN's 2026 proposal would make prompt updates a written requirement |
| Training for staff and agents | Yearly, plus new joiners on arrival | Training records are requested in every examination |
| Bond and net worth check against volumes | Each quarter, with the call report | Both move with the business |
| Permissible investments reconciliation | Daily, evidenced monthly | The requirement applies at all times, not only at quarter end |
| Sanctions list updates | Continuous | OFAC 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
- CSBS: plan ahead for NMLS annual renewal, 21 October 2026
- Georgia Department of Banking and Finance: MSB Call Report due dates
- FinCEN: money services business registration
- 31 C.F.R. 1022.380: registration of money services businesses
- 31 C.F.R. 1022.320: reports of suspicious transactions by money services businesses
- CSBS Money Transmission Modernization Act
- FinCEN proposed rule on AML/CFT programmes, 10 April 2026
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.
Definitive guides on this topic
The permanent reference pages this article relates to.