Do I need to post Form CRS on my website?

The posting duty sits in Rule 204-5(b)(3): you must "post the current Form CRS prominently on your website, if you have one, in a location and format that is easily accessible for retail investors." General Instruction 10.A of the Form CRS instructions says the same thing for your "public website". There is no exemption for small firms. A one-person SEC-registered adviser with a single retail client and a two-page website is covered.

Who needs Form CRS in the first place?

Rule 204-5(a) applies to advisers "registered under the Act", meaning SEC-registered firms. The obligation runs to each retail investor, defined in Rule 204-5(d)(2) as "a natural person, or the legal representative of such natural person, who seeks to receive or receives services primarily for personal, family or household purposes." The definition has no wealth or asset test, so a wealthy individual client still counts. The SEC staff FAQ reads "legal representative" narrowly, to cover non-professional representatives such as an individual trustee, executor or someone holding a power of attorney.

If you have no retail investors (for example, you advise only institutions or a pooled fund), the instructions say you are not required to prepare or file a relationship summary.

State-registered advisers are not subject to SEC Rule 204-5. A small number of states have adopted their own relationship summary requirement, so a state-registered firm should check its state securities regulator's rules rather than assume it is exempt. A firm moving from state to SEC registration files Form CRS with its SEC application.

What does "prominently" and "easily accessible" mean in practice?

The rule does not prescribe a page or a label. The SEC staff have said the posting duty also reaches "doing business as" websites through which the firm's services are offered (FAQ posted 8 December 2023), which tells you the staff read the requirement broadly. A practical set-up for a small firm:

• Label it plainly. Use "Form CRS (Relationship Summary)" or "Form CRS" as the link text. Avoid burying it under a generic "Legal" or "Documents" heading only.
• Put it in the site footer so it appears on every page, and also list it on your disclosures or "Important information" page alongside Form ADV Part 2A and your privacy notice.
• Link straight to the document. One click from the footer should open the current PDF, not a page that asks the visitor to search.
• Keep a stable URL (for example /form-crs.pdf) and replace the file when you amend, so old links in emails and profiles still open the current version.
• Check the DBA sites. If you market under a trade name on a separate domain, post it there too.

The free website check looks for a Form CRS link on the pages it reads. It can only read up to eight pages, so a missing finding is a prompt to look, not proof of a gap.

When must you deliver it, apart from the website?

When you deliver an amended summary to existing clients, Instruction 8.C asks you to highlight the changes, for example with marked text or a summary of material changes attached as an exhibit. The 60-day communication can travel with another disclosure you were sending anyway, and the staff FAQ gives a cover sheet on an account statement as an example. If you deliver on paper as part of a package, Form CRS must be the first document (Instruction 10.D).

How is it filed?

An adviser files Form CRS as Form ADV Part 3 through IARD. Instruction 7.A(i) requires "a text-searchable format with machine-readable headings". The staff FAQ explains this in terms of a PDF whose required headings appear as bookmarks. Each filed amendment must include the exhibit highlighting the changes. The summary itself must begin with its date (Item 1) and point readers to Investor.gov/CRS.

What records should you keep?

Rule 204-2(a)(14)(i) requires a copy of each Form CRS and each amendment, plus "a record of the dates" each version was given to any client or to a prospective client who became a client. For a one-person firm that means:

1. Every version of the PDF, named with its date, never overwritten in your archive.
2. The IARD filing confirmation for each version.
3. A delivery log: client, version, date, method (email, portal, paper).
4. A note of when the website file was replaced, with a screenshot of the footer link.

Plumb's compliance calendar carries a standing Form CRS reminder for the 30-day amendment window, and the evidence log can hold the dated screenshot. The same retention logic for your marketing pages is covered in books and records for marketing.

This page is general information about the federal rule, not legal advice. Your facts, and any state rules that apply to you, may change the answer.