Fingerprints

Last Updated: 8/7/2026

FBI Fingerprint Reuse Policy – No Action at This Time
Recently, the FBI notified FINRA that it continues to work on guidance to organizations related to its updated Fingerprint Reuse Policy, that was published in its January 2026 Outsourcing News newsletter, distributed to Authorized Recipients and available here for reference.  

No Changes to Current Procedures at This Time
Firms must continue following existing FINRA Fingerprint Program requirements. Only fingerprints collected and submitted through the FINRA Fingerprint Program to satisfy the requirements under 15 USC 78q(f)(2) are acceptable.

For Firms Using Electronic Fingerprint Service (EFS) Providers
EFS providers have been instructed to maintain current FINRA Fingerprint Program procedures until further notice. EFS providers are not authorized to store fingerprints on behalf of firms or repurpose fingerprints originally captured for other statutory purposes for use in the FINRA Fingerprint Program. No action on reuse is to be taken at this time.

Next Steps
Earlier in 2026, FINRA submitted questions about the new policy to the FBI and is awaiting guidance, including details on the Authorized Recipient approval process required for fingerprint reuse. The FBI is working on responses to questions it received from FINRA and other organizations as well as information on policy implementation.

Please continue to monitor this page for updates.

Until additional information is available, please visit FINRA.org for the latest information.

Questions?
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