April 30, 2025 - Alerts and Newsletters

        “EDGAR Next” Goes Live

        On March 24, 2025, the rule and form amendments to EDGAR that were adopted by the Securities and Exchange Commission (“SEC”) on September 27, 2024 became effective and the EDGAR Next dashboard went live. These amendments are intended to improve the security of EDGAR, to make it easier for filers to manage their EDGAR accounts and to modernize connections to EDGAR.

        Enrollment in EDGAR Next

        With limited exceptions, filers who had EDGAR accounts prior to March 24, 2025 (referred to as existing filers) can enroll in EDGAR Next any time between March 24, 2025, and December 19, 2025. Once an existing filer has enrolled, filings for such existing filer can be made through the EDGAR Next dashboard. During the six-month period from March 24, 2025, to September 12, 2025, an existing filer can also continue to make filings under the legacy EDGAR filing process using such existing filer’s CIK, CCC, and password. Starting on September 15, 2025, any existing filer that has not enrolled will not be able to file on EDGAR Next until they enroll. In addition, any existing filer that does not enroll in EDGAR Next on or prior to December 19, 2025, will need to submit a new Form ID to regain access to its EDGAR account.

        To enroll an existing filer on the EDGAR Next dashboard, a person will need to be authorized by the existing filer, will need to have Login.gov individual account credentials, and will need the filer’s current CIK, CCC, and passphrase. The authorized individual’s entry of the existing filer’s CIK, CCC, and passphrase will serve as confirmation that such individual is authorized by the existing filer to complete the enrollment. If any of the existing filer’s EDGAR filing codes are not known or are no longer valid, such codes must be updated prior to enrollment. In addition, the authorized individual will also need the following information to enroll an existing filer: (1) information about the individuals being authorized as account administrators, including each such account administrator’s name, email address of the person’s Login.gov individual account credentials, business address, and business telephone number, and (2) the quarter-end date by which the filer will perform the annual confirmation of information that is required by EDGAR Next. A power of attorney from an existing filer is not needed to enroll the filer in EDGAR Next or to authorize an account administrator in connection with such enrollment. When a filer enrolls on the EDGAR Next dashboard, the filer’s CCC will automatically be updated and will be displayed on the filer’s EDGAR Next dashboard. If enrollment is successful, the account administrators listed during enrollment will receive both an email and a notification on the dashboard that they are the account administrators for the filer. In addition, a filer’s existing EDGAR point of contact will be notified of the successful enrollment.

        Login.gov Credentials

        Any individual who is accessing the EDGAR Next dashboard must be authorized by the filer and must have Login.gov individual account credentials, which credentials will be used to log in to the EDGAR Next dashboard. These Login.gov individual account credentials must be kept confidential and may not be shared with others. A person can have more than one Login.gov account, so if an individual has a personal account, a separate account can be set up using the individual’s work email. A filer is not required to have its own Login.gov individual account credentials unless the filer wishes to access the EDGAR Next dashboard. Based on the Login.gov individual account credentials used to access the EDGAR Next dashboard, the SEC will be able to identify exactly who is accessing the EDGAR Next dashboard, who is making any changes to a filer’s information, and who is making any filing with the SEC on behalf of a filer.

        Authorized Individuals

        Under the legacy EDGAR system, anyone with access to a filer’s EDGAR filing codes (CIK, CCC, and password) could submit filings to the SEC on behalf of such filer. Under EDGAR Next, the CIK and CCC will continue to function as the codes required for filings, but only authorized individuals will be able to submit filings on behalf of a filer or take any other actions on behalf of a filer on the EDGAR Next dashboard.

        A filer’s authorized individuals must include at least two account administrators (except for filers that are individuals or filers that are companies that only have a single individual who is the sole equity holder, director and officer (or holds positions performing similar activities as a director and officer), which filers are only required to have one account administrator), and may include up to 20 account administrators. A filer’s account administrators may also allow other categories of individuals to make filings for the filer, namely “users,” “delegated administrators,” and “delegated users,” as further described below.

        • Users. A filer can have its account administrator designate up to 500 individuals as “users.” Users are authorized to submit filings on behalf of the filer, can view the filer’s CCC and can update certain limited information on the filer’s account (e.g., name, address and State of incorporation).
        • Delegated Entities; Delegated Administrators; Delegated Users. A filer’s account administrator can also authorize other EDGAR account holders (“delegated entities”) to make filings for the filer. Examples include filing agents, issuers, law firms, and broker-dealers, as long as such persons have their own EDGAR account. Each delegated entity will have its own account administrators, and these “delegated administrators” can submit filings on behalf of the filer, view the filer’s CCC, and authorize and manage users at the delegated entity (“delegated users”) to make filings on behalf of the filer.

        If a filer connects to any Application Programming Interfaces (APIs) such filer will be required to designate two technical administrators (and may designate up to 20 technical administrators), unless such filer delegates to a delegated entity that is in compliance with the technical administrator requirements and connects to the APIs using its delegated entity’s filer API tokens and API connections. APIs are software interfaces that allow machine-to-machine communications with EDGAR and provide a more secure connection to the EDGAR system, and technical administrators will be responsible for managing the filer’s connection to the APIs.

        To summarize, filer account administrators are responsible for setting up and managing a filer’s account on the EDGAR Next dashboard. In addition, account administrators can also submit filings on behalf of the filer, generate or create custom CCC filing codes for the filer, add and remove other account administrators, add and remove users and technical administrators, and delegate or remove authority to file to other EDGAR accounts (which are referred to as delegated entities). An account administrator’s addition of other account administrators, users, and technical administrators, or delegation of authority to a delegated entity, will be effective once accepted by the applicable individual or delegated entity.

        Each filer, through its account administrators, is required to maintain accurate and current information on EDGAR concerning the filer’s account and confirm annually on EDGAR that all account administrators, users, technical administrators, and/or delegated entities reflected on the EDGAR Next dashboard for its EDGAR account are authorized by the filer to act on its behalf, and that all information about the filer on the dashboard is accurate. The filer can elect the calendar quarter in which such annual confirmation must be made (which calendar quarter can thereafter be changed). If a filer’s account administrators fail to timely perform the annual confirmation, filers will maintain their EDGAR access through a three-month grace period and will receive daily notifications reminding them to satisfy their annual confirmation requirement. If no account administrator performs the annual confirmation by the end of the three-month grace period, EDGAR will deactivate the filer’s access, and the filer will be required to submit a new Form ID application to request access to file on its account.

        Amended Form ID

        The Form ID (i.e., the application for EDGAR access) is being amended, and use of the amended Form ID began on March 24, 2025. Any existing filer who does not enroll in EDGAR Next on or prior to December 19, 2025, will need to submit a new Form ID to regain access to its EDGAR account. In addition, new filers seeking access to EDGAR Next for the first time, as well as existing filers (1) who lost electronic access to their existing EDGAR account, (2) who are a legal successor of the filer named on the existing EDGAR account but did not receive access from that filer, or (3) who are a broker-dealer or “paper filer” seeking electronic access for the first time in order to file electronically on an existing EDGAR account in their name, will all need to apply for EDGAR access on amended Form ID. If the amended Form ID application is approved, the filer will be in compliance with EDGAR Next and will not need to follow the enrollment procedure for existing filers.

        The amended Form ID requires a filer to identify its account administrators. Notarized powers of attorney may be needed in certain cases, including if a filer is authorizing an account administrator who is not the individual applicant or employed by the filer or its affiliates. Amended Form ID also requires additional information about the filer and its authorized individuals, including information about violations of securities laws, so processing may take additional time.

        Next Steps

        After enrolling or filing an amended Form ID, a filer should determine if it wants its account administrators to designate any additional account administrators, any users or any delegated entities, and whether it will need its account administrators to designate any technical administrators. Any filer planning to make its own filings in-house should also communicate with its software provider regarding the use of APIs and API tokens and any updates that may need to be made to such filer’s software. In addition, any filer that is an issuer whose directors and officers make filings with the SEC should notify its directors and officers about the need to enroll in EDGAR Next.

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