LawFlash

EDGAR Next: SEC Announces Updated EDGAR Filer Management Platform

26. November 2024

The US Securities and Exchange Commission (SEC) will launch an updated version of its Electronic Data Gathering, Analysis, and Retrieval (EDGAR) Filer Management platform (EDGAR Next) on March 24, 2025. EDGAR Next is meant to improve the security of EDGAR, enhance filers’ ability to manage their EDGAR accounts, and modernize connections to EDGAR. Beginning September 15, 2025, filers must be enrolled in the new platform to submit their filings.

BACKGROUND

On September 27, 2024, the SEC adopted the final rule and form amendments to implement EDGAR Next. As part of the rollout of EDGAR Next, the SEC recently provided information on the key changes, enrollment process, and general timeline for the transition to the new platform via its EDGAR Next website and pending updates to volume one of the EDGAR Filer Manual.

KEY CHANGES

Each person authorized to manage filers’ EDGAR accounts or to make filings will need to obtain Login.gov credentials to enroll in the new EDGAR Next platform. Login.gov is a secure sign-in service provided by the US General Services Administration. Login.gov credentials may be obtained by visiting the sign-in page, clicking on “Sign in with Login.gov,” and responding to the prompts from the website, including establishing a form of multifactor authentication.

Each filer will also need to designate EDGAR Next account administrators via the EDGAR Next platform. Account administrators have the power to delegate filing authority to others, including filing agents; generate custom central index confirmation codes (CCCs); perform the newly required annual confirmation of account information; and create and edit groups of up to 500 users. To make a filing on behalf of a filer, an individual will need to be an authorized user for the filer, sign into EDGAR Next with their own Login.gov credentials, and enter the filer’s central index key (CIK) and CCC. This is a major change from the current requirements to make a filing, which are simply to have the filer’s CIK and CCC.

Starting on March 24, 2025, any natural person or entity that does not already have EDGAR codes must obtain their EDGAR codes via the newly amended Form ID application process. The amended Form ID will be modernized to make the form more user-friendly but will still be individually reviewed by the SEC staff. Filers will submit the amended Form ID through the EDGAR Next dashboard. As with the current Form ID, prospective filers will need to submit a notarized copy of the amended Form ID as part of their application for EDGAR codes.

Additionally, when completing the amended Form ID, a prospective filer’s identification of its account administrators will constitute their authorization of those individuals as account administrators, except that a scanned hard copy of a notarized power of attorney will be required when an individual seeks to authorize another individual—or a company seeks to authorize an individual not employed by it or its affiliates—as account administrator. Filers will be able to delegate filing authority to another EDGAR account through the EDGAR Next dashboard or through an optional delegation API (as described below). The filer’s account administrator delegates authority by entering the prospective delegated entity’s CIK on the EDGAR Next dashboard. The EDGAR Next platform will then send an email invitation and an invitation through the EDGAR Next platform to all account administrators of the prospective delegated entity.

Filers will also be able to delegate filing authority to multiple entities simultaneously, and delegated administrators will be able to accept multiple invitations simultaneously. In the event that the delegated entity makes a submission for a filer without the filer’s authorization, the filer’s account administrators will be able to remove the delegated entity’s filing authority and take corrective actions.

Filers will also have the option to take advantage of Application Programming Interfaces (APIs) to help them enroll into EDGAR Next and submit filings through EDGAR Next. An API is a software interface that allows computers or applications to communicate with each other. The APIs will provide machine-to-machine communication with EDGAR, which will automate the enrollment and filing processes and allow filers to make filings more efficiently.

Once the filer has successfully connected to the “submission API,” for example, that API will transmit a filer-constructed submission to EDGAR and allow filers to rapidly submit large numbers of filings in an automated manner. Filers will no longer need to make filings one at a time. The filer may choose to leverage the “optional delegation API” which will replicate the manual dashboard functionality and allow the filer to delegate more efficiently. The filer will be able to delegate filing authority to multiple CIKs more easily, enable prospective delegated entities to send delegation requests to filers, and allow filers to automatically accept delegations and become delegated entities if they choose.

In order to take advantage of the APIs, filers, through their account administrators, typically must authorize at least two technical administrators. A filer does not need to authorize technical administrators if the filer arranges to use its delegated entity’s API connections, and the delegated entity is in compliance with the requirement to authorize at least two technical administrators. Technical administrators have the power to generate API tokens, which identify and authenticate the individuals taking action on the EDGAR Next platform. API tokens will remain valid for up to one year.

Technical administrators also have the power to manage the technical aspects of a filer’s connection to the APIs. The SEC recommends that each technical administrator have a basic understanding of API processes and be available to communicate with SEC staff and the filer’s developers or other experts.

Enrollment Process for existing filers

Existing filers will not need to submit an amended Form ID; instead, they or their authorized enroller will navigate to the EDGAR Next website once it goes live on March 24, 2025, click on the “Enroll” button, and then submit their current CIK, CCC, and passphrase. The submission of these codes evidences that the person doing the enrolling for the filer is authorized to do so, and filers will not be required to notarize any documents or present any powers of attorney as part of the enrollment process.

Then, the enrolling person will designate the filer’s account administrators. Individuals or single-member companies must authorize and maintain at least one account administrator; all other filers must authorize and maintain at least two account administrators. The filer must provide the name, email address, business address, and business telephone number of each account administrator. Filers can have up to 20 account administrators.

Finally, the filer must select the fiscal quarter in which they want to complete their “annual confirmation.” The “annual confirmation” is a simple process in which the account administrator confirms that the filer’s EDGAR Next account information is accurate and up to date.

Upon enrollment, a notification will be sent via e-mail and through the EDGAR Next dashboard to the current EDGAR point of contact for the filer, as well as all newly authorized account administrators. Additionally, the EDGAR Next platform will automatically generate new CCC codes for each filer. Filers will have the option to change those new CCC codes back to the old codes.

To facilitate organizations with a large number of users, there will also be a “bulk enrollment” feature that allows authorized individuals to enroll up to 100 users at once by uploading a spreadsheet. Once EDGAR Next is live, filers can log into the system, select “Enroll in EDGAR Next” from the dashboard, choose “Bulk Enrollment,” download a template spreadsheet, populate it, and upload it to complete bulk enrollment. Filers, through their account administrators, may also choose to complete the bulk enrollment process via the “enrollment API.” Enrollment of existing filers will end on December 19, 2025; beginning December 22, 2025, existing filers who did not participate in enrollment will need to submit an Amended Form ID.

TIMELINE

The SEC will roll out the EDGAR Next platform according to the following schedule:

  • March 24, 2025: The EDGAR Next platform goes live; EDGAR Next will be available every weekday other than federal holidays from 6:00 am–10:00 pm ET
  • March 24, 2025–September 12, 2025: The SEC will maintain a hybrid model in which both the current EDGAR Filer Management platform and the new EDGAR Next platform will be running simultaneously
  • September 15, 2025: Existing EDGAR codes will be deactivated, and filers may not submit their documents to the SEC until they’ve enrolled in EDGAR Next
  • December 19, 2025: Enrollment of existing filers in EDGAR Next ends
  • December 22, 2025: New filers (as well as current filers who have not already enrolled in EDGAR Next) will need to submit an application on Amended Form ID to access the EDGAR Next platform

NEXT STEPS

EDGAR filers should take the following actions now to stay ahead of the rollout:

  • Make sure that the individuals authorized to manage filings obtain Login.gov credentials, and coordinate with outside filing agents regarding delegation once filers are enrolled in EDGAR Next.
  • Take advantage of the beta software environment that is already open to get familiar with the new dashboard. Login.gov credentials are required for access
  • Maintain a running list of all current CIKs, CCCs, and passphrases to ensure smooth enrollment; if a passphrase cannot be located, begin the process of resetting it promptly, as the process can take time
  • For reporting companies, determine the EDGAR account administrators and which individuals may make submissions on behalf of the company or any of the persons obligated to make reports pursuant to Section 16 of the Securities Exchange Act of 1934 (Section 16) regarding transactions in company equity securities
  • Persons with Section 16 reporting obligations, or otherwise with reporting obligations, at several different companies should ensure that there are authorized users or account administrators at each company, or consider administrative alternatives to ensure that their filings are made in a timely manner
  • Determine which EDGAR account administrator will be responsible for the annual confirmation
  • Ensure that sufficient time is provided for the processing of Amended Form ID for new filers (for example, new directors) or existing filers who have forgotten their codes and missed the window for enrollment

Legal practice assistant George Trapaidze contributed to this LawFlash.

Contacts

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