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In September 2024, the U.S. Securities and Exchange Commission (SEC) adopted changes to its Electronic Data Gathering and Retrieval (EDGAR) system. Rolling out during 2025, the new system is known as “EDGAR Next”. EDGAR Next will replace the current EDGAR system and aims to improve security (including via two-factor authentication of authorized users), modernize connections to EDGAR, and enhance filers’ ability to manage their accounts.
The time for SEC filers to prepare for EDGAR Next is now. The timetable for EDGAR Next implementation is as follows:
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Starting now: filers who wish to do so can now begin preparing for enrollment on EDGAR Next (see more on enrollment below). An optional beta environment is currently available for testing.
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March 24, 2025: actual EDGAR Next enrollment begins and a new EDGAR Next Dashboard goes live.
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September 15, 2025: filers must comply with EDGAR Next enrollment by September 15, 2025.
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September 15-December 19, 2025: filers can continue to enroll between September 15, 2025 and December 19, 2025, but they will not be able to file during that time period until they enroll.
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After December 19, 2025: filers will be unable to enroll, and filers that have not enrolled will be unable to file on EDGAR or otherwise access their EDGAR accounts until they submit a Form ID application for access that is granted by SEC staff.
As part of EDGAR Next, the SEC has adopted an updated Form ID (the form filed with the SEC to get EDGAR codes). Note that filers whose Form ID applications for EDGAR access are submitted and granted by SEC staff on or after March 24, 2025 are immediately subject to the requirements of EDGAR Next and do not need to enroll.
Key EDGAR Next Enrollment and Other Facts
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All current entity and individual EDGAR filers will be required to enroll in EDGAR Next, whether or not they are using a filing agent or other third-party service provider (such as a financial printer) to file. To enroll in EDGAR Next, certain information must be presented to SEC staff on the dashboard of the EDGAR Filer Management website.
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The new system will require each public company filer to authorize and maintain at least two individuals with individual account credentials as account administrators to manage the filer’s EDGAR account. These should be senior executive officers (CEO and CFO) or their direct reports (e.g., Controller, V.P. of Finance, etc.).
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Each filer may only enroll once, and only one individual can enroll each filer. A filer may select anyone it trusts to enroll it in Edgar Next, including but not limited to an employee of the filer, the filer’s filing agent or law firm. Therefore, each filer should coordinate carefully with all entities and individuals that may currently be filing on its behalf as soon as possible to determine which entity or individual the filer will authorize to enroll it and so that others do not attempt to enroll the filer without authorization. Keep in mind that the person or entity that is responsible for the enrollment will have sensitive information about the filer’s account.
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Enrollment will be a streamlined process that allows current EDGAR filers to transition to EDGAR Next without completing a Form ID, notarizing documents, or presenting a power of attorney to SEC staff. We therefore strongly recommend early enrollment in EDGAR Next.
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Many EDGAR filers use a financial printer or other service provider to submit EDGAR filings. A filer should coordinate with its filing agents and third-party service providers prior to enrolling in EDGAR Next to determine whether they will provide enrollment services to the filer and which entity or individual the filer will authorize to enroll it.
- Enrollment requests will typically be processed and effective the same day they are submitted, and enrolled filers may access the optional EDGAR Application Programing Interfaces.
SEC Webinar and Additional Resources
The SEC’s EDGAR Business Office is hosting a webinar focused on EDGAR Next for Section 16 filers on Thursday, January 23, 2025 from 1:00 to 2:30 pm Eastern time. You must register in advance for this webinar at https://secgov.webex.com/weblink/register/r1ef283c1c17ca43e9140d0e80967c3ff.
Additional information with respect to EDGAR Next is available from the SEC at https://www.sec.gov/newsroom/whats-new/sec-adopts-edgar-next and at https://www.sec.gov/submit-filings/improving-edgar/edgar-next-improving-filer-access-account-management.
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We look forward to assisting our clients in this important endeavor. If you have questions or would like additional information, please contact your primary EGS attorney with whom you work.
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