EDGAR Next Implements Significant System Updates

EDGAR, which facilitates filing submissions under federal securities laws, will be undergoing significant updates to enhance its security. The legacy EDGAR system has historically assigned each EDGAR filer a set of access codes to be used by different individuals to make submissions on the filer’s behalf and did not employ multifactor authentication. Among the key changes in security processes for EDGAR Next are:

• requiring individual account credentials;
• employing multifactor authentication; and
• requiring filers to authorize individuals to manage their EDGAR accounts.

EDGAR Next will also implement optional Application Programming Interfaces (APIs) intended to enhance efficiency and speed by allowing filers to make submissions, retrieve data and facilitate account management on a machine-to-machine basis.

Please take note of the following key dates to assist you in a seamless transition from EDGAR to EDGAR Next:

The following summarizes the upcoming changes to EDGAR and includes practical steps and recommendations to minimize the challenges of transition to the new EDGAR Next.

What Is Changing?

• Amended Form ID. Form ID is an online form that individuals and entities must complete in order to receive access to file electronically on EDGAR. Among other things, Form ID requires information about the identity and contact information of the applicant. As noted above, to be able to submit filings on EDGAR or take other actions with respect to an EDGAR account, an amended Form ID must be submitted after December 19, 2025, by filers that have not previously enrolled in EDGAR Next. Amended Form ID will require additional information, including:

- the designation of at least two individuals to act as the filer’s EDGAR account administrators (individuals and single-member companies^[1]will only be required to designate one individual, though it is advisable to designate at least two account administrators);

A. If an account administrator is not the applicant (in the case of an individual applicant) or an employee of the applicant (in the case of a company applicant), a notarized power of attorney authorizing the individual as account administrator is required.

- the applicant’s Legal Entity Identifier (LEI) number, if any^[2]; and

- a requirement to provide more specific contact information about the filer, including the filer’s account administrator(s), authorized individual and billing contact.

Additionally, amended Form ID will alert applicants that, by default, the first account administrator listed on the submitted Form ID will be designated as the filer’s EDGAR point of contact.

• More Secure Account Management
• Secure Account Management. The new EDGAR rules require that each filer must complete amended Form ID, as described above, to authorize account administrators who will be responsible for a variety of functions, including managing the security and accuracy of the filer’s account, confirming on an annual basis that all individuals and entities are properly authorized by the filer to act on its behalf and that the filer’s information is accurate, and serving as the filer’s point of contact for the SEC staff.
• Individual Account Credentials. The new EDGAR rules require individuals acting on behalf of filers to obtain individual account credentials from Login.gov and complete multifactor authentication to access the filer’s EDGAR account.
• Ability to File on EDGAR

- A filer may only authorize individuals who have obtained individual account credentials to act on its behalf on EDGAR.

- An existing filer must submit a new Form ID if it (i) has lost access to its existing Central Index Key (CIK) account, or (ii) is the legal successor of the filer named on the existing CIK account but did not receive access from that filer.

Recommended Steps to Ensure Compliance

• Start preparing now. Although the compliance deadline is a few months away, implementing the changes for EDGAR Next will likely be a time intensive process. Developing processes early will help ensure a smooth transition before the compliance deadlines. We recommend participating in the EDGAR Next beta software environment that is available until December 19, 2025, and taking advantage of SEC resources, including instructional videos and kickoff webinars.
• Obtain Login.gov account credentials now. All individuals who will be making submissions on behalf of a filer or its Section 16 officers and directors should obtain Login.gov account credentials early. Individual account credentials will be required for beta testing, enrollment and compliance.
• Determine whom to designate as account administrator(s). Remember that the account administrator(s) are responsible for the general security and account administration, including completing the annual confirmation.
• Update EDGAR processes. The amendments may require filers to implement new processes or consider updates to existing processes. For example, administrators must specifically approve individuals or filing agents (i.e., financial printers, outside law firms, financial institutions and broker-dealers) to submit filings on their behalf. Further, the relationship between filers and filings agents will need to be reconsidered. EDGAR Next eliminates the ability to allow a filing agent, such as an outside law firm, to make filings by sharing the filer’s EDGAR login credentials. Under EDGAR Next, account administrators will need to take certain actions to delegate and accept authority to make filings. Such actions include (i) inviting users and additional account administrators, (ii) if connecting to the optional API, authorizing at least two technical administrators, and (iii) delegating filing authority to delegated entities, including, but not limited to, filing agents, such as an outside law firm.
• Gather all necessary EDGAR access codes, including CIKs, CIK confirmation codes (CCCs), passphrases and passwords. These access codes will be required to enroll each filer in EDGAR Next, and once enrolled, a new CCC will be generated and displayed on the EDGAR Next dashboard for account administrators. However, note that all legacy EDGAR access codes, including passphrases and passwords, will be deactivated on September 15, 2025.
• Plan for enrollment. Filers should strategically consider when to complete enrollment. Companies should consider enrolling after their 2024 fiscal-year-end reporting cycle is completed, while ensuring that they enroll before the September 15, 2025, compliance deadline.

FAQs

Q: How should Section 16 filers approach enrollment, especially in the case where a Section 16 filer is a director for more than one company?

A: All individuals, such as Section 16 filers, can enroll themselves on EDGAR Next or be enrolled through a third party, such as the Section 16 filer’s company or an outside law firm. In the case where an individual is a Section 16 filer for more than one company, companies should coordinate with the Section 16 filer to ensure the individual is only enrolled once, and to determine who will serve as the account administrator for the Section 16 filer. This coordination is critical to avoid confusion and multiple attempts at enrollment as each filer can only enroll once. Once enrolled, the Section 16 filer’s single account can be linked to multiple issuers, allowing the filer to submit Section 16 filings for each company. Unlike the requirements for Form ID, as described above, a notarized power of attorney is not required to authorize a third party, such as the Section 16 filer’s company or an outside law firm, to enroll the Section 16 filer. In the case where an employee of the Section 16 filer’s company or a member of an outside law firm is enrolling a Section 16 filer in EDGAR Next, this individual must have their own Login.gov individual account credentials. The person authorized to enroll the Section 16 filer will log into the EDGAR dashboard using their individual Login.gov account credentials and follow the instructions to complete enrollment. The person completing enrollment will need the Section 16 filer’s CIK, current passphrase and CCC to complete enrollment. Once the Section 16 filer is enrolled in EDGAR Next, the account administrator will be able to authorize representatives of different companies to be users or account administrators. Please refer to the SEC’s guidance relating to Section 16 filers for additional detail.

Q: How does enrollment work?

A: Enrollment opened on March 24, 2025, and entails a streamlined process allowing current EDGAR filers to transition to EDGAR Next without completing the amended Form ID until December 19, 2025. Enrollment will be completed through the EDGAR Filer Management dashboard. The following information will be required for enrollment: CIK, CCC, passphrase, contact information for each account administrator and confirmation of the date by which the filer will perform the annual confirmation on EDGAR (either March 31, June 30, September 30 or December 31). Unlike the requirements for Form ID, as described above, a notarized power of attorney is not required. Enrollment requests may be processed and effective as soon as the same day they are submitted. Note that the filer’s CCC will automatically be reset upon enrollment. Beginning December 22, 2025, even current EDGAR filers will be required to complete amended Form ID to enroll in EDGAR Next.

Q: When is the enrollment deadline for filers?

A: Enrollment opened on March 24, 2025, and will continue until September 12, 2025, with no consequence to the filer’s current filing ability. From September 15, 2025, to December 19, 2025, filers may still participate in enrollment; however, they will not be able to file or access their EDGAR accounts until they have completed enrollment. Beginning December 22, 2025, filers may only enroll in EDGAR Next by applying for access on amended Form ID and awaiting the outcome of SEC Staff review. The SEC Staff has advised they currently require at least four business days to review an amended Form ID once submitted. As a result, current filers are strongly encouraged to utilize the open enrollment process prior to September 12, 2025.

Q: How does this affect filers who typically utilize a filing agent (i.e., financial printers, outside law firms, financial institutions, broker-dealers and other filings agents) to make filings?

A: The relationship and scope of the filing agent’s ability to assist filers to make filings will necessarily change with the implementation of EDGAR Next, and we expect that filing agents may adopt their own policies and procedures with respect to the same. For example, prior to EDGAR Next, an outside law firm was able to make filings on Forms 3, 4 and 5 on behalf of a Section 16 officer by utilizing the Section 16 officer’s access credentials during the filing process. With EDGAR Next, an outside law firm may still assist in enrolling a new Section 16 officer or making filings under the new system; however, this will require additional processes and time. Specifically, filing agents must have an EDGAR Next account and comply with the same requirements applicable to all filers.

For an outside law firm to assist a Section 16 officer with submitting a Form ID, the Section 16 officer must authorize an individual at the outside law firm to act on his or her behalf as an account administrator by executing a notarized power of attorney. The authorized individual must also have a personal Login.gov account in order to access EDGAR Next and submit the Form ID. The Section 16 officer will be required to designate at least one account administrator on the Form ID, who will have the ability to manage the filer’s EDGAR Next profile, submit filings on the filer’s behalf and delegate filing authority to other EDGAR accounts. The Section 16 officer may designate an outside law firm as its account administrator, or alternatively, may have an account administrator of their choosing delegate filing authority to the outside law firm. In the latter case, the account administrator for the outside law firm’s EDGAR Next account will then need to accept the delegation and authorize one or more of its users to make filings on behalf of the Section 16 officer.

Q: What if a company wants to assume management of its Section 16 officers’ filing obligations?

A: If the Section 16 officer has an existing EDGAR account, the Section 16 officer may choose to either enroll in EDGAR Next directly or authorize the company to complete the Section 16 officer’s enrollment in EDGAR Next.

If the Section 16 officer manages an EDGAR Next account personally as the account administrator, the Section 16 officer will need to delegate authority to the company to make filings on the Section 16 officer’s behalf as a delegated entity. An account administrator of the company will need to accept the delegation on the EDGAR Next dashboard or through an email invitation. Once the company is a delegated entity, all of its account administrators will automatically become delegated administrators for the Section 16 officer.

If the Section 16 officer chooses to authorize the company to complete the Section 16 officer’s enrollment in EDGAR Next, the company should authorize one or more individuals at the company to act as the Section 16 officer’s account administrator(s), and if applicable, other authorized users.

If the Section 16 officer does not already have an EDGAR account, the Section 16 officer will need to submit an amended Form ID to create an account. The Section 16 officer may authorize another individual to complete the enrollment; however, this individual will need a personal Login.gov account.

Q: What if an individual or filer doesn’t have an EDGAR account as of March 24, 2025? How do they enroll in EDGAR Next?

A: Starting March 24, 2025, all new filers must enroll in EDGAR Next by completing the amended Form ID, which includes obtaining individual login credentials on Login.gov, identifying an account administrator and providing notarized documents, including a notarized power of attorney, as applicable.

Q: Where can filers find more information and guidance?

A: The SEC’s EDGAR Next website provides detailed information regarding enrollment, including commonly asked questions and answers, step by step instructions, webinars and other guidelines. Filers may also seek assistance by emailing EDGARNext@sec.gov or calling 202-551-8900, option #2.

^{[1] A “single-member company” is a company that has a single individual who acts as the sole equity holder, director and officer (or, if the entity does not have directors and officers, such individual holds position(s) performing similar activities as a director and officer).}

^{[2] An LEI is a 20-character alphanumeric code that identifies legal entities participating in financial transactions. An LEI for a specific legal entity may be found on by searching on the following webpage: https://search.gleif.org/#/search/. Companies that have an LEI should provide it on amended Form ID. If, however, a company does not have an LEI, it is not required to obtain one.}