EDGAR Next: Preparing For The SEC's Filing System Transition

In 2024, the SEC adopted amendments to the rules and forms related to its EDGAR filing system that will impact the way all filers access and manage their EDGAR accounts and make electronic filings with the SEC.¹ These changes—referred to as "EDGAR Next"—are intended to improve the security of and modernize EDGAR and will affect all filers who submit filings electronically on EDGAR. As part of the transition to EDGAR Next, filers will have to enroll and designate individuals who will be responsible for managing their EDGAR accounts, and the SEC will phase out filers' ability to use shared EDGAR access codes to make filings.

Starting on March 24, 2025, existing filers will be able to begin enrolling in EDGAR Next through the new EDGAR Filer Management dashboard, and prospective new filers will be required to electronically submit an amended Form ID on the dashboard to apply for EDGAR access. In order to avoid interruption in the ability to file, existing filers will need to enroll in EDGAR Next no later than Sept. 12, 2025.

There is no downside to enrolling early in EDGAR Next, and we encourage you to take advantage of the enrollment period (March 24, 2025 to Sept. 12, 2025) to enroll each of your entities/individuals who may make EDGAR filings. During the enrollment period, filers will continue to be able to submit filings using the current password-based access system and the same processes used prior to EDGAR Next.

What to Expect with EDGAR Next:

• New Filer Management Dashboard
  • The SEC is launching a new dashboard on the EDGAR Filer Management website to allow filers to manage their accounts and to make filings on March 24, 2025
  • The dashboard will be used to enroll current filers, apply for EDGAR access, authorize individuals to manage a filer's account or submit filings on behalf of a filer, view EDGAR codes, connect EDGAR application programming interfaces ("APIs"), and to submit required annual confirmations for an EDGAR filer
• Requirement for Individual Account Credentials
  • Historically, filers accessed EDGAR using a CIK and a single set of shared access credentials (such as a password, CCC, PMAC, and passphrase), and anyone with access to these credentials was able to make filings and manage the filer's EDGAR account
  • Under EDGAR Next, persons accessing EDGAR to make filings, manage EDGAR accounts or view the new dashboard will be required to use their own individual Login.gov account credentials² (and complete a multifactor authentication) and must first be authorized/designated to act on behalf of each filer
  • The public EDGAR site to view filings will still be accessible without credentials
• Designation of Account Administrators and Other Roles
  • Each filer will generally be required to designate at least two individuals as "account administrators" to manage its EDGAR account using the dashboard³
  • Account administrators can add individuals to specific roles (i.e. additional account administrators, "users" that can make filings and "technical administrators" to connect to EDGAR APIs) for each filer
  • Account administrators can delegate the authority to make filings on the filer's behalf to third parties, such as law firms, broker-dealers, printers or other filing agents
  • Each administrator or other user will need individual Login.gov account credentials
• Delegation of Filing Authority
  • In order for third parties, including law firms, broker-dealers, printers and other filing agents, to make filings on behalf of a filer, an account administrator must first delegate filing authority to such third party's EDGAR account by using the dashboard
    • Delegated entities will be able to make EDGAR submissions on the filer's behalf but will not otherwise have access to the filer's dashboard
  • Filers should contact each of their filing agents to obtain delegation instructions; it's possible that multiple delegations may be necessary (for example, if your law firm sometimes uses an outside printer, you may need to authorize both the law firm and the printer)
    • Click here for instructions to delegate filing authority to Schulte Roth & Zabel
  • Compliance by September 15 is Mandatory
    • Starting Sept. 15, 2025, filers will no longer be able to submit filings using the legacy password-based access system, and enrollment on EDGAR Next will be mandatory for filers to manage their accounts or submit filings
    • Filers will continue to be able to submit filings using the current password-based access system and the same processes used prior to EDGAR Next through September 12
  • New Annual Confirmation Requirement
    • An account administrator for each filer will have to confirm annually that all of the individuals and entities on the filer's dashboard are authorized by the filer to act on its behalf and that all information related to the filer on the dashboard is accurate
    • Account administrators will be able to select which quarter-end date will be the filer's ongoing confirmation deadline (March 31, June 30, September 30 or December 31)
    • If the annual confirmation is not made within three months after the deadline, the filer's EDGAR account will be deactivated and it will not be able to make filings until it re-enrolls in EDGAR Next by submitting the new Form ID

Existing Filers: Enrolling in EDGAR Next

Filers who have current EDGAR codes can enroll during the enrollment period without having to submit the new Form ID, obtain a power of attorney or notarize any documents. In order to avoid interruption in the ability to file, existing filers will need to enroll in EDGAR Next no later than Sept. 12, 2025.⁴ Filers will continue to be able to submit filings using the current password-based access system and the same processes used prior to EDGAR Next through September 12.

How to Enroll in EDGAR Next:

• Obtain individual Login.gov account credentials
  • The person who enrolls the filer and each account administrator will need individual Login.gov account credentials to access the EDGAR dashboard
  • Instructions on how to create a Login.gov account can be found here
    • It is recommended to use your business email address to sign up for EDGAR purposes, even if you already have a Login.gov account using your personal email
  • Collect current EDGAR access codes (CIK, CCC and passphrase)
    • You will need the CIK, CCC and passphrase for each filer in order to enroll into EDGAR Next during the enrollment period
      • If your CCC and/or passphrase has not been reset since September 2019 or you don't have access to such codes, then you may need to reset these codes by following these instructions
    • Identify account administrators for each filer
      • Filers will need to designate at least two account administrators (except for individuals and single member company filers, who need to designate at least one account administrator)
      • You will need the name, email address (which must match such person's Login.gov credentials), business address and business telephone number for each account administrator
    • Enroll in EDGAR Next using the dashboard between March 24 and September 12
      • Login to the dashboard (https://www.filermanagement.edgarfiling.sec.gov/) using your Login.gov account credentials and click "Enroll in EDGAR Next"
      • You can manually enroll individual EDGAR accounts, or bulk enroll multiple EDGAR accounts simultaneously using the CSV template available on the dashboard
      • During enrollment, you must choose an annual confirmation date for each filer (March 31, June 30, September 30 or December 31)
      • Note that enrollment will automatically reset the filer's CCC, which EDGAR will continue to require in order to make filings; the new CCC will be visible on the dashboard to any account administrator, user, or delegated entity
    • Delegate authority to file to necessary third parties
      • If a filer uses a third party such as a law firm, broker-dealer, printer or other filing agent to make filings, an account administrator must first delegate authority to file to such third party's EDGAR account using the dashboard; filers should coordinate with each of its filing agents for necessary instructions
        • If a public company submits Section 16 filings on behalf of any of your filers that serve as directors, you should coordinate with the company with respect to the delegation of authority to file on their behalf
      • Click here for instructions on how to delegate filing authority to Schulte Roth & Zabel

New Filers: Applying for EDGAR Access on Form ID

Beginning March 24, 2025, any prospective new filer that will need EDGAR codes will need to apply using the amended Form ID using the EDGAR dashboard with Login.gov credentials. The amended Form ID requires additional new disclosures regarding the applicant, its account administrators and certain other contacts, including disclosures regarding whether these individuals have been found to have violated securities laws and whether the applicant is in good standing in its place of incorporation. The account administrators can be (i) employees of the filer or an affiliate of the filer or (ii) any other individual authorized by a notarized power of attorney from the filer (which must be uploaded as part of the application).

The completed Form ID application must be signed, notarized, uploaded and submitted to the SEC for approval, which can take a number of business days. If the application is approved, the account administrator(s) will receive an email and can login to the dashboard to manage the EDGAR account, authorize additional users/admins and delegate filing authority to authorized third parties.

Additional Resources

The SEC has published additional materials relating to EDGAR Next and enrollment on the below websites. If you would like to discuss EDGAR Next or have any questions, we encourage you to contact one of the authors of this Alert or your attorney at Schulte Roth & Zabel.

• Obtain Login.gov Individual Account Credentials (SEC.gov)
• Enroll in EDGAR Next (SEC.gov)
• EDGAR Next Frequently Asked Questions (SEC.gov)
• EDGAR Next Overview Homepage (SEC.gov)
• EDGAR Next Instructional Video Playlist (YouTube)
• EDGAR Next Adopting Release (SEC.gov)

Footnotes

1. For the full adopting release, seeEDGAR Filer Access and Account Management, SEC Release No. 33-11313 (Sept. 27, 2024), which amended Rules 10 and 11 under Regulation S-T and Form ID.

2. Instructions on how to obtain Login.gov credentials are available here.

3. Filers who are individuals or single-member companies may have a single account administrator (although the designation of multiple account administrators is encouraged).

4. Between Sept. 15, 2025 and Dec. 19, 2025, existing filers may continue to enroll using the dashboard, but will not be able to make filings until they complete enrollment. Any filer who has not enrolled by December 19 will be required to submit the amended Form ID to apply for EDGAR access to make submissions and obtain SEC approval of the application.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.