In order to avoid interruptions to their electronic filings with the U.S. Securities and Exchange Commission (the “SEC”), companies that file reports with the SEC must enroll in EDGAR Next by September 15, 2025.
The SEC announced the transition to EDGAR Next, the new version of its Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system, last year, as discussed in our earlier client publication available here. Among other things, EDGAR Next requires filers to designate specific individuals to make filings on the filer’s behalf.
What does enrollment require?
Enrollment is a streamlined process that allows filers to transition to EDGAR Next through the EDGAR Filer Management system.
Filers will be required to submit the following key information in order to enroll:
- The filer’s CIK, and current passphrase and CIK confirmation code (CCC). If a filer has not reset its CCC and/or passphrase since September 2019, these codes should be reset, as set out here, prior to enrolling.
- The names of two account administrators the filer will authorize during enrollment, and each account administrator’s: (i) business address; (ii) business telephone number, and (iii) email address, which must match the individual’s Login.gov individual account credentials email address for use on EDGAR.
- The quarter-end date by which it will perform annual confirmation on EDGAR (either March 31, June 30, September 30, or December 31). There is no requirement for this date to match the filer’s annual financial reporting cycle.
Each filer may enroll only once, and only one individual can enroll each filer. Therefore, each filer should determine which entity or individual the filer will authorize to enroll it and ensure that others do not attempt to enroll the filer without authorization. Enrollment requests are typically processed and effective the same day they are submitted.
If completed before December 19, enrollment will not require filers to submit a notarized Form ID to the SEC staff.
Who should enroll the filer?
A filer may enroll itself or may select anyone it trusts to enroll it, including but not limited to the filer’s employee, filing agent or law firm, or other trusted entity or individual.
The individual who enrolls the filer must have Login.gov individual account credentials to access the dashboard, as described further here.
What happens if a filer has not enrolled by September 15?
During the transition period ending September 15, 2025, all EDGAR filers may make EDGAR filings using the traditional process, whether or not they are enrolled. Beginning September 15, 2025, however, filers that have not enrolled will be unable to file on EDGAR until they enroll.
What is the next key date?
Enrollment ends at 10PM ET on December 19, 2025. After that date, filers that have not enrolled will not be able to file on EDGAR or otherwise access their accounts unless they submit a Form ID application for EDGAR access that is granted by SEC staff. The Form ID application requires notarization, and a notarized power of attorney for any third-party account administrator.
* * *
Please contact us for any assistance with enrollment.
You can also find further helpful information on the SEC’s website, including a short video on enrollment, an in-depth webinar on EDGAR Next and the webinar slides.
For further information, please contact:
Mike Bienenfeld, Partner, Linklaters
mike.bienenfeld@linklaters.com
