Public companies and others required to file reports with the U.S. Securities and Exchange Commission (the “SEC”) will soon have to follow new procedures for submitting their filings, under recently adopted amendments to the SEC’s Electronic Data Gathering, Analysis, and Retrieval system (“EDGAR”) known as EDGAR Next.
Complying with the changes should not require significant effort, but some preparation is necessary. Current EDGAR filers will be able to comply through enrollment on the new EDGAR dashboard, which will go live on March 24, 2025. Prospective new filers (and existing filers unable to enroll) will have to submit a Form ID. By September 15, 2025, all filers will have to use the new process to make EDGAR filings.
The key changes include:
- Individual credentials – Historically, each EDGAR filer was assigned a set of access codes that may be used by any individual who had access to the codes to make EDGAR submissions for the filer. Under EDGAR Next, only designated individuals can make filings on the filer’s behalf and must obtain individual account credentials from Login.gov. Specifically, only an account administrator, a user, a delegated administrator or a delegated user may submit filings on EDGAR.
- Two account administrators – With some exceptions, each filer must authorize at least two individuals as account administrators.
- Annual confirmation – Each filer, through its account administrators, will be required to confirm annually that all account administrators, users, technical administrators, and other filers authorized to file on its behalf, such as filing agents (“delegated entities”), reflected on the filer’s EDGAR dashboard are authorized by the filer to act on its behalf and that all information regarding the filer on the dashboard is accurate.
- Application Programming Interfaces (“APIs”) – Filers will be able to use APIs to make submissions, retrieve information and perform account management tasks. Filers choosing to connect to EDGAR through APIs will need to authorize at least two technical administrators unless the filer arranges to use a delegated filer’s APIs.
For further details about the changes, please download our full publication.
For further information, please contact:
Mike Bienenfeld, Partner, Linklaters
mike.bienenfeld@linklaters.com