EDGAR Next: FAQs for Section 16 Reporting Persons

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On March 24, 2025, the SEC’s new filing system, “EDGAR Next,” went live. This transition has left Section 16 reporting persons with various questions about what they need to do and by when.

The following FAQs address the key issues Section 16 reporting persons need to know about the EDGAR Next transition.

1. What is EDGAR Next, and why is the SEC making these changes?

EDGAR Next is the new filer access and account management system for the SEC’s EDGAR online filing database. The SEC adopted EDGAR Next in order to enhance the security of EDGAR filings and to prevent fraudulent filings.

Among the security enhancements is the creation of an account administrator responsible for delegating filing access to specific people, which prevents filings being made by anyone who has access to another person’s filing codes.

2. If I am a director or officer of a public company, what information do I need to enroll in EDGAR Next?

Whoever is handling your EDGAR Next enrollment will need three SEC filing codes for you:

  • CIK: Central Index Key, which is your publicly available, unique identifier on the SEC’s EDGAR system. Analogous to a username, this number may not be changed and never expires.
  • CCC: CIK Confirmation Code, which is not public and is used together with your CIK to make EDGAR filings. This is analogous to an account password.
  • Passphrase: This is a code created by filers during the application for EDGAR codes. It currently allows filers to make changes to certain account settings, such as generating a new CCC. The passphrase will be discontinued on December 22, 2025 following the phase-out of the legacy EDGAR filing system.

3. What happens if I don’t have access to my CCC or Passphrase?

If you have one of these two codes, it may be possible to reset the missing code by requesting to have a security token sent to the email address associated with your codes. Your company’s SEC filing team and/or outside counsel can assist with this process.

If you don’t have either code, then you will need to sign a notarized power of attorney granting your company’s SEC filing team or outside counsel authority to apply for new codes on your behalf. Note that this can take several business days after the application is submitted.

4. I sit on multiple public company boards, how do I know who is handling enrolling me in EDGAR Next?

If you make filings for multiple companies, you will need to make sure that the appropriate contacts at each company are coordinating the EDGAR Next enrollment process. A few important things to note:

  • You can only be enrolled in EDGAR Next once, so if multiple companies try to enroll you, they will get error messages.
  • When you are enrolled in EDGAR Next your CCC will automatically be reset. In order to avoid late filings, whoever handles your enrollment should either set the CCC back to what it was prior to enrollment or communicate the new CCC to each of your other companies.
  • Whoever handles your initial enrollment will need to add at least one account administrator from your other companies (who can then add additional account administrators and delegating filing access as needed).

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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