Overview
On September 27, 2024, the U.S. Securities and Exchange Commission (the SEC) adopted amendments to Regulation S-T, resulting in major changes to the Electronic Data Gathering, Analysis, and Retrieval (EDGAR) System for SEC filers. The updated system, called “EDGAR Next,” went live on March 24, 2025, though filers may continue using the legacy system until September 15, 2025. After September 15, however, EDGAR Next will become the default filing system, and all filers will be required to enroll in EDGAR Next before submitting any additional filings. Enrollments must be completed by December 19, 2025 to take advantage of the streamlined enrollment process.
While the SEC attempted to ease the burden of the transition for filers with a streamlined enrollment process, there are several issues that filers should consider to avoid any complications or loss of filing access. This alert provides an overview of key considerations and reminders as companies prepare to transition to EDGAR Next.
What Is EDGAR Next?
EDGAR Next represents the latest step the SEC’s efforts to modernize its electronic filing system. The changes are designed to enhance and strengthen account access, filer authentication, and account management.
Some of the major features of EDGAR Next include:
- Mandatory Login.gov accounts for all individuals accessing EDGAR, replacing shared credentials.
- Multi-factor authentication (MFA) to improve system security.
- Role-based access and account administration, allowing filers to control who can manage filings and what level of access they have.
- Filing agent delegation, allowing filers to authorize third parties to make filings on their behalf.
- Annual certification requirements for filers to verify account details and user access.
Notably, access to EDGAR will move from a system permitting shared login credentials to one requiring individual Login.gov accounts backed by MFA. As a result, the physical filing process will change significantly, and filers will need to designate specific individuals authorized to file on their behalf in advance of any filing date.
Important Dates
The SEC published the following timeline for the implementation of EDGAR Next:
- March 24, 2025: Enrollment opened. Companies began the process of transitioning to the new filing system. Filers may continue to use the legacy password-based access system while enrolling in EDGAR Next.
- September 15, 2025: The legacy EDGAR login system (using CIKs and passphrases) will be retired. From this date forward, all EDGAR access and submissions must use the EDGAR Next platform. While the enrollment period will remain open through December 19, 2025, filers will not be able to submit filings until completing enrollment, which could potentially delay any last-minute filings beyond applicable deadlines.
- December 19, 2025: Enrollment closes. Any filer who has not completed enrollment will be required to submit an amended Form ID prior to filing on EDGAR. This process will require additional documentation and SEC review beyond what is required during the enrollment period.
Filers are strongly encouraged to enroll early to avoid last-minute complications and ensure uninterrupted access to EDGAR, especially for filers with multiple authorized users or filing agents.
Key Roles Under EDGAR Next
In a major change from the current EDGAR system, EDGAR Next introduces role-based access, delineating particular persons for specific filing functions. These include:
- Account Administrators: Companies must authorize and maintain at least two account administrators per filer, with a maximum of 20. Account administrators manage all user access, role assignments, and periodic account certifications. Account administrators can also perform all the functions of a general user and thus cannot be registered for both roles. Filers should consider distributing these roles across the company and reviewing their list of account administrators frequently to ensure continuous access to EDGAR in the event of employee turnover.
- General Users: Individuals authorized to prepare and submit filings.
- Technical Users: Individuals or systems using EDGAR API tokens to submit filings programmatically.
Role assignments are entirely under the control of the filer via the filer’s authorized account administrators and changes can be made at any time through the EDGAR Next dashboard.
Delegating to Filing Agents
If it uses a third-party service provider—such as a law firm or a filing agent—to make EDGAR submissions, the company will need to formally delegate filing authority to that party within EDGAR Next by selecting each filer that will be delegating authority and entering the CIK for the third-party. This is done via the account dashboard and can be managed or revoked at any time. Filers should ensure that any third-party provider receiving delegated authority has been provided with the updated CCC that was issued to the filer during enrollment on EDGAR Next.
Delegation does not give the agent full access to the company’s filer account; it only allows them to submit filings only under the authority granted to them.
Annual Certification Requirement
All filers will be required to annually certify the accuracy of their EDGAR account information. This includes:
- validating user roles and permissions;
- confirming active delegations; and
- verifying the contact information associated with the filer account.
The certification must be completed within 90 days after the quarter-end date (March 31, June 30, September 30, or December 31) that was selected at enrollment. If a filer fails to complete its annual certification within the 90-day period after its selected quarter end date, it will have a three-month grace period to comply. If the filer fails to complete the annual confirmation by the end of the three-month grace period, the filer’s account will be deactivated and its ability to submit EDGAR filings will be suspended. The filer will then be required to re-apply for access to file on EDGAR via Form ID and to re-invite any administrators, users, and delegates. Annual certification is required for all filers registered on EDGAR, even if not actively engaged in an offering.
Section 16 Filers
Individual directors and officers with Section 16 filing obligations will also be required to enroll in EDGAR Next. The enrollment process for individual Section 16 filers mirrors the process for companies, and individuals, like companies, may opt to have a trusted third-party (such as the company, a filing agent, or law firm) complete the enrollment process on their behalf. As with company enrollment, Section 16 filers can only be enrolled once and should coordinate with all third parties that currently file on their behalf, especially if they serve as a director for more than one company.
What to Do Now?
Given the number of parties required to coordinate and the time sensitive nature of enrolling in EDGAR Next, filers should begin planning their transition well in advance of the September 19 discontinuation of the legacy EDGAR system. Identified below are seven steps that filers can begin taking or discussing internally to ensure they are in the best position to fully comply with EDGAR Next.
Step 1: Identify Current Parties
- Filers should identify all individuals and third parties who currently access the company’s EDGAR account.
Step 2: Create a Login.gov Account
- Each individual who needs to access EDGAR will be required to create a personal Login.gov account if they do not already have one. This account is used to verify the individual’s identity and must be protected with MFA.
- Filers should note that the personal Login.gov accounts for individuals (such as an employee submitting a filing on behalf of an issuer) are distinct from the filer’s own Login.gov account, and filers will need to either create their own Login.gov account to enroll or select a trusted person (such as an employee, filing agent, or law firm) to enroll them.
- Each filer may only enroll once, so it is important to coordinate with all individuals and entities that currently submit filings on the filer’s behalf to ensure a coordinated approach for enrollment.
- Filers should ensure that all individuals who will continue to access the filer’s EDGAR account create Login.gov accounts well ahead of the enrollment deadline.
Step 3: Access the EDGAR Filer Management Interface
- Users will use their Login.gov credentials to sign into a new EDGAR interface designed specifically for managing filer accounts and delegating authority.
Step 4: Claim and Enroll CIKs
- Filers will need to link their Central Index Key (CIK) numbers. This is a verification step that links EDGAR Next access to the company’s existing filer identity, and requires the filer’s CIK, CIK Confirmation Code (CCC), and passphrase.
- Enrollment can be done manually for each filer or in bulk if a company will be registering multiple filers with individual CIKs.
- Note: Filers must have a “current” CCC and passphrase to enroll.
- CCCs and passphrases are considered “current” if they were created after August 2019.
- Any CCCs and passphrases created prior to September 2019 are insufficient for enrollment, and filers must obtain a new CCC and passphrase in the existing EDGAR system prior to enrolling in EDGAR Next.
- Note: The filer’s CCC will be updated with the enrollment process, and the new CCC must be used by those submitting filings on the filer’s behalf, even for traditional filings during the transition period from March 24, 2025, to September 12, 2025.
- Filers should make sure to share this updated CCC with appropriate parties.
Step 5: Assign Account Administrators and User Roles
- At least two account administrators must be designated for each filer. These individuals are responsible for managing user access, assigning user roles, completing annual confirmations (see Step 6), and updating account details.
- Filers will need to provide each administrator’s
- Business address,
- Business telephone number, and
- Email address, which must match the email associated with an individual’s own Login.gov account.
- After designating account administrators, the filer should establish clear internal procedures for granting and revoking access as employees or third-party vendors change roles.
- Any new employees or vendors will need to have an assigned role prior to submitting any filings on behalf of the filer.
- Users and their respective access privileges should be reviewed frequently.
Step 6: Annual Confirmation Selection
- Filers will need to select the quarter-end date by which they will perform annual confirmation on EDGAR and ensure that such confirmation is provided each year.
Step 7: Delegation to Third-Party Filing Agents
- Filers should reach out to all third-party filing agents that currently file on the company’s behalf and coordinate delegation within the EDGAR Next dashboard.
- Filers will need the filing agent’s CIK in order to delegate authority, and this election should be made in advance of any filing date.
Conclusion
EDGAR Next represents a significant step forward in how the SEC manages electronic filings. While the new system will require EDGAR filers to invest time and attention during the transition, filers will hopefully benefit from increased security and a more streamlined filing interface.
Early preparation is the best way to ensure the company stays compliant and avoids last-minute disruptions. For more information, visit the SEC’s dedicated EDGAR Next webpage:
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