Key takeaways – action list for filers
- Prepare Login.gov credentials: All individuals who need access to a filer’s EDGAR account will be required to have a Login.gov account. Those individuals should prepare their credentials as soon as possible to avoid unnecessary delays.
- Identify who will serve as administrators: Filers should determine who will serve as account administrators, technical administrators and users, each with unique roles within EDGAR Next explained further below.
- Review EDGAR access codes: The access codes used in the legacy EDGAR system (the CIK, CCC and passphrase) are required for enrollment in EDGAR Next. Filers should gather these codes and verify that they are current.
- Coordinate with officers and directors: Individuals filing as Section 16 officers and directors must be enrolled in EDGAR Next separately from the companies that they serve on. Those individuals who serve as officers or directors for multiple companies should coordinate to ensure proper enrollment and that third parties who need filing access, such as brokers filing Rule 144 forms, are properly registered.
Background
On September 27, 2024, the Securities and Exchange Commission (the “SEC”) adopted rule and form amendments to the Electronic Data Gathering, Analysis, and Retrieval (“EDGAR”) system. EDGAR Next is a modernization of the legacy EDGAR electronic filing system and is designed to enhance security, streamline account management, improve user accessibility and allow for easy identification of authorized users and filing parties.
What’s new under EDGAR Next?
Under the legacy EDGAR system, each filer uses a set of assigned EDGAR access codes (the CCC, password, PMAC and passphrase) in addition to the filer’s unique CIK identifier code to access their EDGAR account. Filers share these codes with third parties whom they have authorized to file on their behalf. Under EDGAR Next, filers will have the ability to designate account administrators, technical administrators and users with scaled responsibilities and designated roles to manage the filer’s EDGAR information and authorize filings, replacing the access code system.
- Account administrators: Each filer must designate at least two but up to twenty account administrators who will be responsible for managing the filer’s EDGAR account and handling tasks such as making submissions on behalf of the filer and modifying access for additional account administrators, technical administrators or users. Individuals and single-member companies are required to designate only one account administrator. However, as account administrators serve key functions such as adding and removing other individuals as administrators and serving as the point-of-contact for the filer with the SEC, we strongly recommend all filers have two or more account administrators to avoid any issues or delays.
- Technical administrators: If the filer chooses to connect to EDGAR APIs, the filer, through its authorized account administrator(s) must authorize at least two but up to twenty technical administrators to manage the filer’s Application Programming Interfaces (“APIs”) used in the submission of filings, retrieval of information and performance of account management tasks, unless the filer uses a separate delegated entity that complies with the technical administrator requirements.
- Users: Users can make filings on behalf of the filer but are otherwise limited in their filer management abilities compared to the account administrators.
To obtain access to EDGAR Next, account administrators, technical administrators and users will be required to have their own separate Login.gov account with multifactor authentication. Additionally, account administrators will be required to confirm the accuracy of the filer’s EDGAR system information annually, including verifying that all persons listed in the EDGAR account dashboard are authorized by the filer to act on its behalf and that all other information about the filer is correct. While the CIK will remain to identify filers and the CCC will remain as a code required to file on EDGAR Next, the password, PMAC and passphrase will be discontinued for filing purposes after September 15, 2025; previous access codes will only be available from September 15, 2025 to December 19, 2025 for filers to enroll in EDGAR Next.
Key compliance deadlines for EDGAR Next transition
Below are critical dates1 for all filers to keep in mind to maintain compliance with SEC’s transition to EDGAR Next:
- March 24, 2025 – EDGAR Next launch date: The new EDGAR Filer Management system, including the updated dashboard, went live. Existing filers can begin enrolling in EDGAR Next; any new filers applying for EDGAR access must apply with the amended Form ID on the EDGAR Next dashboard.
- September 15, 2025 – mandatory enrollment deadline: To continue submitting filings, all filers must be fully enrolled in EDGAR Next by September 15, 2025. While the legacy system will remain operational until December 19, 2025, it will only be available for enrollment purposes, and no filings can be submitted using legacy credentials after this deadline. The password, PMAC and passphrase will be discontinued for filing purposes after this date; previous access codes will only be used for filers to enroll in EDGAR Next.2
- December 19, 2025 – legacy system deactivation: The legacy EDGAR system will be permanently retired. Any filers who have not completed enrollment in EDGAR Next must submit a new amended Form ID to request access to their existing accounts or to make any filings.
Section 16 filers: additional considerations
All individuals who are filing on EDGAR Next, such as Section 16 filers who serve as an officer or director, can enroll themselves onto EDGAR Next or be enrolled through a third party, such as their filing agent or the company for which they serve as a Section 16 officer or director. Once individuals are enrolled with their unique CIK, they will be able to access the dashboard on EDGAR Next, authorize account administrators, and delegate to filing agents as necessary. As such, companies who have Section 16 filers should coordinate with their filers to ensure proper enrollment.
Furthermore, in cases where a Section 16 filer is a director for more than one company and has each company manage their filings, companies should coordinate with the filer to ensure that the filer is enrolled only once. Companies should also determine who will serve as the account administrator for the filing individual to ensure that all parties are in alignment regarding the individual’s enrollment in EDGAR Next. Once enrolled, individual filers will be able to authorize representatives of different companies to be users or account administrators and may alternatively instruct their account administrators to delegate the ability to file to additional representatives or filing agents by adding further users.3
Looking forward to EDGAR Next: implementation and next steps
The SEC’s website on EDGAR Next provides informative guidelines on enrollment, commonly asked questions, webinar links and other filer support information that filers should review in preparation for the transition to EDGAR Next. Additionally, filers should consider the following steps as they begin enrollment:
- Review the SEC EDGAR Next’s Beta website: The SEC has opened a beta version of EDGAR Next to give filers a chance to see the new dashboard and authorization tools in action. Filers should review the beta website to familiarize themselves with the new interface and test out the new features available. While filers must use actual Login.gov credentials to access the beta, once logged in, filers should only submit fictional data and avoid using any sensitive personally identifiable information of the filer for creating test accounts or test filings. All test accounts or test filings done through the beta website is for beta testing purposes only and will not carry over to the filer’s actual EDGAR Next account. Once familiarized with the beta website, filers should consult with their external counsel and third-party filing agents to discuss any implications that the changes in EDGAR Next might have on their internal filing procedures.
- Review filer information and EDGAR access codes: Existing filers should review their current access codes, including the filer’s CIK, CCC and passphrase, which will be necessary to enroll in EDGAR Next. Filers who have not reset CCC or passphrase since September 2019 should also obtain a new passphrase and a new CCC before enrolling on EDGAR Next.
- Identify administrators/users and prepare Login.gov credentials: Filers should use the transition to refresh their corporate filing procedures and determine internally who they will be selecting as their account administrators, technical administrators and users. While most filers are required to appoint at least two account administrators, filers should consider appointing additional administrators and users as appropriate to meet their filing needs. In addition, filers should ensure that any individuals who they intend on designating as an account administrator, technical administrator or user has their own Login.gov account credentials prepared, which operates separately from EDGAR Next and can be created in advance. As EDGAR Next will need each account administrator’s name, email address (which must be identical to their Login.gov email address), business address and telephone number, filers should also consider preparing the following information prior to commencing enrollment.
Footnotes
1. Please visit the EDGAR Next Frequently Asked Question #5 for a table illustrating the timeline for enrollment: SEC.gov | EDGAR Next Frequently Asked Questions.
2. While the password, PMAC and passphrase will be discontinued, the CIK will remain to identify filers and the CCC will remain as a code required to file on EDGAR Next.
3. For more information on Section 16 filers and enrollment in EDGAR Next, please visit SEC.gov | Enroll in EDGAR Next: Individual Filers/Section 16 Filers.