EDGAR Next – Time to Enroll

By Alex Bowling and Olivia Meade

On September 27, 2024, the U.S. Securities and Exchange Commission (SEC) adopted rule and form amendments, collectively referred to as "EDGAR Next," to make its online filing and account management system more secure and user-friendly. EDGAR Next became effective on March 24, 2025, and existing filers have until September 12, 2025 to comply with the amendments.

The amendments apply to all entities and individuals that make filings with the SEC on EDGAR (referred to throughout as filers), including reporting companies, Section 16 insiders, shareholders or large traders with filing obligations (e.g., individuals or entities filing on Schedules 13D, 13G or 13F and Form 144) and non-reporting companies that are required to file a Form D, as well as individuals who serve in any of the new roles introduced by EDGAR Next, such as Account Administrators and Users.

In this legal alert, we provide recommended actions filers should take now to prepare for the transition to EDGAR Next. Additional details about the changes introduced by the new rules can be found in our November 5, 2024, alert.

Preparing for EDGAR Next

Filers should prepare for enrollment in EDGAR Next by taking the following actions.

• Create a Login.gov account. All individuals who will need access to a filer’s EDGAR account must have Login.gov credentials. This includes the person authorized to enroll the filer, Account Administrators and Users. Individual filers are not required to have a Login.gov account unless they plan to be designated as an Account Administrator for their own EDGAR Next profile or plan on accessing EDGAR to make their own submissions. Instructions on how to create an account can be found at Login.gov. 

• Collect and review EDGAR access codes.
  • A filer’s CIK, CCC and passphrase are required for enrollment in EDGAR Next. Confirm you have the EDGAR access codes for each filer for whom you are responsible and test the codes to confirm they are accurate and have not expired.
  • According to the SEC, filers who have not reset their CCC or passphrase since September 2019 must obtain a new CCC and a new passphrase before enrolling. Please visit the SEC’s EDGAR Next Frequently Asked Questions for more information on resetting codes, generating replacement codes and updating EDGAR points of contact. Prior to resetting the CCC, filers should ensure there is coordination with all filing agents who need access to EDGAR for the filer. Once enrolled, the CCC can be reset to the original CCC to ensure no EDGAR submissions are impacted.
  • An individual responsible for enrolling multiple filers in EDGAR Next will have the ability to use a "bulk enrollment" feature. This feature will allow authorized individuals to enroll up to 100 accounts at once by populating and uploading a spreadsheet template that is available on the EDGAR Next dashboard.
• Coordinate with officers and directors. Officers and directors with Section 16 reporting obligations must be enrolled in EDGAR Next. Such individuals can be enrolled by any of the companies where they are a Section 16 filer, their employers (if different) or their advisors (e.g., law firm or filing agent). Filers can only be enrolled once, so officers and directors who have Section 16 reporting obligations at multiple companies will need to confirm (1) who is enrolling them, (2) that there are authorized Users or Account Administrators at each such company and (3) which Account Administrator will complete the required annual confirmation on the filer’s behalf. 

• Identify the individuals who will serve in various roles. Determine who will serve as Account Administrators and Users for each EDGAR account. While most filers are required to appoint at least two Account Administrators (or one, in the case of an individual or a single-member company), filers should consider appointing additional Account Administrators and Users as appropriate to meet their filing needs.

• Coordinate with third-party filing agents. If you use a financial printer or other filing service to make SEC filings, you must delegate to them the authority to file on your behalf by September 15, 2025. Filers will need the CIK of their filing agent, and the filing agent must be prepared to accept the delegation of authority from the filer. We recommend coordinating in advance of September 15, 2025 to understand the transition processes and timelines of your vendors.

• Complete amended Form ID for new filers. Use amended Form ID to request EDGAR access for any new filers. The amended Form ID and any power of attorney attachments must be notarized. Please note that processing delays may occur due to the changes introduced, so ensure you submit your application well in advance of any anticipated filing deadlines. 

Key Compliance Deadlines

• September 15, 2025 – mandatory enrollment deadline. After enrolling in EDGAR Next, filers can continue to use both the legacy EDGAR platform and their new EDGAR Next access credentials interchangeably until Friday, September 12, 2025. Beginning on Monday, September 15, 2025, all filers must be fully enrolled in EDGAR Next to make any filings or submissions with the SEC. The legacy system will remain operational until December 19, 2025 but solely for the purpose of enrolling in EDGAR Next. 

• 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 filings.

If you have any questions related to this legal alert, please do not hesitate to contact any member of the Public Companies group or your regular Smith Anderson lawyer.

Special thanks to contributing author Alex Simpson, Smith Anderson paralegal and current student at Campbell University School of Law.