Be Prepared for “EDGAR Next” Changes So You Aren’t Locked Out of EDGAR Right Before a Filing Deadline

On September 27, 2024, the US Securities and Exchange Commission (SEC) adopted amendments to Rules 10 and 11 of Regulation S-T, Form ID,¹ and the EDGAR Filer Manual, all of which will change the way filers access and manage their accounts on EDGAR (changes collectively referred to as “EDGAR Next” by the SEC).²

Among other things, EDGAR Next will phase out and ultimately eliminate the EDGAR access codes that filers (and financial printers and other filing agents) currently use to log in to EDGAR and make filings. If you are a current EDGAR filer, even if you only make a few filings a year, you need to be prepared for EDGAR Next and be ready to enroll on the EDGAR Next dashboard within the transition period.

Fortunately, current filers with active EDGAR access codes can use those codes during the transition period to enroll on the EDGAR Next dashboard. However, failure to enroll during the transition period will require filers to submit the new Form ID—which must be approved by SEC staff—to apply for access to make submissions on their EDGAR accounts.

Important transition dates to remember are:

March 24, 2025: The EDGAR Next dashboard goes live and enrollment begins. Current filers may begin enrolling on the dashboard as described under Q1 below but can continue to use the legacy EDGAR filing system in most cases until September 15, 2025. Current filers who submitted a Form ID under the old rules do not need to submit a new Form ID to enroll, unless they fail to enroll by December 19, 2025. New filers must apply for EDGAR access using the new Form ID.

September 15, 2025: All filers (current and new) will be required to use the EDGAR Next dashboard to make filings on EDGAR. Legacy EDGAR access codes (including password, passphrase, and PMAC) will be deactivated for filing purposes on September 15, 2025. After enrollment in EDGAR Next, filers will generate the CCC on the dashboard. The EDGAR Next framework of individual account credentials, account administrator dashboard invitation, and CCC will supplant legacy EDGAR access codes. However, the legacy EDGAR access codes will remain available solely for EDGAR Next enrollment until December 19, 2025, to allow any filers who did not enroll by September 15 time to reset needed codes and submit their enrollment.

December 19, 2025: Any filers (including current filers) who have not enrolled by 10:00 p.m. ET will be required to submit the amended Form ID to apply for access to make submissions on their EDGAR accounts. After December 19, 2025, legacy EDGAR access codes will be deactivated for all purposes.

FAQs

Q1: If I already currently file on EDGAR, do I need to submit a new Form ID once EDGAR Next goes live? If not, what do I do?

A1: Filers who have previously submitted a Form ID under the old rules and possess working EDGAR access codes do not need to submit a new Form ID as long as they enroll in EDGAR Next by December 15, 2025. Current filers will need to (1) authorize account administrators (for most filers, this will be between two and 20 people) to manage the filer’s EDGAR account, and once the account administrators have signed up at login.gov (more on that below), the account administrators will need to (2) use the filer’s existing EDGAR access codes to enroll on the EDGAR Next dashboard after it goes live on March 24, 2025.

Q2: If I’m a new EDGAR filer, what do I have to do?

A2: All new EDGAR filers will need to apply for EDGAR access using the new Form ID any time on or after March 24, 2025. Among other things, the new Form ID includes a space for authorizing and designating account administrators.

Q3: What are account administrators and what do they do?

A3: An “account administrator” is an individual that the filer authorizes to manage its EDGAR account and to make filings on EDGAR on the filer’s behalf. This can be a person who is employed by the filer (or one of its affiliates) or a person employed by a third party. However, if a filer wants to name an individual employed by a third party as an account administrator, then an authorized individual of the filer must provide a notarized power of attorney (which must be uploaded to the EDGAR Next dashboard or attached to the Form ID, as relevant to the filer).

Q4: How does login.gov work? Can we create a corporate-level account rather than individual accounts?

A4: Login.gov is a sign-in service of the US federal government that employs multifactor authentication. Login.gov is not exclusive to the SEC and is used for identity verification and account access across federal agencies. Only individual people may apply for login.gov access. It is not available at a corporate level. Because multifactor authentication is required, text message or other push notifications will generally be sent to the individual user’s cell phone, which may be a personal device. It is highly recommended that multiple people are registered for each filer via login.gov so that timely EDGAR filings are not jeopardized when any one individual is unavailable.

Q5: My company currently engages a financial printer to handle filings on EDGAR. Can I continue to do that on EDGAR Next?

A5: Yes. Individual employees at a financial printer may be authorized and designated as “account administrators” for a filer (see Q3 above). Alternatively, individual employees at a financial printer may be designated as “users” by an account administrator. A “user” is an individual whom the filer authorizes on the EDGAR Next dashboard to make submissions on EDGAR on the filer’s behalf. It is not a requirement that a notarized power of attorney be provided for the account administrator to designate a “user”—it can be done with a few clicks on the EDGAR Next dashboard. Users will need to have created login.gov credentials, must be individuals, and will need to use multifactor authentication.

Q6: What can I do now to prepare for EDGAR Next?

A6:

• If you use a financial printer, reach out to them to discuss how best to handle the EDGAR Next transition. Most, if not all, financial printers who handle EDGAR filings for clients are in the midst of preparing for EDGAR Next.
• Consider which individuals in your organization should be the authorized as and designated “account administrators” and/or if you want to engage any employees of a third party to fill that role. Although EDGAR Next isn’t yet live, login.gov accounts can be created now, and those accounts will remain active and available when EDGAR Next goes live. Consider having the relevant individuals enroll in login.gov sooner rather than later.
• If you are a current filer, confirm that you have active, current CIK, CCC, and passphrase, as you will need this information to enroll on the EDGAR Next dashboard when it goes live.
• Take advantage of the beta testing environment,³ which is available now and will remain open until enrollment ends in December 2025, so that the relevant individuals are familiar with the dashboard interface before EDGAR Next goes live. Note: While real login.gov credentials are required to use the beta testing environment, all other information and data provided should be fictional.

 

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¹ Referenced in 17 CFR 239.63, 17 CFR 249.446, 17 CFR 269.7, and 17 CFR 274.402.

² Available at https://www.sec.gov/files/rules/final/2024/33-11313.pdf

³ Available at https://www.sec.gov/submit-filings/improving-edgar/edgar-next-improving-filer-access-account-management.