The U.S. Securities and Exchange Commission (the “SEC”) adopted changes to its Electronic Data Gathering, Analysis, and Retrieval System (“EDGAR”) used by private and public companies and other reporting persons to submit filings under federal securities laws. These changes, collectively referred to as “EDGAR Next” are the most significant updates to the EDGAR system in over two decades and are designed to improve security, filer access, and account management. 

The deadline for all filers to transition to EDGAR Next is September 15, 2025. Existing filers will not be able to make any filings until they have completed enrollment.

This alert provides a summary of the changes to the EDGAR platform and an outline of the steps that all filers must take in order to enroll in EDGAR Next ahead of the mandatory compliance deadline. 

What is Changing with EDGAR Next

EDGAR Next will not allow filers to share access codes with third parties. Instead, each individual authorized by the filer must obtain their own EDGAR account credentials via Login.gov, which requires multifactor authentication. This shift enhances security by ensuring that access is tied to verified identities and protected by strong authentication protocols. As a result, the password, passphrase, and password modification authorization code (“PMAC”) associated with each filer will be retired. 

After enrollment, account administrators can delegate filing authority to other EDGAR accounts through the EDGAR Next dashboard, allowing authorized third parties (such as law firms or filing agents) to submit filings on the filer’s behalf. These delegations can be added or revoked at any time, giving filers full control over who can access and file through their EDGAR account.

In connection with these updates, the SEC has also released an updated Form ID application and EDGAR Filer Manual. EDGAR Next will also offer optional application programing interfaces (“APIs”) to filers, which will enable machine-to-machine communication with EDGAR for the first time. 

What is not Changing with EDGAR Next?

EDGAR Next will continue to use a central index key (“CIK”) and CIK confirmation code (“CCC”) to identify filers. The CIK assigned to each filer will remain unchanged, but filers will be issued a new CCC at the time of enrollment. Existing online forms for EDGAR filings will also remain the same, provided that filers must be enrolled in EDGAR Next to make such filings. The public-facing search and retrieval systems remain unchanged.

Risks of Failing to Enroll in EDGAR Next

Failure to enroll in EDGAR Next will result in the loss of filing capabilities, leading to late or missed required filings with the SEC. Such failures to make timely filings could result in enforcement actions, trading suspensions or delistings, inability to access capital markets, and exposure of directors and officers to liability. The legacy EDGAR system will be accessible until December 19, 2025. After this date, filers will need to submit an amended Form ID in order to enroll in EDGAR Next.

Confirm Current EDGAR Access Codes Are Current

Account administrators will need to submit the filer’s current CIK, CCC and passphrase in order to complete enrollment. As an initial step, filers should confirm that that they have access to their EDGAR credentials and test these credentials to confirm they are active.

Obtain Individual Account Credentials

Filers will need to determine who will serve as their initial account administrators and those individuals will need to obtain individual account credentials. For existing filers, in order to complete EDGAR Next enrollment, these individuals will need to first obtain individual account credentials through login.gov and enable multifactor authentication.

Note that each individual account will have unique credentials which cannot be shared.  

Complete One-Time Enrollment and Designate Account Administrators

An individual who has obtained individual credentials can initiate the enrollment process. Existing filers should coordinate this process with any third parties that they have historically authorized to make filings on their behalf, such as outside law firms and filing agents, in order to avoid duplicative enrollment attempts. The individual completing the enrollment process will not have ongoing responsibilities for managing the filer’s EDGAR account unless they are separately designated as an account administrator.

Account administrators are designated during the enrollment process and these persons will have ongoing responsibility for maintaining the filer’s EDGAR Next account. The name, email address, business address, and business telephone number for each account administrator must be provided. Generally, at least two individual accounts must be designated as account administrators during the enrollment process. Individuals or single-member companies will only be required to designate one account administrator. Filers will have the ability to add additional account users once enrollment is complete.

After Enrollment

Once enrollment is complete, account administrators can delegate the ability to submit filings to other EDGAR accounts, allowing third parties—such as law firms or filing agents—to submit filings on the filer’s behalf. These invitations are managed through the filer’s EDGAR Next dashboard, and the delegated entity must have an EDGAR account to accept the invitation. Law firms can play a key role by managing filings for their clients once delegated access is granted, ensuring compliance and timely submissions. Account administrators can add or remove these delegations at any time, maintaining full control over who can act on behalf of the filer.

Designated account administrators will be required to confirm that the filer’s information in EDGAR Next is accurate on an annual basis. Each filer will have the ability to select a quarter-end date (i.e., March 31, June 30, September 30, or December 31) for their annual confirmation during the enrollment process. Failure to complete the annual certification will lead to deactivation of the filer’s EDGAR account.

This Legal Alert is a brief summary of EDGAR Next and is intended for informational purposes only. It does not constitute legal, compliance or other advice for any individual or entity. Please consult your legal advisor for further information regarding EDGAR Next in relation to any specific situation.

For More Information, Please Contact:

Natalie Wilson

Partner

San Francisco, CA

Holly Delaney

Corporate Projects Manager

San Francisco, CA