EDGAR Next: What Filers Need to Know and How They Can Prepare

• The Securities and Exchange Commission officially adopted the “EDGAR Next” changes to its Electronic Data Gathering, Analysis, and Retrieval system (“EDGAR”) on September 27, 2024.¹
• These changes to the EDGAR filing system will become effective on March 24, 2025, and will affect all current and prospective EDGAR filers.
• Filers that have completed the process of obtaining the password-based credentials used under the current system by 10 p.m. ET on March 21, 2025, also known as “existing filers,” will have until 10 p.m. ET on September 12, 2025, to comply with the changes through a simplified enrollment process. After enrolling, such filers may continue to use their existing password-based access credentials and their new EDGAR Next access credentials interchangeably until 10 p.m. ET on September 12, 2025. Accordingly, to avoid delays, new filers with upcoming filing obligations should consider obtaining password-based credentials under the current system by 10 p.m. ET on March 21, 2025, so as to become an existing filer and qualify for this transition relief.²

EDGAR Next implements technical and process-related changes designed to improve the security of the EDGAR system, as well as filer account access and management, and modernize filing authorization. These changes to the EDGAR filing system affect all current and prospective EDGAR filers. Among other things resulting from EDGAR Next, current and prospective filers should be aware of the following:

• Filers will no longer be able to use (or share) a single set of credentials to access EDGAR. Instead, EDGAR Next will require each individual to obtain a distinct Login.gov account and complete multi-factor authentication to access EDGAR.
• The changes introduce a new website with a dashboard through which each EDGAR filer will manage its account.
• The changes will require each EDGAR filer to designate certain individuals to serve in certain roles with responsibilities. In particular, each filer will be required to appoint at least two “account administrators” (although one is permitted if the filer is an individual or single-member company). Account administrators will be permitted to add and remove other account administrators, technical administrators and users and delegate filing authority to filing agents, including law firms and printers. In addition, as further discussed below, account administrators will be subject to various account management and compliance requirements. The filer also will be required to designate at least two “technical administrators” (unless the filer will not be using any application programming interfaces (APIs) or will be using only the filer API tokens and API connections of a delegated filer). Finally, account administrators will be permitted to appoint additional individuals authorized to make filings on behalf of the filer by identifying them as users on the filer’s dashboard.
• One account administrator will be required to confirm on an annual basis that the information in a filer’s EDGAR Next account is correct. (Any of the four calendar quarter-end dates may be chosen as the filer’s ongoing confirmation deadline.)

As of 6 a.m. ET on September 15, 2025, compliance with all EDGAR Next and form changes will be required in order to file on EDGAR. Access to all EDGAR websites (EDGAR Online Forms, EDGAR Filing, and EDGAR Filer Management) will require Login.gov credentials and completion of multifactor authentication. However, as of March 24, 2025, filers may begin to enroll and file through the new dashboard. Also, as of March 24, 2025, compliance with the amended Form ID and submission of the Form ID (with supporting documentation) through the dashboard will be required for “new filers,” namely those filers that have not completed the process of obtaining password-based credentials under the legacy system by 10 p.m. ET on March 21, 2025. Existing filers (i.e., those that have completed the process by that time) will have until 10 p.m. ET on September 12, 2025, to comply with the changes using a simplified enrollment process. The simplified enrollment process will not require the submission of a new Form ID, a notarized power of attorney or other supporting documentation. During this transition period, existing filers may continue using the legacy filing process (i.e., their password-based access credentials) interchangeably with the EDGAR Next filing process.

To safeguard against any delays or glitches with the new system, a new filer that will be required to make an EDGAR filing on or soon after March 24 (e.g., a new fund launching on April 1 or May 1) should consider obtaining password-based access credentials under the legacy system by 10 p.m. ET on March 21 so as to become an existing filer and, thus, avail itself of the transition relief, including the simplified enrollment process.

To be prepared for the compliance deadline, current and prospective filers should consider:

• Obtaining Login.gov credentials. Each user must have Login.gov credentials in order to access EDGAR Next.
• Determining at least two account administrators for every filer or one account administrator for individual or single-member company filers. (Each filer may have up to 20 account administrators.)
• Coordinating with any individuals who have beneficial ownership reporting obligations with the registrant in question (e.g., Section 16 or Form 144 obligations). Directors who sit on a board of directors and file Forms 3, 4 and/or 5 will need to be enrolled in EDGAR Next and delegate filing authority to each public company with respect to which they file such forms and their filing agent/system.
• Although not required, it is prudent for each individual filer to have each public company with respect to which he or she reports be an EDGAR account administrator on his or her behalf.
• Coordinating with each relevant financial printer to discuss any applicable technological considerations.
• Ensuring that filing authority for each relevant CIK has been delegated to each applicable user, including any filing agent, such as a law firm or financial printer. Filing agents may request delegation directly from filers.
• Logging into the SEC’s EDGAR Next Beta system during the transition period to explore the EDGAR Next dashboard and process.
• Determining when any one registrant will enroll in EDGAR Next and when it will begin submitting filings through the new process.
• Watching the SEC’s EDGAR Next Webinars which are posted to the SEC’s YouTube channel.

1. EDGAR Filer Access and Account Management, Release No. IC-35343 (September 27, 2024) (Adopting Release). At times, this Dechert Newsflash tracks the Adopting Release without the use of quotation marks. Terms not defined in this Dechert Newsflash have the meaning assigned to them in the Adopting Release.
2. In the event that the U.S. Congress is unable to pass legislation for continued government funding, it is expected that many U.S. federal government agencies, including the SEC, may shut down on March 14, 2025 (“government shutdown”). While it is expected that SEC staff will be available to process Form ID requests and generate new EDGAR codes during a government shutdown, processing times may be delayed.