Preparing for EDGAR Next

• Gregory Wiessner, Stephanie Leopold, Nickolas Andreacchi
• 2.18.2025

On March 24, 2025, enrollment for EDGAR Next will open. All EDGAR filers, including existing reporting entities, Section 16 reporting persons, and Section 13 filers, are required to transition to the new system by September 15, 2025.

The goals of EDGAR Next are to improve the security of, and modernize connections to, the SEC’s current Electronic Data Gathering, Analysis, and Retrieval system (“EDGAR”) and enhance filers’ abilities to manage their EDGAR accounts. For current and future users, EDGAR Next represents a significant change to the way users access and interact with the system, whether they access EDGAR directly or use self-service filing systems or third-party vendors.  It is important for EDGAR users to begin taking steps now to prepare for the transition.

As a technical matter, the changes, which were adopted by the SEC on September 30, 2024, will be reflected in the form of amendments to Rules 10 and 11 of Regulation S-T and Form ID. These changes will require filers to authorize and maintain individuals as account managers and take certain actions to manage their EDGAR accounts, as well as require account administrators and persons performing certain other roles to first obtain individual account credentials in accordance with the EDGAR Filer Manual prior to acting in such roles. Conforming edits are also being made to Volume I of the EDGAR Filer Manual. Additionally, optional application programming interfaces (“APIs”) will be offered to filers for machine-to-machine communication with EDGAR.

This client alert provides an overview of the upcoming changes and outlines the steps that filers should take now and in the near term for a smooth transition to EDGAR Next.

What’s changing?

The current EDGAR system provides each filer with a single set of access codes relating to that individual filer, whether it be a person or entity. Filers often share these codes with their filing agents, internal legal departments, outside law firms, broker-dealers, and other authorized third parties. Any party that possesses these access codes can use them to make EDGAR submissions on the filer’s behalf or to generate replacement codes. As a result, the current EDGAR system cannot identify which party used the access codes to submit a filing or generate replacement codes. This can raise security issues in the event of an unauthorized filing, and may create confusion if filers lose track of their access codes or the parties that possess them. The current EDGAR system also does not support machine-to-machine communication with EDGAR, leading filing agents to develop and operate their own platforms that may be less secure than supported interfaces would be.

EDGAR Next implements several changes. First, filers must authorize specific individuals to access and manage their EDGAR accounts within the EDGAR system. Each of these individuals must obtain individual account credentials, which will be used in tandem with multifactor authentication to log into the EDGAR Next website. Filers can assign different rights and responsibilities to these individuals by assigning them to specific groups. In addition, EDGAR Next will feature optional APIs to facilitate machine-to-machine communication with EDGAR.  Rather than relying on unsupported platforms operated outside of the EDGAR system, filers can utilize these EDGAR-supported APIs to reduce the need for manual input and more efficiently make submissions, retrieve information and perform account management tasks.

What steps should I take now?

The EDGAR Next dashboard goes live on March 24, 2025, but there are several steps that filers and their authorized parties can take now to prepare for the upcoming transition.

• Obtain individual account credentials. Each individual who makes submissions on behalf of an EDGAR filer or manages an EDGAR filer’s account or access codes–which may include individual filers as well as members of internal legal and/or compliance departments, outside law firms, and filing agents–should obtain individual account credentials at Login.gov, a secure sign-in service provided by the U.S. General Services Administration. These credentials are unique to each individual and cannot be shared across companies, law firms or filing agents. See “How to Obtain Individual Account Credentials” below for more information.
• Become familiar with the EDGAR Next dashboard. The SEC has created an EDGAR Next “adopting beta” website, which is a test version of EDGAR Next that filers can use to familiarize themselves with the new dashboard before the system goes live on March 24, 2025. The beta is for practice only; while the dashboard simulates the features and processes of EDGAR Next, it does not contain EDGAR account information and is not a substitute for the current EDGAR system. The beta can be accessed here using the individual account credentials described above.
• Compile EDGAR access codes. Each filer, along with any individuals who make submissions or manage EDGAR accounts or access codes on a filer’s behalf, should ensure that it has access to the filer’s current CIK, CCC and passphrase. Codes should be tested to confirm they are active. Filers that do not have a current CCC and/or passphrase should follow the instructions in the SEC FAQs at the link below to generate replacement codes. Additionally, the SEC staff has advised that it may require additional time to process new Form ID applications due to the expected increase in volume leading to the transition period; filers are advised to plan accordingly.
• Determine who will serve as the “enrolling party.” Beginning March 24, 2025, each filer will be required to complete a one-time enrollment process to enroll in EDGAR Next. Filers may enroll themselves or authorize another individual to do so on their behalf. Each filer should determine who will serve as its enrolling party and communicate this information to others who make submissions or manage EDGAR accounts or access codes on its behalf (including internal legal departments, outside law firms, filings agents, etc.) to prevent duplicative enrollment attempts. This is particularly important for Section 16 filers who are associated with multiple companies. The enrolling party’s only obligation is to complete the one-time enrollment process; the enrolling party will not have ongoing responsibility for the filer’s EDGAR account unless it is separately assigned to an ongoing role.
• Determine whom to designate as “account administrators.” As part of the enrollment process, the enrolling party must designate specific individuals as the filer’s “account administrators.” Account administrators will have ongoing responsibility for managing the filer’s account on the EDGAR Next dashboard or through optional APIs. Account administrators have the ability to make submissions, manage the other parties that have access to the filer’s account, delegate authority to others, generate new CCCs, perform a newly required annual confirmation of account information and serve as the point of contact regarding the filer’s account. Only two account administrators can be authorized during the enrollment process, but additional account administrators can be added after enrollment by using the EDGAR Next dashboard. After enrollment, each filer may have a maximum of 20 account administrators and a minimum of one account administrator (for individual filers, such as Section 16 reporting persons) or two account administrators (for entity filers). Filers should decide who will serve as their account administrator(s) and convey this information to the enrolling party ahead of the enrollment process. Individual filers are permitted but not required to act as their own account administrators.

What should I expect during the enrollment process?

Each filer’s enrolling party must complete the EDGAR Next enrollment process this year between March 24 and September 12. The process requires the enrolling party to (i) log into the EDGAR Next website using its individual account credentials, (ii) provide the filer’s CIK, CCC and passphrase and (iii) designate the filer’s account administrators by providing the name, email address, business address, and business telephone number for each account administrator. The enrolling party must also select the fiscal quarter in which the filer will complete a newly required annual confirmation, a routine process in which an account administrator confirms that the filer’s EDGAR Next account information is accurate and up to date. If enrollment is successful, a pop-up success message will appear, and the account administrators listed during enrollment will receive an email and a notification on the EDGAR Next dashboard that they are the account administrators for the filer. Existing filers will not be required to present a notarized document or power of attorney to enroll.

This enrollment process applies only to existing filers that obtained EDGAR credentials prior to March 24, 2025. New filers that submit a Form ID application on or after March 24, 2025, will be required to apply using an amended Form ID, which will require applicants to provide the information required by EDGAR Next at the Form ID application stage. 

What should I expect after the enrollment process?

The account administrators authorized during enrollment should set up the filer’s account on the EDGAR Next dashboard. They may designate additional account administrators, as well as individuals who will serve in other EDGAR Next roles for the filer. These roles include users (individuals that make EDGAR submissions), technical administrators (individuals that manage the technical aspects of APIs; filers that use APIs must designate at least two technical administrators), and delegated entities (other entities with their own EDGAR accounts, such as filing agents or issuers; upon designation, each of the delegated entity’s account administrators will be authorized to make EDGAR submissions on behalf of the filer).

Enrollment in EDGAR Next will automatically reset the filer’s CCC, which will continue to be required to make submissions. The CCC will be visible on the filer’s EDGAR Next dashboard after enrollment. Filers should therefore make sure that their account administrators add relevant individuals and/or delegate authority to relevant entities that file on their behalf immediately after enrollment, so that these parties can view the CCC and continue to make submissions without interruption.

How to Obtain Individual Account Credentials

You can obtain individual account credentials now by accessing the Adopting Beta EDGAR Filer Management page at https://filermanagement-bravo.edgarfiling.sec.gov/ and following the steps below:

1. Click on the box that says “Sign in with LOGIN.GOV” to be redirected to the Login.gov website.
2. Select “Create an account” and follow the instructions to enter your email address. You should provide the email address that you intend to use for all EDGAR purposes and use this same email address for all future EDGAR-related activities.
3. Click on the link in the email sent by Login.gov to confirm your account. You will be prompted to create a password and select a multifactor authentication model.
4. Once you’ve obtained individual account credentials, select “Agree and continue” to be redirected to the EDGAR Filer Management website.
5. Log in to the EDGAR Filer Management website using your individual account credentials and complete multifactor authentication.

If you encounter difficulties in obtaining credentials or signing in, you can seek assistance from Login.gov using the following methods:

• Access the online help center at https://www.login.gov/help/
• Submit a help desk ticket at https://www.login.gov/contact/
• Call the assistance line at (844) 875-6446 (24 hours a day, seven days a week)

Timeline and Additional Resources

• March 24, 2025: EDGAR Next opens for enrollment and the dashboard goes live.
• March 24, 2025-September 12, 2025: Filers enroll in EDGAR Next and set up their accounts on the dashboard. During this transition period, the EDGAR Next system will be available to enrolled filers, but filers will still have the option to make submissions using only their CCC and password.
• September 15, 2025: Compliance with EDGAR Next is required. Filers that have not enrolled in EDGAR Next will lose the ability to make submissions or take other actions in EDGAR, although they may still enroll in EDGAR Next until December 19, 2025. Thereafter, filers who still have not enrolled must apply for access to their existing EDGAR accounts by submitting the amended Form ID through the EDGAR Next dashboard.

The SEC has published a series of FAQs about EDGAR Next, which is accessible here.