EDGAR Next Transition Alert: Are you ready for 2025?

A. Timeline

1. March 24, 2025: EDGAR Next goes live.
2. March 24, 2025 until September 12, 2025: The SEC will maintain a hybrid model in which both the current EDGAR platform and the EDGAR Next platform will be running simultaneously.
3. September 15, 2025: Existing EDGAR codes will be deactivated, and filers may not make filings with the SEC until they have enrolled in EDGAR Next.
4. December 19, 2025: Enrollment of existing filers in EDGAR Next ends.
5. December 22, 2025: New filers (as well as existing filers who have not yet enrolled in EDGAR Next) will need to submit a new Form ID to access EDGAR Next.

B. Key changes

1. Authorized Individuals: EDGAR Next will require filers to authorize specific individuals (e.g., members of the financial reporting team, in-house legal team, filing agents) to manage their EDGAR accounts as an “Account Administrator” or a “User,” and each authorized individual will need to have his or her own account credentials (which may not be shared) to log into EDGAR Next. This will allow the identification of the individual submitting a filing on behalf of a filer. Under the current EDGAR platform, filers have one set of account credentials that anyone can use.
2. Individual Credentials: Each individual authorized to manage filers’ EDGAR accounts or to make filings will need to obtain Login.gov credentials to access EDGAR Next. Login.gov credentials may be obtained by visiting the site, clicking on “Sign in with Login.gov,” selecting “Create an account” and responding to the applicable prompts, including establishing a form of multifactor authentication. Login.gov account credentials may be obtained now.
3. Account Administrators: Each filer will also need to designate “Account Administrators” via EDGAR Next. Individual filers (e.g., Section 16 filers) must authorize and maintain at least one Account Administrator, and all other filers (e.g., companies) must authorize and maintain at least two Account Administrators. Account Administrators have the power to: (i) delegate filing authority to others; (ii) generate custom central index confirmation codes (CCCs); (iii) perform the newly required annual confirmation of account information; and (iv) serve as the point of contact regarding the filer’s account.
4. Users: Account Administrators may delegate others as “Users” who can make submissions on behalf of a filer. To make a filing on behalf of a filer, an individual will need to be authorized as a User, sign into EDGAR Next with his or her own Login.gov credentials, and enter the filer’s central index key (CIK) and CCC.

C. Enrollment process for existing filers

1. Existing filers are not required to submit a new Form ID; instead, such existing filer or existing filer’s authorized individual will, after obtaining login.gov credentials, navigate to the EDGAR Next website once it goes live on March 24, 2025, click on the “Enroll” button, and then submit the filer’s current CIK, CCC, and passphrase.
2. The enrolling person will designate the filer’s Account Administrator(s).
3. The enrolling person will designate the fiscal quarter in which “annual confirmation” for the filer is to be completed. The annual confirmation is a straightforward process in which an Account Administrator confirms that the filer’s EDGAR Next account information is accurate and up to date.
4. Once enrollment is complete, a notification will be sent via e-mail and through the EDGAR Next dashboard to the current EDGAR point of contact for the filer, as well as the newly designated Account Administrator(s). Additionally, EDGAR Next will automatically generate new CCC codes for each filer. Account Administrators have the option to revert those new CCC codes back to the old codes.
5. Enrollment of existing filers will end on December 19, 2025. Beginning December 22, 2025, existing filers who did not participate in the enrollment process will need to submit a new Form ID.

D. Section 16 filers

1. Section 16 filers do not need to create their own login.gov credentials for EDGAR Next unless they plan on accessing EDGAR Next to make their own filings, or unless they want to be designated as an Account Administrator for their own EDGAR Next profile.
2. Section 16 filers only need login.gov credentials if they will be personally accessing EDGAR Next.

E. Next steps

1. Obtain Login.gov credentials. All individuals who make submissions on behalf of a company or Section 16 filers, or who manage the EDGAR accounts/access codes of those filers, including anyone who will be in charge of enrolling filers in EDGAR Next, should obtain Login.gov account credentials. Login.gov account credentials may be obtained now.
2. Take advantage of the EDGAR Next beta. Become familiar with the new dashboard. Login.gov credentials are required for access.
3. Collect current EDGAR access codes. Maintain a running list of all current CIKs, CCCs, and passphrases to ensure smooth enrollment. Check to make sure you have the codes of the company and any Section 16 filers for which the company is responsible for, and confirm that the codes work.
4. Identify individuals who will serve in various roles. Decide who will serve as Account Administrators and Users for the company and any Section 16 filers for which the company provides filing support. Companies commonly manage EDGAR submissions for Section 16 filers who are directors of more than one public company, so those companies and the Section 16 filer will need to coordinate to determine who is going to enroll the filer in EDGAR Next once it goes live and who will serve as Account Administrator(s).
5. Annual Confirmation. Determine which Account Administrator will be responsible for the annual confirmation discussed above.
6. Coordinate with filing agents. Coordinate with any filing agents you use to ensure that the filing agent is implementing appropriate processes in connection with the EDGAR Next transition.
7. Update onboarding process to account for Form ID. After March 24, 2025, any new Section 16 filers that need EDGAR codes will need to designate who will serve as Account Administrator(s) and provide certain other information (e.g., information regarding history of past securities law violations and good standing) via the new Form ID.

Authored by Steve Abrams, Steve Nicolai, Amanda Brown, Tyler Glass, and Kayvon Paul