EDGAR Next also introduces the concept of designated individuals who are delegated filing and account management powers by filers.

In September 2024, the Securities and Exchange Commission (SEC) adopted a final rule upgrading the filer account and account management systems of its online submission system, EDGAR (electronic data gathering, analysis and retrieval), through the introduction of EDGAR Next. The EDGAR Next system replaces the existing EDGAR filer management system and is intended to provide EDGAR filers with improved access and ability to manage their EDGAR filer accounts, while also increasing the overall security of the EDGAR system. Filers should take action before September 15, 2025.

On March 24, 2025, EDGAR Next went live and became available for enrollment by EDGAR filers. Although filers may continue to use the legacy EDGAR filing and online forms websites until September 15, 2025, the SEC is encouraging all EDGAR users to complete enrollment with EDGAR Next prior to that date.

Who Does This Change Apply To?

Each person who makes filings with the SEC on EDGAR will be required to enroll in and use the EDGAR Next system. Such persons include SEC reporting companies, reporting company insiders subject to Section 13 or Section 16 beneficial ownership disclosure obligations, third-party filing agents and legal printers and individuals who assist others with their EDGAR filings.

How Has EDGAR Access Changed?

Prior to the introduction of EDGAR Next, filers accessed the EDGAR filer management system and made submissions using a series of codes provided by the SEC. A filer would need to maintain records of a central index key (CIK) and its corresponding confirmation code (CCC), password, passphrase and password modification authorization code in order to access EDGAR filer resources and make submissions. With the introduction of EDGAR Next, the SEC is moving away from the use of EDGAR codes. Instead, each person who makes filings on EDGAR, either as a filer or on behalf of a filer, or accesses the filer management system must have an individual Login.gov account. This account, which is used by many other U.S. government websites and services, enhances security by requiring multifactor authentication, while the individual nature of the account allows for identification of each person who makes an EDGAR filing.

EDGAR Next also introduces the concept of designated individuals who are delegated filing and account management powers by filers. Upon enrollment in EDGAR Next, each filer will be required to identify individuals who will serve as account administrators for the filer, along with any users or delegated entities that will be permitted to make filings on the filer’s behalf. Under the legacy EDGAR system, any person with access to a filer’s EDGAR codes could make filings on the filer’s behalf. The EDGAR Next system is designed to improve security by requiring filers or their designated account administrators to affirmatively delegate the power to file on the filer’s behalf to specified individuals or entities, and such delegation can be revoked at any time.

EDGAR Next Roles and Delegations

Account Administrators

As part of the EDGAR Next enrollment process, each filer will be asked to designate account administrators who will be authorized to manage the filer’s EDGAR account. Typically, two account administrators must be designated, but filers who are individuals or sole shareholder companies are only required to designate a single account administrator. Following enrollment, filers are able to designate up to 20 individuals in total to serve as account administrators, each of whom must have their own individual Login.gov account.

Account administrators are provided full access to a filer’s account and are responsible for, among other things, managing the account, annually confirming that the authorizations and delegations under the account remain accurate, and maintaining up-to-date information regarding the filer on the EDGAR Next system. Each account administrator is also authorized to make filings on behalf of the filer, designate additional account administrators and delegate filing authority to users and delegated entities.

Users

Enrolled filers may designate individuals as users, who are then authorized to make EDGAR submissions on behalf of the filer.

Delegated Entities

Any account administrator may designate one or more other EDGAR accounts to file on the filer’s behalf. EDGAR accounts designated as delegated entities are typically filing agents, issuers for which the filer is an insider or financial printers. Once an EDGAR account is designated as a delegated entity, its own account administrators may authorize other individuals within the delegated entity to make filings on the filer’s behalf.

How Does EDGAR Next Enrollment Work?

Existing EDGAR filers must complete the EDGAR Next enrollment process. This process allows EDGAR filers to transition to EDGAR Next without providing the SEC staff with any Form ID, notarized documents or power of attorney. Enrollment is typically effective on the date of submission.

Filers do not need to complete the enrollment process themselves. Any person with a Login.gov account can enroll a filer on the filer’s behalf, as long as the enrolling person has the filer’s EDGAR codes and identities of the account administrator or administrators.

What Information Is Needed for Enrollment?

Each person enrolling a filer for EDGAR Next will need:

• An individual Login.gov account, which can be created at that same website;
• The filer’s existing EDGAR codes; and
• The Login.gov email accounts of the persons identified to serve as account administrators for the filer.

It’s important to note that if a filer’s central index key confirmation code and passphrase haven’t been used since before September 2019, these codes will need to be renewed prior to enrollment. The SEC has also created a new website for EDGAR Next enrollment.

Key Enrollment Dates

September 15, 2025

Prior to this date, filers may continue to use their legacy EDGAR filing codes to access the system and make filings using their legacy codes. After September 15, 2025, filers who have not completed EDGAR Next enrollment will be unable to make EDGAR filings or access their accounts until they have completed enrollment.

December 19, 2025

EDGAR Next enrollment ends at 10:00 p.m. on December 19, 2025. After this date, any filer that has not enrolled in EDGAR Next will not be able to file on EDGAR or otherwise access their accounts until and unless they submit a Form ID to the SEC and are granted access by the SEC staff. Individuals identified on the Form ID as account administrators for the filer will be required to have individual Login.gov credentials. The legacy EDGAR system will be deactivated December 22, 2025.

For More Information

If you have any questions about this Alert, please contact Darrick M. Mix, J. Blake Hovander, any of the attorneys in our Capital Markets Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.