It has been almost one year since the Securities and Exchange Commission (the “SEC”) adopted the amendments to Regulation S-T that paved the way for the updated EDGAR system, known as EDGAR Next. Enrollment onto EDGAR Next began on March 24th of this year, and we are almost halfway through the enrollment period!
Key Dates
Existing filers have until Friday, December 19, 2025 to complete their enrollment onto EDGAR Next. However, we are recommending that all existing filers enroll on or before Friday, September 12, 2025. After September 12th, existing filers who have not yet enrolled onto EDGAR Next will be required to enroll before submitting any filings on EDGAR. This delay may result in late filings—which could result in losing Form S-3 eligibility for a public company and unwanted proxy disclosure for public company insiders associated with filing a late Section 16 report.
If a filer does not enroll by the December 19, 2025 deadline, that filer will only be able to gain access to its EDGAR account, and submit filings on EDGAR, after it submits a new Form ID application. The Form ID will go through SEC review and may take several business days to be approved—resulting in potential filing delays.
Filers who first obtained EDGAR access on or after March 24, 2025 do not need to separately enroll onto EDGAR Next. EDGAR Next enrollment for a new filer is established once the SEC has approved that filer’s Form ID.
Enrollment Items
As noted in our prior Legalcurrent, in order for a filer to enroll onto EDGAR Next, the filer must have handy their CIK, CCC and passphrase. The SEC has stated that these codes must have been updated prior to September 2019 in order to enroll. In addition, the filer will need to identify (1) the individual or entity (such as a third party filing agent or law firm) who will enroll the filer onto EDGAR Next, and (2) the individual(s) who will serve as the filer’s EDGAR account administrator. Corporate filers must have at least two account administrators and an individual filer must have at least one account administrator, although two is recommended for continuity purposes. Account administrators are required to have credentials on Login.gov in order to access the EDGAR Next dashboard.
Permissions in EDGAR Next
A common question we’ve fielded in this process is what the different permission levels on EDGAR Next mean. Here is a breakdown of the permissions that can be granted to each type of EDGAR Next user:
Communication is Key
Those who use a third party filing agent to file on EDGAR will need to communicate with their agent to determine how to delegate filing permission to such agent. Typically, a filer can list their filing agent’s CIK in the “delegated entity” section of the filer’s EDGAR Next dashboard. This delegation to the filing agent will allow the agent to continue submitting on the filer’s behalf once EDGAR Next’s new filing procedures take effect on September 15, 2025. We encourage filers to coordinate with their filing agents to confirm the appropriate delegation process.
For individual filers who sit on multiple public company boards, it will be important to collaborate with each company in order to (1) determine which company will be responsible for enrolling the filer onto EDGAR Next, (2) delegate appropriate filing access to each company, and (3) confirm which company will handle the filer’s annual EDGAR certification.
If you have questions about enrollment onto EDGAR Next, please contact a member of Harter Secrest & Emery’s Securities and Capital Markets group.