EDGAR Next Is Now Live: What Should You Do Now?

Effective September 15, 2025, all U.S. Securities and Exchange Commission (SEC) filings must now be submitted through the SEC’s updated filing system, called “EDGAR Next.” This means that all SEC filers — whether a public company, an individual executive officer or director, a fund manager, or otherwise — must be enrolled in EDGAR Next in order to continue submitting filings to the SEC.

For those who have yet to enroll in EDGAR Next, it is still not too late: Existing filers may continue to enroll until 10 p.m. ET on Friday, December 19, 2025. Thereafter, anyone who seeks to make an SEC filing but has yet to enroll in EDGAR Next will need to submit a Form ID application to the SEC to enroll. Currently, SEC staff require an average of at least six business days to process a Form ID application — which could result in late filings if the application is not submitted sufficiently in advance of a filing deadline. Therefore, to avoid potential interruptions or late SEC filings, existing filers that have not yet enrolled should do so by the December 19 deadline.

Delegating Filing Authority and Requests for Delegation

Once enrolled in EDGAR Next, each filer’s existing account administrators may delegate filing authority to other individuals — as either additional account administrators or as “users” — as well as to other entities that have their own EDGAR accounts, as delegated entities. In addition, entities that have their own EDGAR accounts can request authority to file on behalf of another EDGAR filer as a “delegated entity.” For example, an individual who serves as a director on multiple boards and also manages an investment fund that makes its own SEC filings can delegate employees of the investment fund as account administrators and/or users and can also delegate the public companies on whose board he/she serves as delegated entities (and/or can delegate employees of those companies as account administrators or users) for his or her EDGAR account. Similarly, if the investment fund uses a financial printer or other third-party vendor to submit its SEC filings, such vendors will need to request authority to be delegated entities for the filer’s account.

Importantly, because all account administrators, users, and delegated entities are able to submit SEC reports on the filer’s behalf (and account administrators can make any/all changes to the account), it is important for a filer to recognize and trust all of the individuals and entities delegated with such authority for its EDGAR Next account. In addition, any entity with an existing EDGAR account is able to request such delegation. As such, upon receiving an invitation from a prospective account administrator, user, or delegated entity, the filer’s account administrators should confirm with the filer (and with any other account administrators) that such delegation is appropriate prior to accepting such requests.  

Annual Confirmation Is Required to Maintain Account Access

Under the new EDGAR Next system, each filer’s account administrators are responsible for maintaining the security of the EDGAR account and the accuracy of the filer’s information on EDGAR. Specifically, on an annual basis, account administrators are required to confirm that all of the filer’s information remains accurate, including that each of the account administrators, users, technical administrators, and delegated entities remains active and is still authorized to act on the filer’s behalf. This annual confirmation process serves to ensure that the filer is tracking who is authorized to submit SEC filings on its behalf, provides an opportunity for account administrators to confirm that the filer’s information remains accurate, and facilitates the removal of any individuals or entities no longer authorized to submit filings on the filer’s behalf.

As such, during enrollment in EDGAR Next, each filer is required to select the date by which it will complete this annual confirmation. The four options are March 31, June 30, September 30, and December 31. The SEC will also send automated notifications to the filer’s account administrators in advance of each annual confirmation deadline, as well as throughout the three-month grace period to complete the confirmation, in order to remind the account administrators to complete the annual confirmation.

Importantly, if no account administrator completes the annual confirmation by the end of the three-month grace period, the filer’s EDGAR Next account will be deactivated and the filer will no longer be able to submit SEC filings (or to otherwise access its EDGAR Next account) until a new Form ID application for renewed access to the account is submitted and accepted by the SEC. Once the SEC accepts that application for renewed access, the filer will have the same central index key (CIK), but the account administrators included on the application will need to re-invite any others account administrators, technical administrators, users, or delegated entities to renew their access to the filer’s account as well.

As noted, SEC staff currently require an average of at least six business days to process a Form ID, so it is imperative that each filer’s account administrators complete the annual confirmation process in a timely manner in order to avoid interruptions to the filer’s ability to timely file SEC reports.  

Filers also do not need to wait until the chosen annual confirmation due date to complete the confirmation. An account administrator may complete the confirmation during the quarter preceding the quarter-end that was selected as the confirmation due date — which, notably, will also change the next annual confirmation due date to the end of the quarter during which that earlier confirmation was completed. For example, if December 31 is the current confirmation due date for the account, but the annual confirmation is completed in August instead (i.e., prior to October 1, the start of the fourth fiscal quarter), then the filer’s annual confirmation for the following year would automatically change to September 30 (or the next business day, if that date falls on a weekend or SEC holiday).

If you have any questions concerning enrollment in EDGAR Next or managing an existing EDGAR Next account or would like assistance with the enrollment process, please contact SidleySection16Filings@sidley.com.