Reminder for EDGAR Account Administrators: Complete the Annual Confirmation Process

All EDGAR accounts that submit U.S. Securities and Exchange Commission (SEC) filings must be enrolled in the SEC’s updated filer management system, called EDGAR Next.

Under the EDGAR Next system, each filer’s account administrators are responsible for maintaining the security of the filer’s EDGAR account and the accuracy of the filer’s information on EDGAR. Specifically, on an annual basis, an account administrator must confirm on the filer’s EDGAR Filer Management dashboard that all identified users, account administrators, technical administrators, and delegated entities remain authorized by the filer to act on its behalf.

If none of the filer’s account administrators complete the annual confirmation process within a three-month grace period after the deadline, the filer’s EDGAR account will be deactivated and the filer will be unable to submit SEC filings until it submits a new Form ID application and the SEC accepts that application.

Assignment of Annual Confirmation Due Date

When a filer submits a Form ID application (whether to establish a new EDGAR account or restore access to an existing EDGAR account), the filer is assigned an annual confirmation due date corresponding to the quarter-end date of the quarter in which their Form ID application is accepted: March 31, June 30, September 30, or December 31. For example, if an EDGAR filer’s Form ID application was accepted in September 2025, their annual confirmation due date would be September 30 (i.e., the quarter-end date of the quarter in which their EDGAR account was created or restored).¹ The due date for the filer’s annual confirmation is displayed at the top of the filer’s EDGAR Filer Management dashboard.

Completion of Annual Confirmation

Beginning six weeks prior to a filer’s annual confirmation due date, EDGAR will send the filer’s account administrators reminder emails regarding the upcoming deadline.

Any of the filer’s account administrators may complete the annual confirmation, and only one account administrator is required to do so.

The annual confirmation must be completed by the annual confirmation due date or within the three-month grace period thereafter.

The SEC has a dedicated webpage with step-by-step instructions on how to complete the annual confirmation (accessible here).

Failure to Complete Annual Confirmation Results in Deactivated Account

If no account administrator completes the annual confirmation by the end of the three-month grace period following the annual confirmation due date, the filer’s EDGAR account will be deactivated and the filer will no longer be able to submit SEC filings to EDGAR (or to otherwise access its EDGAR account) until the filer submits a Form ID application for renewed access to the account and the SEC accepts the application. Once the SEC accepts the 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 reinvite any other account administrators, technical administrators, users, and delegated entities to renew their access to the filer’s account as well.

The SEC staff currently require an average of four business days (excluding federal holidays) to process a Form ID, so it is imperative that each filer’s account administrators complete the annual confirmation process in a timely manner to avoid interruptions to the filer’s ability to timely file SEC reports.

Filers do not need to wait until the 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 or assigned 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 questions concerning the annual confirmation requirement or managing an existing EDGAR account, or would like assistance with the submission of a Form ID application, please contact SidleySection16Filings@sidley.com.

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¹ Filers with existing EDGAR accounts that enrolled in EDGAR Next prior to December 22, 2025, were permitted to select one of four annual confirmation due dates at the time of enrollment.