SEC Transitions to EDGAR Next Filing System

Introduction

In late 2024, the U.S. Securities and Exchange Commission (SEC) adopted new rules implementing changes to its Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system. As a result of these changes, the EDGAR system, which is currently used by filers to submit reports and documents to the SEC, will soon be replaced by an updated system — EDGAR Next. The new filing system, EDGAR Next, will begin functioning on March 24, 2025. However, existing filers can continue using the previous EDGAR system until September 12, 2025, at 10:00 pm ET.

This Advisory discusses some of the new features of the upcoming EDGAR Next system and how filers can prepare for the EDGAR system change.

EDGAR Next: Major Changes

EDGAR Next has a series of new features aimed at enhancing the system’s security and improving a filer’s ability to manage its EDGAR account. These features include individual logins, multi-factor authentication requirements, account administrators and users, and application programming interfaces.¹

Individual Logins and Multi-Factor Authentication

Currently, each filer (whether a company, sovereign, individual, etc.) has its own EDGAR login credentials, and those were the only credentials that could be used to access EDGAR on each such filer’s behalf. With EDGAR Next, in addition to the filer’s login credentials, each individual authorized to file documents on behalf of the filer (e.g., investor relations personnel, filing agents, in-house counsel, external legal counsel) must also have his or her own account credentials, which are to be created through Login.gov, as discussed later in this Advisory. EDGAR Next will also employ multifactor authentication during the login process.

Account Administrators and Users

EDGAR Next’s new dashboard² will allow each filer to designate authorized users and administrators and manage its account. Filers will have to authorize specified individuals, including any internal personnel and external providers such as filing agents, financial printers, or legal counsel, to manage their EDGAR account as “Users” or “Account Administrators.”

Account Administrators will be able to grant filing authority and generate CCC codes.³ They also serve as the point of contact between EDGAR and the filer’s account and are required to confirm account information annually. The annual confirmation is also new and requires that the Account Administrator confirm the accuracy and currency of the filer’s EDGAR Next account information each year. All filers other than Section 16⁴ individual filers and single member companies⁵ must designate at least two and up to 20 Account Administrators. Section 16 individual filers and single member companies must designate at least one Account Administrator, although more are recommended.

Only individuals authorized by the filer’s Account Administrators will be able to make filings with the SEC on the filer’s behalf. Account Administrators can make filings without needing to be separately identified as Users and can perform other important functions, such as adding or removing additional Account Administrators and Users. Users can make submissions to the SEC on behalf of the filer. Filing agents, such as financial printers, will only be able to file on behalf of an issuer if an Account Administrator delegates filing authority to the filing agent through the EDGAR Next dashboard.⁶

Enrollment Process for EDGAR Next

To enroll in EDGAR Next, an existing filer, or an individual authorized by the filer, will first need to obtain individual account credentials through Login.gov. Login.gov is a secure government sign-in service that will allow individuals to obtain EDGAR credentials by inputting their email address and creating a password. This email and password will become that individual’s EDGAR credentials. When first obtaining individual credentials for EDGAR through Login.gov, each individual will also elect a multifactor authentication option.

With the Login.gov credentials, the individual can then navigate to the EDGAR Next website, click on the “Enroll” button and submit the filer’s current CIK, CCC, and passphrase.⁷ The filer will then designate Account Administrators and select the fiscal quarter in which its annual confirmation will be completed. The filer will also designate a point of contact and include a point of contact email address, which will be used by SEC staff to contact the filer. After these selections are made, each EDGAR filer point of contact and Account Administrator will receive a confirmation email. Upon a filer’s enrollment, EDGAR Next will automatically generate new CCC codes for the filer, but the Account Administrators will have the option to revert back to the old CCC codes.

This simple enrollment process for EDGAR Next will remain in place for existing filers until December 19, 2025. Beginning December 22, 2025, existing filers who have not yet enrolled in the new EDGAR Next system will instead have to follow the more onerous process of submitting a new Form ID with the SEC. The new Form ID will require additional information, such as the designation of Account Administrators, the filer’s Legal Entity Identifier (if applicable), and disclosure as to whether any individuals associated with the applicant have been criminally convicted, held civilly liable, or been administratively barred or suspended due to a violation of federal or state securities laws.

Next Steps for Existing Filers

Although EDGAR Next will not launch until the end of March 2024, existing filers can and should begin preparing now for the change.

Collecting EDGAR Credentials

One key way filers can already begin preparing for the change is by collecting and testing their current EDGAR codes (CIK and CCC) and EDGAR passphrase, as they will need those credentials to enroll in EDGAR. Each filer (or a person authorized by the filer) will also need to obtain individual account credentials for EDGAR through Login.gov.

Recovering EDGAR Credentials if Needed

If a filer does not have a record of its EDGAR credentials, those EDGAR credentials can be recovered through the current EDGAR Filer Management website.

To retrieve the EDGAR CCC, password, or password modification authorization code (PMAC), a filer must reset all three access codes simultaneously through the EDGAR Filer Management Website. The filer will need to input its CIK and EDGAR passphrase to generate updated access codes.

If a filer has lost or forgotten its EDGAR passphrase, there are two ways to reset it. The first is by submitting a request through the EDGAR Filer Management Website to have a security token sent to the filer’s EDGAR point of contact. EDGAR staff will then email the point of contact with a security token and a hyperlink which the filer can use to generate a new passphrase.⁸ If a filer cannot reset the passphrase through its point of contact, it is possible to manually update the passphrase by submitting a signed and notarized document to the SEC requesting the passphrase to be reset.

Filers should then test their credentials and passphrases to ensure they can successfully access EDGAR. Additionally, if the filer is a reporting company with subsidiaries or other affiliate entities, it should follow the same procedure for any entities for which the company makes filings. Similarly, a company making Section 16 filings for its directors and executive officers should also collect the EDGAR access codes and point of contact email addresses of each director and executive officer.

Familiarization With EDGAR Next

The SEC has made a beta version of EDGAR Next available. EDGAR Next beta allows filers with Login.gov credentials to familiarize themselves with the new dashboard before its official release.

Determine Account Administrators and Users

Filers should begin deciding which individuals within the organization will be designated as Account Administrators and Users. Filers should also select an Account Administrator to be in charge of the annual confirmation for the filer. Each individual who will serve as an Account Administrator or User will need to create his or her own EDGAR credentials through Login.gov. As part of the enrollment process, filers should be prepared to submit the name, Login.gov email address, business address, and telephone number for each Account Administrator and make a selection as to when the annual information confirmation will be done.

Ensure Filing Agents Are Transitioning to EDGAR Next if Applicable

Filers who intend to rely on filing agents (such as financial printers) to submit filings to the SEC should also coordinate with those agents to ensure they are prepared to transition to EDGAR Next in a timely manner.

Further, many U.S. domestic companies manage EDGAR submissions for directors and other Section 16 filers who may be directors of multiple public companies. It is therefore important for these companies to coordinate with each Section 16 filer, company, and filing agent that might be involved in the Section 16 filer’s EDGAR account or filing process to avoid confusion.

Conclusion

EDGAR Next will require filers to adapt to new security measures, particularly involving individual logins and multi-factor authentication, but it will also bring innovations aimed at streamlining the filing process. Filers should begin preparing now for the change by ensuring they have functioning Login.gov credentials and EDGAR codes and passphrases, which they will need to switch over to the new EDGAR Next system. Further, because Users and Account Administrators will play central roles in the filing process in EDGAR Next, filers should begin compiling a list of individuals within their organization who will fill those roles.

© Arnold & Porter Kaye Scholer LLP 2025 All Rights Reserved. This Advisory is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.