EDGAR Next Is Here

At a Glance

• The EDGAR Next dashboard went live on March 24, 2025, and will become mandatory for all entities and individuals in September 2025.
• Individual filers can work with existing advisors and generally should not expect to need to perform their own enrollment.
• Appropriate, comprehensive pre-enrollment coordination will ensure a smooth transition.

As we noted in our proxy season seminars in December and January, the U.S. Securities and Exchange Commission has amended its filer access and account management requirements for its Electronic Data Gathering, Analysis and Retrieval (EDGAR) platform. The new dashboard, “EDGAR Next,” is set to become mandatory for all entities and individuals in September 2025.

EDGAR Next Dashboard is Live

On Monday, March 24, 2025, the EDGAR Next dashboard went live, and two changes took effect:

1. Entities and individuals with existing EDGAR accounts may, but are not yet required to, transition to the new EDGAR Next dashboard, a process that the Commission is calling “enrollment.”
2. All new EDGAR applicants (i.e., persons or entities without an existing CIK) must use the amended Form ID via the EDGAR Next dashboard to request credentials.
   Any pending Form ID that was not accepted by the SEC before 10:00 p.m. ET, Friday, March 21, 2025, must be re-submitted using the new form and dashboard. See the SEC’s updated guidance on preparing and submitting Form IDs for additional information on how to prepare and submit the revised Form ID and establish a new EDGAR filer account.

Legacy EDGAR Filing Methods and Code Reset Methods Will Remain Active

Pre-existing methods for filing will remain in place, even if an EDGAR account has been enrolled in EDGAR Next. This means that existing EDGAR filers (and their agents) can continue to use CIK and CCC or CIK and password combinations to electronically submit filings to the SEC in the same manner(s) they have used previously. Most legacy EDGAR websites and filing methods are expected to remain online until enrollment closes in September 2025. 

Based on informal discussions with the SEC Staff, until December 19, 2025, filers (and their agents) will continue to be able to change the point of contact information and reset EDGAR codes via the legacy filing website prior to enrollment in EDGAR Next. See “Understand and Utilize EDGAR CIKs, Passphrases and Access Codes and Guide to Obtaining a New Passphrase.

Preparing for Eventual Enrollment

Because legacy filing methods will remain active, it is not necessary for filers to feel pressure to complete EDGAR Next enrollment rapidly after March 24, 2025. Instead, it is vitally important for filers (and their current/prospective account managers) to coordinate with any others who may be affected by enrollment well in advance of any intended enrollment date (between March 24, 2025, and September 12, 2025).

Before attempting enrollment, an existing SEC filer (or whomever has been managing the filer’s account to date) should confirm that:

1. The filer’s EDGAR Codes (see detailed descriptions below) are all known and current
2. The existing EDGAR Codes will not expire before the earlier of the intended enrollment date or September 2025

If either of the foregoing are false, then we recommend performing a reset of the filer’s codes as soon as possible to minimize disruptions in the ability to prepare and submit filings. If a filer is associated with multiple issuers, then it is important to warn any other persons who file on the filer’s behalf before the reset is applied and also promptly inform those persons of the new credentials.

However, so long as both A and B are true, the filer (or the filer’s agents) should be able to continue to file using legacy methods and eventually complete EDGAR Next enrollment before September 2025. 

How and With Whom Should We Be “Coordinating”?

Before completing enrollment, filers (or the filers’ agents) should endeavor to communicate with all other persons who have (or in the future may) prepare or submit EDGAR filings on behalf of the applicable CIK. This includes other issuers, brokers and vendors. Important coordination topics include:

• Which one individual will be completing enrollment for the applicable CIK?
• What is an ideal enrollment date to avoid conflicts with expected filings?
• Who will be set up as initial account administrators, users, delegated entities or technical administrators?
• What quarter-end will be selected for the annual confirmation required by EDGAR Next?

Because completion of EDGAR Next enrollment is expected to automatically reset the CCC for the applicable CIK, each party who relies on the CCC will need to be informed of the new CCC or — if set up as an administrator, user, or delegate for the affected CIK — view the new CCC through their own access via the EDGAR Next dashboard. 

In the absence of an individual filer expressing a preference for who enrolls or maintains their account, parties may not readily agree who should take on those roles. In such cases, we recommend first deferring to the filer’s primary employer (if the employer has a CIK), and then breaking any remaining ties by deferring to whichever party is associated with the earliest Form 3 or other initial public filing with the SEC.

What Do You Mean When You Say “EDGAR Codes”?

• Central Index Key (CIK) – A unique public number used to identify a filer. It does not expire or change. A CIK is required to complete enrollment.
• CIK Confirmation Code (CCC) – An eight-character code used in conjunction with a CIK to verify a filer account. Depending on the legacy filing method, including via most third-party vendors, it is possible to submit a filing with only the CIK and CCC. The CCC does not expire but can be changed/reset. A CCC is required to complete enrollment.
• Passphrase – A separate eight-character security code that is used with a CIK to generate new EDGAR access codes. This value is assigned during the EDGAR application process. The passphrase does not expire but can be changed/reset. A passphrase is required to complete enrollment.
• Password – A password that is distinct from the passphrase and is used with a CIK to log in to the EDGAR filing website. It is possible to submit a filing with only the CIK and password via the EDGAR Filing Website. The password expires 12 months after it was created or was last changed. A password is not required to complete enrollment.
• Password Modification Authorization Code (PMAC) – An eight-character code that allows changes to EDGAR passwords via the EDGAR Filer Management website. A PMAC is not required to complete enrollment.

I Want to Know More!

The SEC staff are seeking to minimize disruptions that filers may experience during the transition to EDGAR Next. If there are questions about a particular filing situation, it is possible to contact SEC Filer Support at +1 202 551 8900, Option #2.

The following resources, in most cases published directly by the SEC, are available for additional reference.

• EDGAR Next–Improving Filer Access and Account Management
• EDGAR Next Small Entity Compliance Guide
• Enroll in EDGAR Next
• Enroll in EDGAR Next–Individual/Section 16 Filers Guidance
• EDGAR Next Frequently Asked Questions
• Obtain Login.gov Individual Account Credentials
• Guide to Obtaining a New Passphrase

The Faegre Drinker team is prepared to assist both existing and new filers with the EDGAR Next transition, including code resets and preparations for enrollment. We will continue to collect information regarding the SEC’s transition to EDGAR Next, including experience with the dashboard, early enrollers and new filing methods, and we intend to report any further useful information or rising best practices as we identify them.