On the 2025 Agenda: How to Prepare for Updates to the SEC’s EDGAR Filing Platform

Background

On September 27, 2024, the Securities and Exchange Commission (SEC) adopted rule and form amendments to enhance the security and usability of its Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system. The changes, collectively known as “EDGAR Next,” arose after a 2021 SEC request for public comment regarding potential improvements to EDGAR filer access and account management. The new finalized rules, which amend Rule 10 and Rule 11 of Regulation S-T, amend Form ID, and update the EDGAR Filer Manual, address security concerns while streamlining the filing process. This modernization effort marks one of the most significant overhauls of the EDGAR platform since its inception.

Those most impacted by the new changes include public company and investment fund administrators, officers and directors with beneficial ownership reporting obligations, and filing agents, meaning entities “engaged in the business of submitting EDGAR filings on behalf of their clients.” Compliance is required by September 15, 2025, so all affected parties should take a proactive approach toward adopting the new system to ensure a smooth transition. 

What is EDGAR Next?

EDGAR Next represents a large-scale overhaul of the SEC filing process, impacting filing activities of an estimated 208,000 active filers. In the past, third-party individuals were able to make EDGAR submissions on behalf of an EDGAR accountholder using the accountholder’s access codes. As a result, access codes were often widely distributed, making it difficult for accountholders and the SEC to track which filings were submitted by which individuals. The codes also posed security vulnerabilities as they could be shared and utilized so easily and with so little oversight. The new changes aim to address these problems by enhancing security, improving efficiency, and streamlining management of the SEC’s filing process.

Summary of Changes Being Implemented in 2025

• Enhanced Account Security: To access an EDGAR account, all users will be required to obtain unique credentials through login.gov and use multi-factor authentication during login. Shared account access will now only be possible using unique identifiers, allowing each submission to be traced back to its respective filer.
• Delegation of Authority: Filers will now be able to delegate submission authority to any other EDGAR account. These “Delegated Users”—individuals or third-party filers with limited authority that may file on a filer’s behalf—will be subject to the same Account Administrator rules noted below and may make submissions on behalf of the filer (however, they will be unable to access the filer’s dashboard).
• Introduction of Account Administrators: Each filer must now designate at least two Account Administrators (or one for filers who are individuals) who bear responsibility for managing their EDGAR account. Account Administrators will be tasked with overseeing the account activity, ensuring filer information is accurate and current, carrying out annual confirmation requirements, adding or removing other Account Administrators, and adding Delegated Users to filers’ accounts.
• New Dashboard for Account Management: A new dashboard will allow Account Administrators to oversee their filers’ account activity, manage Delegated Users, and confirm access rights as needed. The dashboard will allow administrators to manage account information for more than one EDGAR account at once if need be, thus eliminating tedious and repetitive login processes.
• Annual Certification of Authorized Users: Account Administrators will be required to perform an annual certification that all individuals and entities reflected on the dashboard remain authorized to act on the filer’s behalf, ensuring continued accuracy and compliance.
• New Application Programming Interfaces (APIs): Filers will have the option to utilize any of 15 new APIs for direct integration with EDGAR. The APIs will allow outside software to interact with the EDGAR platform and perform dashboard tasks—including making submissions, checking submission statuses, and automating bulk filings—all without needing to access the EDGAR site manually. 

Timeline

Filers should heed several key dates, including a final compliance deadline of September 15, 2025, as the SEC rolls out EDGAR Next:

• 2024 and Q1 2025: Beta Environment: On September 30, 2024, the SEC introduced the EDGAR Next beta testing environment. Filers can now access the beta website for testing and feedback, as well as to gain proactive experience with the new system, though actual filings must still be submitted through the legacy platform. To access the beta environment, filers must acquire access credentials through login.gov and need not submit an amended Form ID.
• March 24, 2025: New Platform Goes Live: Filers will be able to submit filings through EDGAR Next. Submission of an amended Form ID will now be required.
• September 12, 2025: Legacy System Discontinued: The legacy platform will no longer be available for submissions.
• September 15, 2025: Compliance Deadline: Filers who have not enrolled in EDGAR Next by this date will no longer have access to any EDGAR filing system and will need to enroll in EDGAR Next to continue making filing submissions.

How to Prepare

Public companies should start taking action now to ensure as smooth a transition as possible to the new EDGAR Next platform by undertaking the following steps:

1. Identify those individuals who make submissions on behalf of the company or any of the Section 16 reporting persons within their organization, and ensure that those individuals obtain login.gov credentials ahead of the March 2025 launch.
2. Determine which individuals will act as Account Administrators, Users, or filing agents through the EDGAR Next dashboard. As noted, each individual filer will need at least one Account Administrator, and all other filers will need at least two.
3. Account Administrators will be charged with providing annual certifications, and should be tasked with oversight of enrollment efforts for the company and other individual filers within the company.
4. Ensure that all existing EDGAR filing information (CIK, CCC, passphrase) for the company and Section 16 filers is known and current, as this information will be needed to enroll on the new dashboard. Coordinate with other reporting companies who will also be undertaking filings for Section 16 reporting persons due to participation on multiple boards, etc.
5. Spend time within the EDGAR Next beta environment to gain familiarity with the new system.
6. Determine any changes needed for onboarding processes to align with the new EDGAR Next platform.