TheCorporateCounsel.net

In case you’ve forgotten, EDGARNext goes live on March 24, 2025 (okay, I know that’s not exactly the Ides of March but indulge me). Filers will be able to use the current platform until September 15, 2025. At that point, existing filer codes will be deactivated, and filers will need to enroll in EDGARNext in order to make future filings. This Hogan Lovells memo outlines what filers need to do in order to transition to EDGARNext, and this excerpt addresses the actions companies should take in preparation for the new filing regime:

– Obtain Login.gov credentials. All individuals who make submissions on behalf of a company or Section 16 filers, or who manage the EDGAR accounts/access codes of those filers, including anyone who will be in charge of enrolling filers in EDGAR Next, should obtain Login.gov account credentials. Login.gov account credentials may be obtained now.

– Take advantage of the EDGAR Next beta. Become familiar with the new dashboard. Login.gov credentials are required for access.

– Collect current EDGAR access codes. Maintain a running list of all current CIKs, CCCs, and passphrases to ensure smooth enrollment. Check to make sure you have the codes of the company and any Section 16 filers for which the company is responsible for, and confirm that the codes work.

– Identify individuals who will serve in various roles. Decide who will serve as Account Administrators and Users for the company and any Section 16 filers for which the company provides filing support. Companies commonly manage EDGAR submissions for Section 16 filers who are directors of more than one public company, so those companies and the Section 16 filer will need to coordinate to determine who is going to enroll the filer in EDGAR Next once it goes live and who will serve as Account Administrator(s).

– Annual Confirmation. Determine which Account Administrator will be responsible for the annual confirmation discussed above.

– Coordinate with filing agents. Coordinate with any filing agents you use to ensure that the filing agent is implementing appropriate processes in connection with the EDGAR Next transition.

– Update onboarding process to account for Form ID. After March 24, 2025, any new Section 16 filers that need EDGAR codes will need to designate who will serve as Account Administrator(s) and provide certain other information (e.g., information regarding history of past securities law violations and good standing) via the new Form ID.

Also, be sure to check out the EDGARNext page on the SEC’s website. The EDGAR Business Office has done several informative webinars addressing EDGARNext and the enrollment process for issuers and individual filers. Replays of those presentations (together with downloadable slide decks) are available on that page.

– John Jenkins