On September 27, 2024, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rules 10 and 11 of Regulation S-T, Form ID, and the EDGAR Filer Manual, concerning access to and management of accounts on EDGAR (EDGAR Next). According to the SEC, the amendments are intended to enhance the security of EDGAR, improve filers’ ability to manage and maintain access to their EDGAR accounts, facilitate the responsible management of filer credentials, and simplify the procedures for accessing EDGAR. As a practical matter, EDGAR Next will change how EDGAR accounts are managed and provide for individual traceability of EDGAR submissions.

In furtherance of these objectives, some of the key changes include:

• Mandatory use of Login.gov: To access a filer’s EDGAR account on the new EDGAR Filer Management dashboard (dashboard), individuals will need to obtain and use their individual Login.gov account credentials. Login.gov is a secure sign-in service of the U.S. General Services Administration, which requires multifactor authentication.
• Account administrators to manage filers’ accounts: Filers must authorize account administrators to manage their EDGAR accounts on the new dashboard. Individual (e.g., Section 16 officers and directors) and single-member company filers will be required to authorize at least one account administrator, and all other filers will be required to authorize at least two account administrators. One of the filer’s account administrators will be required to confirm annually that all information on the filer’s dashboard is accurate.
• Individual accountability and traceability: Individuals submitting filings on behalf of a filer must be authorized by the filer or the filer’s account administrators. If submitting a filing through a third-party filing service¹ (as most filings are), the individual submitting the filing will need the filer’s CIK and CCC, a filer token, as well as the individual’s unique user token, which the individual can generate on the dashboard. Passphrases, passwords, and PMACs will cease to exist under EDGAR Next.
• Amended Form ID: Form ID is being amended to include questions to identify account administrators and other information, and to add instructions to guide applicants through completion and submission of the form. The amended Form ID will be effective and required as of March 24, 2025, and will be required to be completed in the dashboard.

All current EDGAR filers will be required to enroll in EDGAR Next. This includes public and private companies, foreign private issuers, Section 16 filers, and Section 13 filers, among others. EDGAR Next will go live on March 24, 2025, and filers will be able to enroll beginning on that date using the filer’s CIK, CCC, and passphrase. To continue making submissions on EDGAR without interruption, existing filers must enroll no later than September 12, 2025. Through that date, filers will be able to continue to use their legacy EDGAR access codes and the legacy EDGAR submission process, even if they enroll prior to that date. After September 12, 2025, compliance with EDGAR Next will be required in order to make submissions on EDGAR.

The following shows the phase-in timing for EDGAR Next:

Dashboard Goes Live	Legacy EDGAR Ends	Compliance Required	Enrollment Ends
March 24, 2025	September 12, 2025	September 15, 2025	December 19, 2025
Enrollment opens for existing filers. Applicants for EDGAR access (i.e., new filers) must use amended Form ID.2 NOTE: Legacy EDGAR filing process will continue to be available through September 12, 2025, for new filers and existing filers, regardless of when filer enrolls.	Legacy EDGAR filing process ends at 10 p.m. ET.	To make submissions on EDGAR, filers must be enrolled in EDGAR Next or granted access on amended Form ID.	Final deadline for EDGAR Next enrollment. After this date, submission of amended Form ID required to request access to existing accounts.

The following are steps that existing filers should consider as they prepare to enroll in EDGAR Next.

1. Participate in the EDGAR Next Adopting Beta. Individuals who submit filings on a filer’s behalf should consider participating in the EDGAR Next Adopting Beta, available here. The Adopting Beta reflects the EDGAR Next changes including the new EDGAR Filer Management website and dashboard. Login.gov credentials are required to access the Adopting Beta. These credentials will carry forward and may be used to log into EDGAR during enrollment and thereafter when EDGAR Next compliance is required. All other information entered or obtained in the testing environment is for testing purposes only and will not carry forward when EDGAR Next goes live. The SEC’s EDGAR Business Office has published EDGAR Next Testing Guidance to assist individuals participating in the Adopting Beta test environment.
2. Gather CIK, CCC, and Passphrase. In order to enroll in EDGAR Next, the individual enrolling the filer will need the filer’s CIK, CCC, and passphrase. The passphrase differs from the password and was created when the filer first applied for EDGAR access. Please note that, according to the SEC, if the filer has not reset its CCC and/or passphrase since September 2019, the filer should reset these codes prior to enrolling. Prior to resetting the CCC, filers should ensure there is coordination with all filing agents who need access to EDGAR for the filer. In addition, consideration should be given to whether to ultimately reset the CCC back to the original CCC to ensure no EDGAR submissions are impacted. The SEC has provided instructions to reset the passphrase here and to generate a new and replacement CCC here.
3. Coordinate with Filing Services. Many of the filing services are closely monitoring EDGAR Next developments and making preparations to assist clients with the transition and going forward. Company filers may use more than one filing service. For example, some companies may use one filing service for periodic reports, but another filing service for proxy statements. In addition, the company’s Section 16 officers and directors may use a separate filing service from the company. We encourage you to reach out to your contacts at all relevant filing service(s) to discuss what services they may offer and to discuss how the filing process will change under EDGAR Next, which will vary by provider.
4. Coordinate with Brokers. Section 16 officers and directors, among others, are required to file Forms 144 if sales of the company’s securities reach certain thresholds. Coordination with these brokerage firms should be considered to ensure that they will remain able to submit these filings during the transition period and thereafter.
5. Coordinate with Other Public Companies on Which Officers/Directors Serve. To the extent Section 16 officers and directors serve in similar reporting roles at other public companies, coordination among those companies will be important in determining the process for enrollment and dashboard management and roles going forward.
6. Identify Account Administrators. Most filers are required to authorize at least two account administrators to manage their EDGAR account in the dashboard. Single-member companies and individual filers need only authorize one account administrator; however, we encourage these filers to authorize at least two account administrators in case one becomes unavailable. The role and responsibilities of account administrators include: 1) adding and removing account administrators, users, and technical administrators; 2) managing filing delegations; 3) user group creation and maintenance; 4) performing the annual confirmation of the filer’s EDGAR account; 5) serving as the filer’s point of contact with SEC staff for EDGAR account issues; and 6) serving as the point of contact for other individuals and delegated entities on the dashboard. Account administrators are also authorized to submit filings on behalf of the filer.

While these steps will assist in preparing for enrollment, we encourage you to reach out to your Wilson Sonsini attorney for more information and if you have questions relating to this transition.

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[1] When we refer to a third-party filing service, we are referring to filing services such as Broadridge, DFIN, Toppan Merrill, and Workiva.

[2] In certain limited circumstances, existing filers will need to use amended Form ID on or after March 24, 2025, including, for example, if they have lost electronic access to their existing CIK account or they are the legal successor of the filer named on the existing CIK account but did not receive access from that filer.