Preparing for EDGAR Next: Filer Transition Reference Guide
March 19, 2025
The launch of the SEC’s updates to EDGAR, collectively referred to as EDGAR Next, is now upon us. EDGAR Next will fundamentally change how filers (including public companies and individual Section 16 filers) manage and access their respective EDGAR accounts and make EDGAR filings.
EDGAR Next: What’s Different?
Under the legacy EDGAR system, each filer is assigned a set of confidential EDGAR access codes (the CCC, password, PMAC, and passphrase) to log in to and manage the filer’s EDGAR account. Filers use their CCC and password to file on EDGAR and share these codes with third parties who they have authorized to make filings on their behalf.
With EDGAR Next, each filer and each individual who files on a filer’s behalf will need to have their own EDGAR Next account and individual log-in credentials created through login.gov. Rather than sharing EDGAR access codes, filers will authorize individuals to file on their behalf by granting them specific roles on a new EDGAR Next dashboard. EDGAR Next includes features to allow filers to designate filing privileges to certain third parties, such as filing agents (e.g., financial service software providers, law firms, etc.).
EDGAR Next also includes updates to Form ID.
Key Dates for the EDGAR Next Transition
EDGAR Next and the new Form ID go live on March 24, 2025 and will be required for all new filers after that date.
Existing filers are expected to enroll their current EDGAR accounts in EDGAR Next (a process which does not require submission of a new Form ID) anytime between March 24, 2025 and December 19, 2025. Starting December 22, 2025, any existing filer who has not enrolled in EDGAR Next will be required to submit a new Form ID to regain access to the EDGAR system.
Filers will be able to utilize EDGAR Next to submit filings starting on March 24, 2025. Filers may also utilize the legacy EDGAR system through September 12, 2025. Starting September 15, 2025, all filings will need to be made through EDGAR Next.
To assist companies in planning their transition to EDGAR Next, we have prepared an EDGAR Next Filer Transition Reference Guide, which is available here.
This memorandum is a summary for general information and discussion only and may be considered an advertisement for certain purposes. It is not a full analysis of the matters presented, may not be relied upon as legal advice, and does not purport to represent the views of our clients or the Firm. Shelly Heyduk, an O’Melveny partner licensed to practice law in California; Robert Plesnarski, an O’Melveny partner licensed to practice law in the District of Columbia and Pennsylvania; Tai Vivatvaraphol, an O’Melveny counsel licensed to practice law in New York; Ashley Gust, an O’Melveny counsel licensed to practice law in the District of Columbia and New York; and Aliza Cohen, an O’Melveny resource attorney licensed to practice law in California, contributed to the content of this newsletter. The views expressed in this newsletter are the views of the authors except as otherwise noted.
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