EDGAR Next: Annual Confirmations

In September 2024, the U.S. Securities and Exchange Commission (SEC) adopted new rules relating to access to, and management of, EDGAR accounts, including the required use of a new SEC filing platform, “EDGAR Next.” The EDGAR Next platform went live on March 24, 2025, and initial enrollment for existing EDGAR filers was required by September 15, 2025. As an ongoing compliance requirement, companies and other EDGAR filers, including directors, executive officers and greater-than-10% shareholders (“Section 16 insiders”), must complete annual EDGAR confirmations to maintain access to the EDGAR Next filing system.

Key takeaways

• Annual confirmation is mandatory. All EDGAR filers, including public companies and individual Section 16 insiders, must submit an annual confirmation through EDGAR Next.
• Annual deadlines. The confirmation must be completed by the end of filer’s designated annual confirmation quarter (i.e., March 31, June 30, September 30, or December 31). If the date falls on a weekend or SEC holiday, the deadline moves to the next business day. The filer’s current deadline is displayed on its EDGAR dashboard.
• Confirmations. As part of the confirmation process, reviewers should confirm that: 1) the individuals and entities listed on the filer’s dashboard (including account administrators, users and delegated entities) remain authorized to act on the filer’s behalf; and 2) the filer information shown on the dashboard is accurate.
• Account administrators may submit annual confirmations on behalf of filers. The filer does not need to complete the annual confirmation personally; any designated account administrator may complete it on the filer’s behalf.
• Early filing is permitted. Filers may submit the confirmation before the applicable deadline. However, submitting a confirmation in an earlier quarter will change the filer’s ongoing annual confirmation deadline to the end of that quarter in the following year.
• Grace period. Filers receive a three-month grace period after the deadline. During this period, the filer retains full EDGAR access and filing capabilities.
• Failure to confirm. If the filer fails to submit the annual confirmation by the end of the three-month grace period, the filer’s EDGAR account will be deactivated. The filer must then submit a new Form ID application, which requires notarization, to regain filing access. If the new Form ID application is approved, the filer will retain the same CIK/EDGAR account number, and historical filing records are preserved.

The annual confirmation process is straightforward; however, failure to submit a timely annual confirmation can ultimately result in loss of EDGAR filing access and lead to potential delayed and/or delinquent filings for both companies and their Section 16 insiders.

Next steps

To the extent not already completed, companies and Section 16 insiders should do the following:

• Review the annual confirmation deadlines for the company and each Section 16 insider.
• Confirm that account administrators are properly designated and have access to complete the confirmation.
• Consider calendaring reminders well in advance of each filer’s deadline.
• Verify that all users, administrators and delegated filing agents listed in EDGAR Next remain accurate and authorized. For certain Section 16 insiders, including individuals who serve as directors or executive officers of multiple public companies, completing the annual confirmation may require coordination with the other public companies and their filing agents to verify that all users, administrators and delegated filing agents listed on the individual’s EDGAR dashboard remain accurate and authorized.

For more detailed information regarding process, please see the SEC's guidance regarding annual confirmations.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.