Here’s an excerpt from this Cooley Alert by Beth Sasfai, Brad Goldberg, and Luci Altman that contains practice tips in the wake of the SEC’s new EDGAR Next (which we have already blogged about a few times):
“What should public companies do now to comply with Next?
- All individuals who make submissions on behalf of a company or its Section 16 officers and directors, or who manage their SEC codes, should obtain Login.gov account credentials well before March 24, 2025. This most likely will include members of the corporate secretary’s office and the financial reporting team.
- Take advantage of the beta environment to get familiar with the new dashboard. Login.gov credentials are required for access.
- Develop a process by which the company and its Section 16 officers and directors will authorize individuals to serve as account administrators. This could include powers of attorney from Section 16 filers or a less formal form of authorization. Once authorized, account administrators will be able to manage Section 16 filers’ EDGAR account on the dashboard, adding other account administrators, users and technical administrators and delegating authority to file, as needed.
- Update onboarding processes for new Section 16 officers and directors to include designating an account administrator(s) in the amended Form ID. Starting March 24, 2025, the amended Form ID becomes effective and must be submitted by an account administrator through the dashboard.
- Ensure central index keys (CIKs), CIK confirmation codes (CCCs), passphrases and passwords are current for the company and all Section 16 officers and directors. These EDGAR access codes will be needed to enroll each filer in the EDGAR Filer Management dashboard. Once enrolled, a new CCC will be generated. All EDGAR access codes under legacy EDGAR – including passphrases, passwords and password modification authorization codes – will be deactivated on September 15, 2025.
- Determine when the account administrator will enroll the company and Section 16 officers and directors in the new dashboard. For year-end companies, it is suggested to commence enrollment after the year-end reporting cycle is completed, but well before the September 15, 2025, compliance date.
- Determine which account administrator will be responsible for the annual confirmation and add the annual confirmation into year-end reporting processes.”
Authored by
Broc Romanek