Filing PDFs in EDGAR can present some challenges due both the SEC's requirements on the format and contents of the PDFs, and how EDGAR handles the PDFs during submission. Below is some information on the requirements and process, as well as information to Flatten a PDF and avoid issues.
Unofficial and Official PDF Documents
For most SEC form types, PDFs may be filed but are considered Unofficial Documents also commonly referred to as “courtesy documents”. As described in the EDGAR Filer Manual Volume 2, section 188.8.131.52 , a PDF may be filed alongside the official HTML document, using the same exhibit label as the HTML document.
There are some form types and exhibits where PDFs are considered Official Documents, which are listed in the EFM Volume 2, section 184.108.40.206. The annual “glossy” reporting requirement on Form ARS or Exhibit 99 on Form 6-K, and Exhibit 96 on Form 10-K or Form 20-F are common examples.
Note: For both unofficial and official PDFs, they must adhere to the rules outlined in the EDGAR Filer Manual Volume 2, Section 220.127.116.11, in that they must not contain forms, hyperlinks, or scripting but must contain searchable text. If there are errors found in a PDF during filing it will either strip the PDF from the filing, as is the case for Unofficial Documents, or suspend the filing entirely in the case of Official Documents.
Common PDF Error Messages
- INVALID_PDF_TAG - this error indicates that EDGAR believes that the PDF contains forms, hyperlinks, or scripting.
- EMPTY_DOCUMENT - this error occurs when a PDF is submitted with only images, i.e there is no selectable text.
- INVALID_UNOFFICIAL_PDF - this error indicates that the PDF is not considered as an official document and there is no official document with the same exhibit label.
The SEC also provides the following document to explain PDF issues and possible resolutions.
Note: Errors in "unofficial" PDFs will be stripped but the rest of the filing is accepted, whereas errors with "official" PDFS will result in a suspended filing.
Workiva’s Flatten PDF Feature
In order to address PDF issues, we have added the Flatten PDF feature. This feature is available on the Collect Step, in the menu next to the PDF file:
In addition to the menu, after submitting a filing, when a PDF related EDGAR error message is detected, an option to flatten that PDF is provided.
The Flatten PDF feature offers two levels of PDF processing—Basic and Comprehensive.
- Basic removes the prohibited PDF items as described in the EDGAR Filer Manual in the least invasive manner.
- Comprehensive performs the same processing as Basic, but in addition it rebuilds the PDF in order to better pass the EDGAR validation checks, and for this reason it is recommended for most documents
In addition, there are Advanced Options in the Flatten PDF feature, including a Insert Blank Page option, which will add a page of white text on a white background in a specified location in your document.
- If after you receive an EMPTY_DOCUMENT error, your best option is to go back to whoever produced your PDF and obtain a document which contains selectable text. If you are unable to obtain such document, you can consult with your legal department to determine if this is a suitable option in your situation, you may consider the Insert Blank Page option under the Advanced Options section.
We recommend filers always visually verify their PDF after it has been flattened to ensure there are not artifacts or unexpected changes.
After flattening, you may download and review the PDF in the Collect step menu, the Review step, and in the Test Filing Preview.
Should you need any assistance along the way, please reach out to Workiva Support.