Effective September 15, 2025, any EDGAR account (CIK) not enrolled in EDGAR Next will be unable to submit filings. A three-month grace period, concluding on December 19, 2025, is provided for filers to enroll in EDGAR Next, but is only possible under certain conditions.  Filers who fail to enroll their CIK(s) by December 19th, or lack access to a valid EDGAR point of contact email address, will be required to file an amended Form ID.

As of August 2025, the processing wait time for new and amended Form ID is at least 1 to 2 weeks, and sometimes as long as a month, and is expected to increase after September 15th.

Scenario 1: The Filer has an accurate and valid email address as their EDGAR point of contact, but is not enrolled in EDGAR Next after September 15, 2025.

• • This is the best case scenario and the filer will be able to quickly enroll in EDGAR Next and recover the ability to submit filings, without the need for a notarized Form ID filing.
• • The filer will first need a login.gov account in order to access the EDGAR Filer Management dashboard.
• • If the Filer hasn’t updated their CCC or Passphrase since September 2019 or do not know either code, they should follow the steps described by the SEC and can watch this video for a demonstration of the process.  The existing CCC and Passphrase values can be reused - only the act of doing the reset process is required.
• • After updating the CCC and Passphrase, complete the enrollment process, either using the Workiva Enrollment application or manually on the Filer Management site
• • Once enrolled, the CCC associated with the EDGAR account will automatically be reset to a new value.  The original CCC may be restored using the Filer Management site, under the Manage CCC & Password section.
• • After enrolling, you may wish to delegate to the Workiva filing agent CIKs 0001628280 and 0001628279 in order to eliminate the need to manage your own Filer API Token and be able to utilize the File With Workiva feature.
• • After December 19, 2025, the filer will be required to file an amended Form ID to regain the ability to file. Until a CIK is enrolled, there is no workaround or alternative to be able to submit filings, including using File With Workiva or any by using any other filing agent.

Scenario 2: The Filer doesn’t know their CCC and/or Passphrase, lacks an accurate or valid email address as their EDGAR point of contact, and is not enrolled in EDGAR Next after September 15, 2025.

• • Prior to September 15th, a filer can log into https://www.edgarfiling.sec.gov/ and navigate to the Retrieve/Edit Data section, enter their (or their Reporting Owner’s) CIK and CCC, then go to Retrieve Filer Information, and click the Edit Company Information button at the bottom of the page.  Then they can continue with the Scenario 1 steps.
• • After September 15th, there is no way for an unenrolled account to modify the point of contact email address, and they will be forced to file an amended Form ID.

Scenario 3: The Filer has submitted a brand new or amended Form ID to create or regain access to their EDGAR account, but must file a report and the Form ID request is still pending

• • Rule 201(a) of Regulation S-T permits a filer who “experiences unanticipated technical difficulties preventing the timely preparation and submission of an electronic filing” to file, via Form TH - Notification of Reliance on Temporary Hardship Exemption on paper to the SEC, no later than one business day after the date on which the filing was to be made.
• • After delivery of the Form TH and paper copies of the report, in most cases, the filer has a maximum of 6 business days to submit the report via EDGAR.  The “Is a Paper Copy Confirmation” item on the Filer Information step of the filing wizard must be checked and the document labeling requirements noted in § 232.201 must be made when making the confirming copy submission.
• • It is unclear if this would be applicable in the case where a filer is unable to use EDGAR Next, but it is an option to consider with the approval of their legal counsel.  There are a number of requirements, both for the paper and electronic filings, so filers should carefully read and understand the entire 17 CFR § 232.201 regulation.
• • The regulation explicitly states that it may not be used for Form 3, Form 4, Form 5, Form D, or Form ID.
• • Although it wouldn’t be possible to electronically submit a CORRESP filing, the filer may also consider requesting a Continuing Hardship Exemption, as described here: https://www.sec.gov/submit-filings/filer-support-resources/how-do-i-guides/request-continuing-hardship-exemption

Scenario 4: A new Officer or Director has joined the company and must file their Section 16 report(s) but their Form ID is still pending

• • There are few good options in this situation and currently no specific guidance from the SEC on how to handle this scenario.  The EDGAR Business Office has acknowledged that Form ID delays are possible due to staffing shortages, but so far have not provided any relief or exemptions for filers impacted by these delays.
• • Rule 201(a) / Form TH mentioned in Scenario 3 explicitly states that it does not apply to Section 16 types, and the EDGAR system does not support the Confirming Copy flag for Section 16 filings.
• • Issuers may be required to report non-timely Section 16 filings on their annual and proxy reports.
• • Unless explicitly instructed by their legal counsel or the SEC, filers should not attempt workarounds such as filing a Section 16 report using the Issuer’s CIK for both the Reporting Owner and Issuer.  This is not compliant and may cause more work in the future to be corrected.
• • A filer may consider filing a CORRESP filing to document their reporting owner’s situation, record their issues in obtaining EDGAR access due to Form ID processing delays, and request a Continuing Hardship Exemption. See https://www.sec.gov/submit-filings/filer-support-resources/how-do-i-guides/request-continuing-hardship-exemption for more information.

Useful Links

• General EDGAR Next Information
• Workiva’s EDGAR Next Resources
• Enroll in EDGAR Next
• Prepare and File Form ID
• Obtaining login.gov Credentials
• EDGAR Filer Management Dashboard
• Reset Passphrase Instructions
• Passphrase and CCC Reset Video
• Workiva’s EDGAR Next Enrollment Application
• Manually Enroll on the Filer Management Dashboard
• Form TH - Notification of Reliance on Temporary Hardship Exemption
• Rule 201(a) of Regulation S-T
• 17 CFR § 232.201
• SEC Paper Filing Delivery Instructions
• Request a Continuing Hardship Exemption