On December 18, 2025, the Holding Foreign Insiders Accountable Act was signed into law, eliminating the Section 16(a) reporting exemption for Foreign Private Issuers (FPIs). This may impact your filing requirements and we’re here to help.

What This Means for You

By March 18, 2026, directors and officers of FPIs must comply with U.S. insider reporting obligations, including:

• Initial Filing: A Form 3 disclosing initial beneficial ownership is due by March 18.
• Ongoing Disclosure: Changes in ownership (Form 4) must generally be filed within two business days.
• Key Exception: These requirements do not currently extend to 10% shareholders of FPIs.

Recommended Next Steps

1. Identify Insiders: Determine which individuals qualify as directors or officers.
2. EDGAR Next: Ensure all existing insiders are enrolled with EDGAR Next or new/unenrolled users have applied for an EDGAR account. For guidance on the process, review Workiva’s guidance for initiating the process of registering for a CIK. Consider a US-based online notary as an option for Form ID validation. Due to process timing, we strongly recommend new EDGAR users have completed and submitted Form ID no later than Feb 16, 2026. 
3. Update Internal Policies: Review insider trading policies to support the rapid two-day filing window.
4. Assign Responsibility: Decide if the company or the individual will manage the filings.

How Workiva Can Help

Workiva is ready to support you through this transition. The Section 16 for SEC Reporting streamlines the form creation and filing process, ensuring you meet the new filing rules with confidence.

To get you started, we provide:

• Customer Success and 24/7 Support: Guidance to help navigate these new requirements and helpful tips while doing Section 16 filings.
• From Access to Filing: Unlocking Section 16: Training specifically designed to get you acclimated quickly.
• Guide to EDGAR Access, Form ID, and Getting a CIK

Reach out to your Customer Success contact for assistance with getting started.