What is delegation and why does Workiva recommend that I perform it?
The stated goals of EDGAR Next are to improve the security of EDGAR filings, provide accountability to the person submitting the filing, and modernize the system used by filing agents to access EDGAR (also known as APIs - Application Programming Interface, or the system that Workiva’s machines use to communicate with EDGAR). Under the current EDGAR system, any entity that knows a registrant’s CCC is able to submit filings as that registrant. This system has been mostly abuse-free, but since the CCC never expires and is often shared amongst many filing agents and other users, the potential for a malicious or unauthorized entity to submit a public filing has always been a concern.
- EDGAR Next addresses this issue by adding an additional user management layer on top of the CCC, accessed via the EDGAR Filer Management dashboard, to create a set of authorized users who are allowed to file for an EDGAR account (CIK). Since filing agents are responsible for more than 90% of all filings, adding every filing agent’s user to an account would be impractical, so the concept of delegation was created.
- In the past, providing your CCC to a filing agent or law firm was the implicit delegation mechanism, but this is now augmented by an explicit delegation process on the EDGAR Filer Management site. The delegation process allows the delegated entity (filing agent) the ability to transmit filings on behalf of its customers, while still providing the traceability back to an individual user. Delegation is not required to use Workiva’s filing software, but if you do not delegate, you will be responsible for managing your Filer Token and be required to have at least two Technical Administrator users, which is a separate role from the required Account Administrators.
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