Delegation is a new concept introduced in EDGAR Next where one filing entity (e.g. a registrant or reporting owner) gives permission for another entity (e.g. a filing agent or an issuer) to submit filings on their behalf.  Delegation is a one-time, non-expiring process, and it is a single level - you can delegate to another entity, but that entity can not further delegate for your CIK to another entity.

Delegating to Workiva is a prerequisite imposed by EDGAR Next to being able to utilize the “File With Workiva” filing option, but is not required.  If you choose not to delegate to Workiva, you will still be able to file as usual and you will select or provide your company’s Filer API Token and an authorized individual’s User Token in the Test and Live Filing steps, instead of the SEC password in today’s EDGAR environment.

In practice, delegating to a filing agent, such as Workiva, means they are able to use the filing agent’s Filer API Token and User Tokens to submit your filing.  Your CCC is still required to be provided in the filing package, so even if you delegate to another entity, they will not be able to successfully file without your CCC. 

In Workiva, you can choose to delegate but still utilize your own User Token (and even Filer API Token, if you prefer) in the Test and Live Filing steps, which is analogous to the SEC password in EDGAR - but with the benefit that you don’t have to type it in and your EDGAR account will not be locked out after multiple failed login attempts.

You will still be fully involved and in complete control of the filing process, and almost nothing will change other than you will provide your EDGAR Next User Token in the Test or Live Filing steps instead of a password, or choose to utilize the “File With Workiva” feature exactly as is currently implemented.