SEC Launches EDGAR Next: Mandatory Enrollment Deadline Approaches

The U.S. Securities and Exchange Commission (“SEC”) has introduced EDGAR Next, a modernization of its Electronic Data Gathering, Analysis, and Retrieval (“EDGAR”) system. Under EDGAR Next, all existing EDGAR filer accounts must complete a one-time enrollment process by September 15, 2025, to continue making filings through EDGAR. This change affects a broad range of market participants, including registered investment advisers, private funds, and other entities that use EDGAR to file required forms. Advisers should carefully review which of their entities have EDGAR accounts and complete enrollment in advance of the deadline.

Who Must Enroll

Enrollment applies to all existing EDGAR filers, including but not limited to:

• Registered investment advisers that file reports on EDGAR (e.g., Form 13F or Form N-PX);
• Private funds that submit Form D filings in connection with Regulation D offerings;
• Registered investment companies such as mutual funds, ETFs, closed-end funds, and BDCs; and
• Public companies, broker-dealers, and other SEC registrants with EDGAR obligations.

Types of Filings completed on EDGAR

Investment advisers and private funds may rely on EDGAR for filings such as:

• Form D (private fund and other Regulation D offerings);
• Form 13F (quarterly securities holdings reports, for advisers with ≥ $100 million in qualifying assets);
• Form N-PX (annual proxy voting records, including new requirements for say-on-pay votes); and
• Form 13H (large trader filing)
• Form 13G (beneficial ownership disclosure)

How to Enroll

Enrollment is completed electronically here on the SEC website. It involves:

1. Creating user login.gov accounts – each filer must have at least one login.gov credential associated with its EDGAR account.
2. Designating Account Administrators – responsible for managing user access, assigning roles, and maintaining account security.
3. Reviewing and updating filer information – including legal name, mailing address, and contact details.
4. Confirming user authorizations – ensuring that all individuals who prepare, submit, or view filings have the correct level of access.

If we currently assist with your EDGAR filings, please contact us to ensure we have the appropriate access.

Deadlines and Consequences

• Enrollment Deadline to continue filing: September 15, 2025 – filer is unable to make required SEC submissions through EDGAR after this date until enrolled.
• Final deadline to retain EDGAR access: December 19, 2025 – after this date, filer must re-apply for EDGAR access with Form ID.
• Missing a required filing (such as Form D, Form 13F, or Form N-PX) due to non-enrollment could create compliance risks and potential regulatory consequences.

Your Stark & Stark team remains available to assist with completing your EDGAR Next enrollment and EDGAR filings.