Increased Security Measures Planned for SEC’s EDGAR Next

Increased security measures are in the works for the Securities and Exchange Commission's (SEC) Electronic Data Gathering Analysis and Retrieval (EDGAR) Next program to better protect corporations filing of highly sensitive information. The SEC's proposed security changes to the EDGAR system are critically important in this cyber threat-rich climate, and DFIN continues to work closely with the SEC to monitor its updates and the impact to filers.

The SEC's EDGAR Next program is proposed to launch Spring 2022 and will change how filers transmit submissions and manage their CIK and CCC through EDGAR and Login.gov. We wrote about the SEC's initial beta program as it rolled out in early October and have continued to provide input to the program. Since then, the SEC requested public comment by December 1, 2021 and is still accepting comment letters.

Here's what we know about EDGAR Next:

• The filer would maintain Central Index Key (CIK) and CIK Confirmation Code (CCC)
• Each individual would have their own login.gov account with multi-factor authentication, which is reset at minimum every 30 days
• SEC Password, PMAC, Passphrase would be eliminated
• Credentials would have to be reconfirmed each year
• Entity filers would have two or more administrators on their account, and must have filing agent delegation if outsourcing filing
• Admin must reconfirm all permissions every year (failure to do so requires filing a new Form ID)
• EDGAR would no longer allow server-to-server authentication through the Filing Agent System

If finalized, the proposed rule will eliminate and disrupt automated processes and workflows. As with all proposed SEC rules, we will not fully understand exact impact of the EDGAR Next proposed rule until it is finalized by the SEC's Commission.

Additional resources:

• Additional information on the proposed rule can be found here: https://www.sec.gov/edgar/filer-information/edgar-next
• The proposed rule can be found here: https://www.sec.gov/rules/other/2021/33-10993.pdf
• XBRL US Comments on EDGAR Next: https://xbrl.us/news/xbrlus-comment-edgarnext/

At DFIN, we are committed to delivering the best possible service and solutions to our clients. As the SEC amends, updates, and improves the security of the EDGAR database, we will continue to stay apprised of the proposed changes and communicate them to you.