Those lucky individuals who are responsible for EDGAR codes (for companies and Section 16 filers) are strongly encouraged to confirm this week that those EDGAR codes, specifically the CCCs (CIK Confirmation Codes) and Passphrases, are both (1) valid AND (2) current. EDGAR codes are valid if they are correct and are current if they have been established or reset since September 2019. Valid and current CCCs and Passphrases will be required to enroll in EDGAR Next via the EDGAR Next dashboard, and after Friday, March 21, the process for obtaining valid and current codes will be more tedious.
You can check whether a CCC is current by logging into legacy EDGAR, but there is no method to check whether a Passphrase is current. Therefore, if there is any uncertainty as to whether a Passphrase is current, resetting the Passphrase is the only method to confirm that it is current.
If your codes are not valid or current (or if they are lost), you can reset them via the SEC’s website up until Friday, March 21st at 10:00 PM EST. Please note that this system is not available over the weekend. Once Amended Form ID becomes effective on Monday, March 24, 2025, this method of reset is no longer available. After March 21, 2025, if your CCC and Passphrase are not valid or current (or are lost), the only way to obtain new EDGAR codes will be to submit an Amended Form ID (which would automatically enroll the filer in EDGAR Next but requires new, notarized power(s) of attorney and certain affirmations from the applicant, the account administrator(s), the individual authorized to sign the Amended Form ID, the billing contact, and the person(s) signing the power(s) of attorney regarding past securities laws violations).
If you determine to reset EDGAR codes before 10:00 pm EST on March 21, please be sure to confirm the point of contact on the EDGAR account as the security reset token will be sent to the contact person’s email address. If you do not know who the EDGAR point of contact is, you can check (or update) the point of contact by logging into the EDGAR account. In addition, if you are confirming the EDGAR codes for a Section 16 filer who reports with respect to more than one company, it is advisable to coordinate with whomever assists with that person’s filings at the other company(ies).
Although you will be able to make filings via legacy EDGAR through September 12, 2025, we recommend confirming that your CCCs and Passphrases are valid and current and, if necessary, resetting these codes by Friday, March 21st at 10:00 PM EST to avoid any complications during EDGAR Next enrollment (and bypass an Amended Form ID).
As a reminder of the next steps in the transition to EDGAR Next:
- March 24, 2025: The new EDGAR Filer Management website goes live, and enrollment for EDGAR Next opens. Filers have until September 12, 2025 to enroll in EDGAR Next.
- March 24, 2025 – September 12, 2025: Filers can continue to file using the existing EDGAR Filing and Online Forms websites with their current password access credentials, while also enrolling for EDGAR Next.
- September 12, 2025: The deadline to enroll in EDGAR Next to avoid interruption in filing.
- September 15, 2025: Legacy EDGAR access codes (passwords, passphrases, and PMACs) will be deactivated for filing purposes.
Special thanks to Victor Twu and Antony Nguyen in our Orange County office for their assistance in the preparation of this post.