XBRL US submitted a comment letter to the Securities and Exchange Commission (SEC) regarding its proposed Potential Technical Changes to EDGAR Filer Access and Filer Account Management Processes, File Number S7-12-21. The proposed changes are designed to increase security around the EDGAR administration and filing submission processes. The letter was prepared by the XBRL US Regulatory Modernization Working Group which is a member group composed of 14 filing agents and application providers. To provide input on the viewpoint of the issuer, the working group conducted a survey among 129 issuers to get their feedback to the proposed changes.
While we support and stand behind the success of EDGAR Next, our letter raised certain concerns with the proposed process:
- The proposed change in login to use Login.gov with multi-factor authentication is appropriate for individual, but not server-to-server login which is the approach followed by most filers today. This change could eliminate the ability to preschedule submissions, increase submission time and increase risks associated with manual processing.
- The EDGAR Next administration process proposed could add burden to the filer process.
- The proposed timing for the program of Spring 2022 gives limited time for issuers to prepare for these significant changes and the timing falls during the busy annual filing and annual stakeholder meeting period.
Read the letter: XBRL US Comment File Number S7-12-21
See an infographic describing the proposed EDGAR Next process.