EDGAR Next: Common Form ID Submission Issues and How to Avoid Them

Capital Markets Client Alerts

In 2025 the Securities and Exchange Commission (the “SEC”) implemented significant technical changes to EDGAR, its Electronic Data Gathering, Analysis and Retrieval system. These changes, known as “EDGAR Next”, are intended to improve EDGAR’s security, efficiency, and scalability.

Obtaining access to EDGAR Next requires submitting a Form ID, which has presented some practical challenges. Since the turnaround time for SEC approval of a Form ID is approximately two weeks, ensuring a properly submitted Form ID is even more crucial.  

To help you and your team avoid unnecessary delays and missed filing deadlines, we have listed some common reasons Form IDs are rejected, as well as some suggested solutions to avoid or address them. The issues below highlight several common EDGAR Next Form ID submission errors and practical steps to help avoid rejection.

Corrupted EIS File Submission

• Issue: Due to a glitch in the filing system, saving a Form ID prior to filing may result in a corrupted “.eis” file (the filing format of a Form ID). Some Form IDs have been rejected due to a corrupted “.eis” file. 
• Solution: Avoid saving a Form ID prior to filing to ensure a clean “.eis” file. If necessary, redraft and resubmit a new “.eis” file.

Form ID PDF Did Not Attach to Submission

• Issue: A Form ID was submitted separately from the power of attorney form (“POA”) (as the directions indicate), but the Form ID did not attach. 
• Solution: (Re)submit the Form ID and POA together in one PDF.

Power of Attorney Form – Exhibit location

• Issue: The examiner may consider an exhibit that is behind the signature page of the POA and the notary block outside of the Form ID and may result in a rejection of   the Form ID. 
• Solution: Include the exhibit (e.g., a list of the account administrators) in front of the notary block or add the information to the POA itself.

Notarized Signature Did Not Match Signature Block

• Issue: A discrepancy between the signature and the signature block. For example, some notaries require a signature to exactly match the signatory’s driver’s license (with the middle name), which needs to be reflected in the signature block.
• Solution: Resubmit a Form ID with matching signatures.  

Listing Signatory’s Name with an Initial

• Issue: A Form ID is rejected because the signatory’s name is listed with an initial and then a middle name (e.g., J. Joseph Smith). 
• Solution: Include the first name in its entirety.

Electronic File and Signed Form ID Do Not Match

• Issue: If the Form ID is edited after being sent for signature, it will result in a mismatch of the electronic and authenticating versions of the Form ID. If they do not match, the Form ID will be rejected and will need to be submitted.
• Solution: Ensure the Form ID is final before it is signed.

Improper Title for Company Signatory

• Issue: The examiner will reject a Form ID when the person signing as is listed “Authorized Signatory,” as this is not a permitted title.
• Solution: Use a proper title for the signatory, such as “Chief Executive Officer,” “Chief Financial Officer,” “General Counsel,” or “Secretary,” as applicable. When a person is submitting a Form ID in an individual capacity, a title is not required.

Amy K. Hallman and Chris Agoranos are members of the Capital Markets practice group of Wyrick Robbins. Wyrick Robbins publishes Client Alerts periodically as a service to clients and friends. The purpose of this Client Alert is to provide general information, and it is not intended to provide, and should not be relied upon as, legal advice.