The U.S. Securities and Exchange Commission (SEC) is taking a bold step into the future with the launch of EDGAR Next, a modernized version of its legacy electronic filing system. The Silver Regulatory Compliance Team has received numerous questions from clients about this new system and its implications for regulatory filings in 2025. To address these concerns, we have put together a guide to provide clarity and actionable steps for private fund managers on EDGAR Next and the upcoming regulatory filing deadlines to help firms stay compliant and out of the SEC’s crosshairs.
What is EDGAR Next?
Think of EDGAR Next as more than just an upgrade; it’s a reimagined platform designed to align with today’s technological and regulatory needs. Unlike the older system, which relied on universal access codes that could be shared, EDGAR Next introduces a user-specific portal-based structure similar to the FINRA IARD system. This means every entity will need to designate authorized users who will have individual accounts to access and submit filings.
Here are some standout features of EDGAR Next:
- User-Specific Access: Each authorized user will have a unique account improving security and accountability.
- Multi-Factor Authentication (MFA): Adding an extra layer of security MFA ensures only verified users can access the system.
- Simplified Interface: The revamped portal streamlines the submission process for key filings like Form D, Form 13F, Form 13D/G and more.
- Improved Transparency: The new system creates a clearer audit trail ensuring greater accountability for submissions.
Transition Timeline: Are You Ready?
The SEC’s phased rollout of EDGAR Next provides a structured timeline to help private fund managers adapt to the new requirements. The process begins in March 2025 with an enrollment period wherein firms will designate authorized users and establish their accounts. This is a critical first step as the legacy system’s shared credentials will no longer be valid under the new structure. Firms must ensure that all users are properly trained on the platform and familiar with the system’s multi-factor authentication protocols.
By the second quarter of 2025, the EDGAR Next portal will go live. During this period, firms are encouraged to test the system and familiarize themselves with its functionalities. This testing phase offers an invaluable opportunity to identify and resolve potential issues before the system becomes mandatory. By the compliance deadline in September 2025, all submissions must be completed through EDGAR Next. Missing this deadline could result in disruptions or penalties, making early preparation essential for a smooth transition.
Why This Matters for Private Fund Managers
For private fund managers, EDGAR Next represents a significant operational and compliance shift. The transition requires firms to rethink how they handle filings, manage user access and ensure security protocols are being followed. Unlike the legacy system where credentials could be shared among multiple users, EDGAR Next mandates that each user has their own account tied to specific entities. This creates an additional layer of accountability but also requires firms to coordinate closely with third parties, such as regulatory compliance consultants and legal counsel. The introduction of multi-factor authentication adds another layer of security but demands that users are properly trained to avoid disruptions. Missing enrollment or compliance deadlines could lead to costly delays, making it critical for firms to act swiftly and strategically in order to stay out of the crosshairs of regulators.
Silver’s Recommendations
The Silver Regulatory Compliance Team urges private fund managers to tackle the transition head-on with a proactive approach. As such, we recommend the following:
- Act Now: Identify and onboard your authorized users well ahead of the March 2025 enrollment date. Early preparation minimizes last-minute complications.
- Engage Your Partners: Ensure that your legal and compliance partners are set up as authorized users. Establish clear lines of communication to handle filings seamlessly.
- Leverage the Trial Period: Use the portal’s early access in Q2 2025 to test its features and iron out any issues. Familiarity with the system will pay dividends when the compliance deadline arrives.
- Train Your Team: Provide training on MFA and the new interface. A well-prepared team is your best defense against potential filing mishaps.
- Stay on Schedule: Develop a detailed timeline for the transition with regular progress checks to ensure you’re on track.
While adapting to EDGAR Next may seem daunting, the benefits far outweigh the challenges. For instance, the new system reduces security risks associated with shared credentials, enhances transparency and simplifies the filing process. However, success hinges on early preparation and effective collaboration with compliance professionals, and your Silver Team is here to help.
Key Regulatory Filing Deadlines for 2025
To help private fund managers stay on track, we have outlined a comprehensive summary of critical SEC filing deadlines for 2025, which incorporates the key dates for transitioning to EDGAR Next. The chart provides a clear roadmap for firms to align their compliance efforts with key regulatory requirements:
Deadline | Filing Type | Details |
February 14, 2025 | Form 13F | For managers with $100M+ in positions in Section 13(f) securities. |
February 14, 2025 | Form 13H (Annual) | For large traders handling significant transactions in U.S. exchange-listed securities and options. Quarterly filing is required within 10 days of quarter end. However, quarterly filing for 4th quarter can be filed jointly with annual 13H filing. |
February 14, 2025 | Schedule 13G | For qualified institutional investors with 5%+ beneficial ownership of registered equity securities. |
February 14, 2025 | Form SHO | First required Form SHO filing under Rule 13f-2. Covers January 2025 short position activity. |
March 1, 2025 | Form PF (Quarterly Update for Large Hedge Fund Advisers) | Due for large hedge fund advisers with a December 31 fiscal year-end. |
March 1, 2025 | Form PF (Private Equity Fund Advisers – If Triggered) | Due for private equity fund advisers with a December 31 fiscal year-end upon occurrence of a reporting event. |
March 1, 2025 | CFTC Exemption Filings | For managers claiming exemptions from commodity pool operator and/or commodity trading advisor registration. |
March 14, 2025 | Form SHO | Covers February 2025 trading activity. |
March 31, 2025 | Form ADV Annual Amendment | Required for all registered and exempt reporting advisers with a December 31 fiscal year-end. |
April 10, 2025 | Form 13H (Quarterly) | Due for large traders if a material change occurred in Q1 2025. |
April 14, 2025 | Form SHO | Covers March 2025 trading activity. |
April 30, 2025 | Form PF Annual Filing | For hedge fund, private equity and real estate fund managers filing annually. |
April 30, 2025 | Form PF (Quarterly Update for Large Hedge Fund Advisers) | Large hedge fund advisers that filed only hedge fund-related data by March 1, 2025, must submit an amended Form PF by April 30, 2025, to include other private funds. |
April 30, 2025 | Audited Financial Statements | For private fund advisers relying on the Custody Rule audit exception (excluding funds of funds). |
May 14, 2025 | Form SHO | Covers April 2025 trading activity. |
May 15, 2025 | Form 13F | Updates for managers with $100M+ in positions in Section 13(f) securities. |
May 15, 2025 | Schedule 13G | Beneficial ownership reports for certain institutional investors. |
May 30, 2025 | Form PF (Quarterly Update for Large Hedge Fund Advisers) | For large hedge fund advisers. |
May 30, 2025 | Form PF (Private Equity Fund Advisers – If Triggered) | Required if a Q1 2025 reporting event occurred. |
June 12, 2025 | Form PF Compliance Update | Amended Form PF requirements go into effect for filings after this date. |
June 16, 2025 | Form SHO | Covers May 2025 trading activity. |
June 30, 2025 | Audited Financial Statements | For funds of funds relying on the Custody Rule audit exception. |
July 10, 2025 | Form 13H (Quarterly) | Due for large traders if a material change occurred in Q1 2025. |
July 14, 2025 | Form SHO | Covers June 2025 trading activity. |
August 14, 2025 | Form 13F | Updates for managers with $100M+ in positions in Section 13(f) securities. |
August 14, 2025 | Schedule 13G | Beneficial ownership reports for certain institutional investors. |
August 14, 2025 | Form SHO | Covers July 2025 trading activity. |
August 29, 2025 | Form PF Compliance Transition | Large hedge fund advisers transition to calendar quarterly reporting. |
August 29, 2025 | Form PF (Quarterly Update for Large Hedge Fund Advisers) | For large hedge fund advisers. |
August 29, 2025 | Form PF (Private Equity Fund Advisers – If Triggered) | Required if a Q2 2025 reporting event occurred. |
August 29, 2025 | Form NP-X | Requires reporting of “say-on-pay” proxy votes for the 12 months ending June 30. |
September 15, 2025 | EDGAR Next Transition | All submissions must transition to the EDGAR Next portal. |
September 15, 2025 | Form SHO | Covers August 2025 trading activity. |
October 10, 2025 | Form 13H (Quarterly) | Due for large traders if a material change occurred in Q1 2025. |
October 14, 2025 | Form SHO | Covers September 2025 trading activity. |
November 14, 2025 | Form 13F | Updates for managers with $100M+ in positions in Section 13(f) securities. |
November 14, 2025 | Schedule 13G | Beneficial ownership reports for certain institutional investors. |
November 14, 2025 | Form SHO | Covers October 2025 trading activity. |
November 29, 2025 | Form PF (Quarterly Update for Large Hedge Fund Advisers) | For large hedge fund advisers. |
November 29, 2025 | Form PF (Private Equity Fund Advisers – If Triggered) | Required if a Q3 2025 reporting event occurred. |
December 3, 2025 | Regulation S-P | Applies to registered investment advisers with $1.5B+ AUM. |
December 15, 2025 | Form SHO | Covers November 2025 trading activity. |
January 1, 2026 | FinCEN Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing | Applies to registered investment advisers and exempt reporting advisers |
The Road Ahead
The SEC’s adoption of EDGAR Next signals a forward-thinking approach to regulatory oversight. For private fund managers, embracing this change is an opportunity to strengthen compliance frameworks and improve operational efficiency.
As the September 2025 deadline approaches, private fund managers can take advantage of trusted advisors like Silver Regulatory Associates. Our team’s expertise can help firms navigate the complexities of the transition ensuring they remain compliant while leveraging the benefits of this modernized system. By planning ahead and engaging fully with EDGAR Next, private fund managers can turn this regulatory shift into a strategic advantage.
If you have any questions about how to get started, please reach out to the Silver Regulatory Compliance Team at [email protected], as we would be happy to walk you through the steps outlined above.