SUPPORTING STATEMENT.Final.Draft.LF12-23-2024

SUPPORTING STATEMENT
for the Paperwork Reduction Act Information Collection Submissions
for EDGAR Filer Access and Account Management
This submission is being made pursuant to the Paperwork Reduction Act of 1995, 44
U.S.C. § 3501 et seq. (“PRA”).
Existing Information Collection:
Form ID-Application for EDGAR Access OMB Control Number: 3235-0328
New Request for Information Collection:
The EDGAR Filer Management Dashboard (“the dashboard”)
A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

On September 27, 2024, the Commission adopted rule and form amendments
concerning access to and management of accounts on the Commission’s Electronic Data
Gathering, Analysis, and Retrieval system (“EDGAR”) that are related to certain
technical changes to EDGAR (collectively referred to as “EDGAR Next”).1 The rule and
form amendments require filers to obtain individual account credentials and comply with
certain account access and management requirements by taking action on a new filer
management tool, the EDGAR Filer Management Dashboard (“the dashboard”),
available on EDGAR.
Certain provisions of our rules and forms that will be affected by the final
amendments contain “collection of information” requirements within the meaning of the
PRA. The Commission published a notice requesting comment on changes to these
collection of information requirements in the EDGAR Filer Access and Account
Management Proposing Release,2 and submitted these requirements to you for review in
accordance with the PRA. An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a currently valid
OMB control number. Compliance with the information collection is mandatory.
Responses to the information collection are not kept confidential, and there is no
mandatory retention period for the information disclosed.
The title for the existing collection of information contained in the final
amendments is “Form ID - Application for EDGAR Access” (OMB Control No. 3235-

1

See EDGAR Filer Access and Account Management, Release No. 33-11313, Sept. 27, 2024 [89 FR 106168 (Dec.
27, 2024)], hereinafter referred to as, “EDGAR Next Adopting Release.”
2

See EDGAR Filer Access and Account Management, Release No. 33-11232, Sept. 13, 2023 [88 FR 65524 (Sept.
22, 2023)] and March 12, 2024 [89 FR 19292 (Mar. 18, 2024)].

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0328).3 The final amendments also include a new collection of information titled “The
EDGAR Filer Management Dashboard.” The amendments to Form ID and the
implementation of the dashboard are designed to harness the benefits of improved
technology and to modernize the EDGAR access and management functions. A detailed
description of the final amendments, including the amendments to Form ID and the
implementation of the dashboard, including the need for the information and its proposed
use, as well as a description of the likely respondents, can be found in Section II of the
EDGAR Next Adopting Release,4 and a discussion of the expected economic impact of
the final amendments can be found in Section IV of the EDGAR Next Adopting
Release.5 We discuss below the collection of information burdens associated with each
initiative.
Form ID must be completed online and submitted to the Commission by
individuals, companies, and other organizations that seek access to file electronically on
EDGAR. The amendments to Form ID will require an applicant for EDGAR access to
undertake certain additional obligations, including most significantly: (1) designating on
Form ID specific individuals the applicant authorizes as its account administrator(s) to
manage its EDGAR account on a dedicated dashboard on EDGAR; (2) indicating the
applicant’s legal entity identifier (“LEI”), if any; (3) providing more specific contact
information about the applicant, its account administrator(s), its authorized individual
(the individual authorized to sign Form ID on the filer’s behalf as defined in the EDGAR
Filer Manual), and its billing contact (including mailing, business, and billing
information, as applicable); (4) specifying whether the applicant, its authorized
individual, person signing a power of attorney (if applicable), account administrator, or
billing contact has been criminally convicted as a result of a Federal or State securities
law violation, or civilly or administratively enjoined, barred, suspended, or banned in any
capacity, as a result of a Federal or State securities law violation; (5) indicating whether
the applicant, if a company, is in good standing with its State or country of incorporation;
(6) requiring submission of a new Form ID for both prospective filers seeking access to
EDGAR for the first time and existing filers that must apply for access to EDGAR
because they (i) lost electronic access to their existing EDGAR account or (ii) are the
legal successor of the filer named on the existing EDGAR account but did not receive
EDGAR access from that filer, or (iii) are broker-dealers or “paper filers” seeking
electronic access for the first time in order to file electronically on EDGAR; and (7)
requiring those seeking access to an existing EDGAR account to upload to EDGAR the
documents that establish the applicant’s authority over the company or individual listed
in EDGAR on the existing account. The final amendments will also simplify filer account
management by eliminating the EDGAR password, PMAC, and passphrase.

The current title for the collection of information is Form ID – EDGAR Password, however we are requesting that
the title be changed to Form ID – Application for EDGAR Access.
3

4

See EDGAR Next Adopting Release.

5

See EDGAR Next Adopting Release.

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To file on EDGAR, each filer must also comply with certain account access and
management requirements by taking actions on the dashboard. As outlined above, each
filer will be required to authorize individuals to act on its behalf on the dashboard, and
those individuals must have obtained individual account credentials for EDGAR in the
manner specified in the EDGAR Filer Manual. Moreover, each filer, through its account
administrators, will be required to: (i) authorize and maintain at least two individuals as
authorized account administrators to act on the filer’s behalf to manage the filer’s
EDGAR account, except a filer who is an individual or single-member company must
authorize and maintain at least one individual as an account administrator; (ii) confirm
annually on EDGAR that all users, account administrators, technical administrators,
and/or delegated entities reflected on the dashboard for the filer’s EDGAR account are
authorized by the filer, and that the filer’s information on the dashboard is accurate; (iii)
maintain accurate and current information on EDGAR concerning the filer’s account,
including but not limited to accurate corporate information and contact information (such
as mailing and business addresses, email addresses, and telephone numbers); (iv)
securely maintain information relevant to the ability to access the filer’s EDGAR
account, including but not limited to access through any EDGAR Application
Programming Interfaces (“APIs”); and (v) if the filer chooses to connect to an EDGAR
API, authorize, through its account administrator(s) at least two technical administrators
to manage technical matters related to the filer’s connection to the API, or the filer may
use the API connections and filer API tokens of its delegated entity so long as the
delegated entity is in compliance with the technical administrator and other API
requirements.
2.

Purpose and Use of the Information Collections

The amendments to Form ID and the implementation of the dashboard are
designed to harness the benefits of improved technology and to modernize the EDGAR
access and management functions.
The information provided on Form ID allows the Commission staff to review
applications for EDGAR access and, if the application is granted, assign CIKs (if the
applicant does not already have a CIK) and access codes to applicants to permit filing on
EDGAR.
Filers, through their account administrators, will be required to comply with the
account access and management requirements by taking actions on the dashboard, and
the role and functionality that corresponds to each individual authorized by the filer will
be displayed on the dashboard.

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3.

Consideration Given to Information Technology

Form ID must be submitted, reviewed, and granted before filers may use
EDGAR. As mentioned above, the dashboard is the mechanism through which
electronic filers will manage their EDGAR accounts. The Commission
consistently improves EDGAR information technology to facilitate the utility of
EDGAR for filers, Commission staff, and the public.
4.

Duplication of Information

EDGAR is unique to the Commission; consequently, no duplication of
these information collections exists.
5.

Reducing the Burden on Small Entities

The final rule and form amendments apply to all applicants and current
EDGAR accounts and will apply to small entities to the same extent as other
entities, irrespective of size. Therefore, we generally expect the nature of any
benefits and cost associated with the amendments to be similar for large and small
entities. We note that, as discussed in the EDGAR Next Adopting Release, all
existing and new EDGAR filers will be subject to certain fixed costs to update
and maintain an EDGAR account under the final amendments, which may result
in a proportionally larger burden on small filers.
To the extent that simplifying the requirements of the final rule and form
amendments could reduce regulatory burden on small filers, while affording small
filers greater discretion as to how they manage their accounts and securely
maintain EDGAR access, exempting a particular group of users would hinder the
Commission’s effort of establishing uniform requirements for all filers and
individuals acting on their behalf.
6.

Consequences of Not Conducting Collection

Form ID must be submitted and granted by SEC staff in order for filers to
use EDGAR, and filers and individuals authorized by the filer will be required to
take the actions necessary to manage their accounts through the dashboard.
7.

Special Circumstances
There are no special circumstances in connection with these amendments.

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8.

Consultations with Persons Outside the Agency

The Commission has solicited comments from the public on the collection
of information burdens. The Commission has evaluated the public comments
received during the comment period prior to OMB’s approval.
9.

Payment or Gift to Respondent
There are no payments or gifts to respondents.

10.

Confidentiality

Form ID is used solely for applications for EDGAR access and permitting
(or denying) access to EDGAR. The dashboard is used to manage filers’ accounts
on EDGAR.
11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under either collection of information. The information collection on Form ID
collects basic Personally Identifiable Information (PII) that may include name, address,
phone number, zip code, occupation, job title, email address, LEI, business and billing
contact, information regarding whether certain individuals identified as part of the Form
ID application have been criminally convicted as a result of a Federal or State securities
law violation, or civilly or administratively enjoined, barred, suspended, or banned in any
capacity, as a result of a Federal or State securities law violation, and whether the
applicant, if a company, is in good standing with its state or country of incorporation. The
information collection on the dashboard collects basic PII that may include name, job
title, and work address. The agency has determined that the information collections on
Form ID and the dashboard do constitute a system of record for purposes of the Privacy
Act which are covered by the SEC-33 SORN (General Information Technology
Records)6 and by an existing Privacy Act statement. Information on Form ID is
retrievable by personal identifiers, including, but not limited to names. Information on the
dashboard can be searched and retrieved by, among other things, name, Login.gov email
address, and CIK (which can be linked to an individual). In accordance with Section 208
of the E-Government Act of 2002, the agency has conducted a Privacy Impact
Assessment (PIA) of EDGAR, in connection with these collections of information. The
EDGAR PIA, published on March 22, 2023, is provided as a supplemental document and
is also available at https://www.sec.gov/about/privacy/pia/pia-edgar.pdf.

6

85 FR 85440 (Jan. 27, 2021).

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12.

Estimate of Respondent Reporting Burden:
Form ID

Form ID

Form ID

Annual No. of Filings
Previously
approved
66,519

Requested

Change

73,600

7,081

Annual Time Burden (Hrs.)
Previously
Requested Change
approved
18,578
44,160
25,582

For purposes of the PRA, the currently approved burden includes an
estimate of 66,519 Form ID filings annually and further estimates approximately
0.279289 hours per response to prepare and file Form ID, for a total of 18,578
annual burden hours. Filers are responsible for 100% of the total burden hours.
There were 73,600 Form ID filings in calendar year 2023. The estimate
includes the number of filers without CIKs, filers with CIKs who have not filed
electronically on EDGAR, and filers with CIKs who are seeking to regain access
to EDGAR.7 For purposes of the PRA, we estimate that the number of Form ID
filings under the final amendments will remain the same and that the number of
hours to prepare Form ID will increase by 0.3 hours.8
Thus, for purposes of the PRA, the estimated total number of annual Form
ID filings will increase from 66,519 filings to 73,600 filings. The estimate of
0.279289 hours per response will increase to 0.579289 hours per response, which
for administrative convenience, we are rounding up to 0.6. The estimated total
annual burden will increase from 18,578 hours to 44,160 hours.9 The estimate that
the filers are responsible for 100% of the total burden hours will remain the same.

7

63,676 filings for users without CIKs + 9,602 filings for filers who are seeking to regain access to EDGAR + 322
filings for filers with CIKs who have not yet filed electronically on EDGAR = 73,600 filings.
8

The increase in burden will vary by applicant depending on whether certain of their responses required additional
information (e.g., explaining the circumstances surrounding any specified individuals who are currently subject to
Federal or State securities law investigations, proceedings, convictions, suspensions, or bars, and for applicants
seeking access to an existing CIK account, providing the documents that establish the applicant’s authority over the
company or individual currently listed in EDGAR as corresponding to the existing CIK account).
9

73,600 filings x 0.60 hours/filing = 44,160 hours.

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EDGAR Filer Management Dashboard
Burden
Hours
Per Filer
in Year 1
Dashboard
1
set up
Dashboard
1
management
All dashboard 2
responsibilities

Burden
Hours
Per Filer
in Year 2

Burden
Hours
Per Filer
in Year 3

Total
Burden
Hours
Per Filer

Number Aggregate
of Active Burden Hours
Filers
for Active
Filers

1

Average
Burden
Hours Per
Filer Over 3
Years
0.3

0

0

208,000

62,400

1

1

3

1

208,000

208,000

1

1

4

1.3

208,000

270,400

For purposes of the PRA, we estimate that each filer will spend
approximately one hour in the first year setting up the dashboard, and
additionally, on average, approximately one hour per annum managing the filer’s
account on the dashboard. This burden will vary across filers depending on the
size of the filer, the number of users, account administrators, technical
administrators, and delegated entities authorized by the filer, as well as the
amount of annual staff turnover for those individuals and entities, among other
factors. For a small number of filers, the annual burden may significantly exceed
our estimate (e.g., filing agents that may authorize a large number of individuals,
and that have multiple accepted delegations and user groups for which delegated
users will need to be maintained). On the other hand, for the vast majority of
filers, the annual burden will presumably be less than our estimate because we
expect most filers will authorize a small number of individuals and will
experience little or no annual turnover with regard to those individuals.10
Consequently, the anticipated aggregate average annual burden attributed to the
dashboard for all filers will be approximately 270,400 burden hours, based on a
three-year average burden of 1.3 hours per filer.11

10

A filer survey conducted by a filing agent found that at least 64% of its respondents planned to have three or
fewer account administrators, and 96% of its respondents planned to have fewer than 20 users. See Workiva
Comment Letter (Nov. 30, 2021). Moreover, since filers are not required to authorize users, technical administrators,
or delegations, filers who did not choose to authorize such individuals or third parties would not have any associated
burdens.
11

The estimate of 1.3 hours per filer is based on the following calculations: For dashboard set up, 1 hour in the first
year ÷ 3 years = 0.3 hours on average; for dashboard management, 1 hour per year ÷ 3 years = 1 hour on average;
0.3 hours for dashboard set up + 1 hour for dashboard management = 1.3 hours on average for all dashboard
responsibilities. The estimate of 270,400 hours is based on the following calculations: 0.3 hours for dashboard set up
x 208,000 filers = 62,400 hours; 1 hour for dashboard management x 208,000 filers = 208,000 hours; 62,400 hours +
208,000 hours = 270,400 hours.

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13.

Estimate of Total Annualized Cost Burden

We estimate that the filer is responsible for 100% of the total reporting
burden imposed by Form ID and the dashboard, and there is no additional cost
associated with either information collection.
14.

Costs to Federal Government

The Commission has no specific information available concerning the cost
for staff processing Form ID or staff oversight of the dashboard.
15.

Reason for Change in Burden

As explained in further detail in Items 1, 2, 12, and 13 above, the final rule
and form amendments will result in changes in the burden for Form ID and will
newly require that each filer comply with the account access and management
requirements by taking actions on the dashboard. The amendments to Form ID,
and the implementation of the dashboard, are designed to harness the benefits of
improved technology and to modernize the EDGAR access and management
functions.
For purposes of the PRA, we estimate that the final amendments will
result in an annual increase of 7,081 Form ID filings, an increase of 25,582 burden
hours for Form ID, and no change to the cost burden.

For purposes of the PRA, we estimate that the final amendments will
newly require each filer to spend approximately one hour in the first year setting
up the dashboard, and additionally, on average, approximately one hour per
annum managing the filer’s account on the dashboard. Consequently, the
anticipated aggregate average annual burden attributed to the dashboard for all
filers will be approximately 270,400 burden hours, based on a three-year average
burden of 1.3 hours per filer, and no additional cost burden.
16.

Information Collections Planned for Statistical Purposes
The information collections are not planned for statistical purposes.

17.

Approval to Omit OMB Expiration Date

We request authorization to omit the expiration date on the electronic version of
Form ID and the dashboard. Including the expiration date on the electronic version of these
information collections will result in increased costs, because the need to make changes to
these collections may not follow the applications’ scheduled version release dates. The
OMB control number will be displayed.

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18.

Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions for the Paperwork Reduction Act submissions.

B.

STATISTICAL METHODS
The information collections do not employ statistical methods.

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SHORT STATEMENT
FORM ID – APPLICATION FOR EDGAR ACCESS
The final rule and form amendments will result in changes in the burden
for Form ID. Form ID must be completed online and submitted to the
Commission by individuals, companies, and other organizations that seek access
to file electronically on EDGAR. The amendments to Form ID will require an
applicant for EDGAR access to undertake certain additional obligations. The
amendments to Form ID are designed to harness the benefits of improved
technology, and to modernize the EDGAR access and management functions.
For purposes of the PRA, we estimate that the final amendments will
result in an annual increase of 7,081 Form ID filings, an increase of 25,582
burden hours for Form ID, and no change to the cost burden.

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SHORT STATEMENT
THE EDGAR FILER MANAGEMENT DASHBOARD
The final rule and form amendments will newly require that each filer
comply with certain account access and management requirements by taking
actions on the dashboard. The implementation of the dashboard is designed to
harness the benefits of improved technology and to modernize the EDGAR access
and management functions.
For purposes of the PRA, we estimate that the final amendments will
newly require each filer to spend approximately one hour in the first year setting
up the dashboard, and additionally, on average, approximately one hour per
annum managing the filer’s account on the dashboard. Consequently, the
anticipated aggregate average annual burden attributed to the dashboard for all
filers will be approximately 270,400 burden hours, based on a three-year average
burden of 1.3 hours per filer, and no additional cost burden.

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