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ARTICLE · 19 MARCH 2026

Updates To Section 16(a) Filing Requirements

Carter Ledyard & Milburn LLP
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In light of the unusually large number of Form ID applications submitted as a result of the HFIA Act, the SEC indicated that it would not recommend enforcement...

United StatesCorporate/Commercial Law
Guy Ben-Ami
Guy Ben-Ami

In light of the unusually large number of Form ID applications submitted as a result of the HFIA Act, the SEC indicated that it would not recommend enforcement action against a director or officer of a foreign private issuer for the untimely filing of a Section 16(a) report caused by lack of EDGAR access as long as:

The SEC stated that enforcement action will not be recommended where:

  • The individual submitted a completed Form ID application and required supporting documentation before March 18, 2026;
  • The individual did not receive EDGAR access by March 18, 2026; and
  • The individual files the required Section 16(a) report promptly after receiving EDGAR access, but no later than April 1, 2026.

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