EDGAR Extension Sup Stmt.final.v3 (2-18-2025)

OMB # 3235-0328
SUPPORTING STATEMENT
For the Paperwork Reduction Act Information Collection Submission for
Form ID – Application for EDGAR Access
A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

Regulation S-T (17 CFR Part 232 et. seq.), governs the electronic submission of
documents filed or otherwise submitted to the Securities and Exchange Commission
(“Commission”) through the Commission’s Electronic Data Gathering, Analysis, and
Retrieval system (“EDGAR”). In order to facilitate its electronic filing requirements, the
Commission developed procedures and forms unique to EDGAR, including the Form ID
application for EDGAR access. The purpose of Form ID is to allow SEC staff to
determine whether to provide access to file electronically on EDGAR, in accordance with
Regulation S-T, in a manner that is secure and facilitates the process of maintaining
digital records.
2.

Purpose and Use of the Information Collection

The information provided on Form ID allows the Commission staff to review
applications for EDGAR access and, if the application is granted, assign an identification
number referred to as a Central Index Key (“CIK”) (if the applicant does not already have
a CIK) and/or access codes to applicants, to permit filing on EDGAR. Form ID is
essential to EDGAR security.
3.

Consideration Given to Information Technology

Form ID must be submitted, reviewed, and granted before filers may use
EDGAR. The Commission consistently improves EDGAR information
technology to facilitate the utility of EDGAR for filers, Commission staff, and the
public. Further, EDGAR is designed to reduce the regulatory burdens of paper
filings with the Commission.
4.

Duplication of Information

EDGAR is unique to the Commission; consequently, no duplication of
Form ID exists.
5.

Reducing the Burden on Small Entities

EDGAR has been designed to accommodate small entities to the greatest
degree possible while still providing for the public electronic dissemination of
information.

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 EDGAR Filer
Management Dashboard available on EDGAR.
7.

Special Circumstances
There are no special circumstances.

8.

Consultations with Persons Outside the Agency

The Commission has solicited comments from the public on the collection
of information burdens. No comments were received.
9.

Payment or Gift to Respondent
No payment or gift has been provided to any respondents.

10.

Confidentiality

Form ID is used solely for reviewing applications for EDGAR access and
permitting (or denying) access to EDGAR.
11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under this 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
agency has determined that the information collection on Form ID constitutes a system of
record for purposes of the Privacy Act which is covered by the SEC-33 SORN (General
Information Technology Records)1 and by an existing Privacy Act statement. Information
on Form ID is retrievable by personal identifiers, including, but not limited to, names. 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 this
collection of information. The EDGAR PIA, published on February 18, 2025, is provided

1

85 FR 85440 (Jan. 27, 2021).

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as a supplemental document and is also available at
https://www.sec.gov/about/privacy/pia/pia-edgar.pdf .
12.

Estimate of Respondent Reporting Burden

We estimate that there are 73,600 filings annually on Form ID and that it
takes 0.6 hours to prepare Form ID, for a total annual burden of 44,160 hours. It is
estimated that the filers are responsible for 100% of the 44,160 burden hours. The
estimated hours are made solely for the purposes of the Paperwork Reduction Act.

Form ID

Form ID

13.

Annual No. of Filings
Previously
approved
73,600

Requested

Change

73,600

0

Annual Time Burden (Hrs.)
Previously
Requested Change
approved
44,160
44,160
0

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 there is no additional cost associated with the
information collection.
14.

Costs to Federal Government

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

Reason for Change in Burden
There is no change in burden.

16.

Information Collections Planned for Statistical Purposes
The information collection is 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. Including the expiration date on the electronic version of this information
collection will result in increased costs, because the need to make changes to this collection
may not follow the application’s scheduled version release dates. The OMB control number
will be displayed.
18.

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

STATISTICAL METHODS
The information collection does not employ statistical methods.

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