In accordance with the December 2025 Holding Foreign Insiders Accountable Act, each director or officer of a foreign private issuer that has securities registered under Section 12(b) or 12(g) of the Securities Exchange Act must file reports under the Section 16(a) of the Exchange Act. This modernization becomes effective March 18, 2026.
To file these reports, the reporting entity must have an account on the SEC’s EDGAR system. Financial reporting entities that do not have an EDGAR account should prepare and submit the Form ID application to gain EDGAR access as soon as possible. Helpful instruction and information about Form ID are available on the Prepare and Submit My Form ID Application for EDGAR Access webpage on sec.gov.
The SEC advises applicants to allow time to obtain necessary Login.gov individual account credentials in order to properly complete Form ID and to secure the requisite notarized signature and upload the Form ID authenticating document. SEC staff reviews each Form ID, and applicants should be prepared to provide any additional information requested as a component of that review.
Additional guidance is available at the Filer Support & Resources webpage or by calling Filer Support at (202) 551-8900 (choose option 3).
Source:
New Reporting Requirements Pursuant to Holding Foreign Insiders Accountable Act (sec.gov)
