EDGAR Filer Manual Version 78: Form 1, ANE Notices and the XBRL Move

The SEC’s latest EDGAR Filer Manual update reached the Federal Register on 6 October 2026, three weeks after the system change it describes. In a final rule published at 91 FR 63476 (Release Nos. 33-11438 and 34-106345), the Commission adopted Volume II of the EDGAR Filer Manual, “EDGAR Filing,” Version 78 (September 2026), and amended Rule 301 of Regulation S-T so that the Code of Federal Regulations names it. The rule took effect on publication. EDGAR Release 26.3, the software that implements it, was deployed on 14 September 2026, the date the Commission’s release bears.

Four changes ride on Version 78. Technical XBRL content leaves Chapter 6 of the manual for the staff-prepared EDGAR XBRL Guide. The Form 13F and 13F-CTR submission templates get a corrected cover-page reference. Two Exchange Act submissions that have run on email and paper move onto EDGAR: ANE Exception Notices under Rule 3a71-3(d)(1)(vi), which will no longer be accepted by email from 1 January 2027, and Form 1 for national securities exchanges, which will no longer be accepted on paper from 2 March 2027.

The work lands unevenly. For anyone generating Form 13F XML outside the online form, the label fix arrives as a schema edit. The XBRL move leaves stale cross-references in validation runbooks. The ANE and Form 1 changes carry hard cutover dates and, for any registrant that has only ever filed on paper, a Form ID application before the first electronic submission.

Related reading: Form PF Reporting: Thresholds, Deadlines and the July 2027 Form Switch

Version 78 dates at a glance

The release mixes dates that have already passed with two hard cutovers in 2027. Both cutover dates come from an earlier release, the September 2025 extension of the Exchange Act electronic submission rules. Testing started before the system went live, in the EDGAR Beta environment.

What Rule 301 now incorporates, and what stayed put

Rule 301 of Regulation S-T (17 CFR 232.301) requires filers to prepare electronic filings in the manner the EDGAR Filer Manual prescribes, and the manual is incorporated into the Code of Federal Regulations by reference. The revised rule text names two volumes. Volume I, “General Information,” Version 43 (March 2026), sets out how to become an EDGAR filer and update company data. Volume II, “EDGAR Filing,” Version 78 (September 2026), sets out how to file. The release states that filers must comply with the applicable provisions of the manual to assure timely acceptance and processing of electronic filings.

Volume I stays at Version 43, adopted in March 2026 together with Volume II Version 77 in Release No. 33-11411. The Commission issued that release on 16 March 2026, and it was published and took effect on 16 April 2026. That earlier cycle had the same shape as this one: system deployment first, Federal Register effectiveness weeks later. Account-access rules therefore sit where they did in March, in Volume I Version 43.

The procedural findings are short. Because the Commission treated the amendments as relating solely to agency procedure or practice, the release went straight to final form, without notice and comment under the Administrative Procedure Act and without a Regulatory Flexibility Act analysis. The Office of Management and Budget placed the action outside the significant regulatory actions defined in Executive Order 12866. The Commission also found good cause for an effective date less than 30 days after publication, to coordinate the updated manual with the related system upgrades.

One trap sits inside Version 78 itself. The Form 1 instructions (section 8.2.42) and the ANE Exception Notice instructions (sections 8.2.43 and 8.2.44) are printed under bracketed headers stating that the content “will be added” to the manual effective 2 March 2027 and 1 January 2027 respectively. Read those brackets as marking the mandatory dates. The release says LIVE submissions of both have been possible since 14 September 2026.

The same bracketed notes cite the extension release as “Securities Act Release No. 33-11386 (Dec. 8, 2025).” The Federal Register version of Release No. 33-11386 is dated 8 September 2025 and was published at 90 FR 43552 on 10 September 2025.

Chapter 6 of the EDGAR Filer Manual shrinks to a pointer

Until this release, Chapter 6, “Interactive Data,” carried the manual’s technical information on submitting XBRL documents. In Version 78 the chapter is a single paragraph: technical specifications and additional information for XBRL submissions are provided in the EDGAR XBRL Guide, with a link to the guide on SEC.gov. The release gives the reason in one line. The XBRL material is highly technical, so it belongs in the guide, which the release describes as the technical specification document for submitting Inline XBRL documents on EDGAR.

This is the second step of a migration. The March 2026 update (Version 77) had already removed the Inline XBRL submission material from section 5.2.5 of the manual and placed it in the guide. The guide’s own 2026 change log tracks the rest:

• January 2026: the guide took over the manual’s Inline XBRL content, recording it as moved “unchanged” into its section 11.
• June 2026: definitions and tables previously found only in the manual were added to section 1, “Fundamentals.”
• August 2026, the version corresponding to the Release 26.3 draft manual: Form 1 Exhibit I added as a new instance type, AF.SRO.

The release lists no new XBRL validation among the Version 78 changes. I read the relocation as editorial for existing Inline XBRL filers; the substantive XBRL addition this cycle is the AF.SRO instance type for exchanges, covered below.

The operational cost is in cross-references. The August 2026 guide still describes Chapter 6 as the place that contains the requirements for Interactive Data submissions, and its validation tables carry a reference to version 68 of the Filer Manual, for example “section 6.5.21.” Version 78 Chapter 6 has no subsections at all. Validation runbooks, vendor error-mapping tables and QA checklists that cite manual section 6.5.x have lost their anchor.

Bookmarks need checking too. Chapter 6 links the guide at sec.gov/files/edgar/filer-information/specifications/xbrl-guide.pdf, which is also where the SEC’s technical specifications page points. Section 7.3.10 on filing fee exhibits and the Form 1 attachment instructions in section 8.2.42.10 give a shorter path, sec.gov/files/edgar/xbrl-guide.pdf.

Teams that also tag EU annual reports run a second taxonomy cycle alongside this one. Our ESMA ESEF taxonomy 2025 update covers the 2026 changes on that side, and our note on the draft ESRS XBRL taxonomy covers EFRAG’s sustainability tagging consultation.

A question the release leaves open is the status of the relocated text. The guide’s disclaimer says it is prepared by SEC staff, that the staff’s provision of it does not indicate Commission approval of any change, and that filers must comply with the EDGAR Filer Manual. The amended Rule 301 incorporates the two manual volumes by reference and does not name the guide. The release does not discuss what, if anything, follows from that.

Form 13F: one digit on the cover page, one element in the schema

The Form 13F fix looks cosmetic. In the “Cover Page” section of the 13F and 13F-CTR submission templates on the EDGAR Filing website, the question about explanatory information referred to “Special Instruction 5.” Version 78 corrects it to “Special Instruction 4,” so the question now reads: “Do you wish to provide explanatory information (e.g., pursuant to Special Instruction 4) on your filing?”

The digit matters because the two instructions do different jobs. In the current Form 13F (SEC 1685, 07-23), Special Instruction 4 governs the format of the Cover Page and Summary Page and allows additional information on the Cover Page, placed after the signature and immediately before the Report Type section, with none on the Summary Page or Information Table. Special Instruction 5 governs how a manager designates the Report Type: holdings report, notice or combination report. The old label pointed managers at the report-type instruction when the question was about explanatory information.

Both instructions read as they did before 14 September, so a manager’s Y or N answer keeps its meaning.

The Form 13F XML Technical Specification Version 2.0 (September 2026) renames the cover page element from provideInfoForInstruction5 to provideInfoForInstruction, with the change listed in its summary of changes for 14 September 2026. The element is mandatory, takes “Y” or “N,” and applies to all six submission types: 13F-HR, 13F-HR/A, 13F-NT, 13F-NT/A, 13F-CTR and 13F-CTR/A. The schema file eis_13F_Filer.xsd in the Version 2.0 package declares only the new name. The Federal Register release does not mention the rename, so a team that tracks EDGAR changes through the release alone would miss it.

Managers who file through the online 13F form see a corrected label and nothing else. The exposure sits with filing agents and vendors that generate the submission XML themselves.

ANE Exception Notices: who files, and the email deadline

ANE stands for “arranged, negotiated, or executed.” Under Exchange Act Rule 3a71-3(b)(1)(iii)(C), a non-U.S. person other than a conduit affiliate, when calculating its dealing activity against the de minimis exception, counts security-based swap dealing transactions arranged, negotiated or executed by personnel located in a U.S. branch or office, whether its own personnel or an agent’s. Paragraph (d) switches that counting requirement off when the conditions in paragraph (d)(1) are met.

The first condition, in (d)(1)(i), requires the U.S. activity to be conducted by personnel acting as associated persons of an entity that is registered with the SEC as a broker (subject to specified net capital conditions) or as a security-based swap dealer, and that is a majority-owned affiliate of the non-U.S. person relying on the exception. The notice condition is (d)(1)(vi). Before that registered entity’s associated persons begin the activity, the registered entity must have filed a notice with the Commission, not since withdrawn, that its associated persons may conduct it.

The filing obligation follows from that structure. Under (d)(1)(vi) the notice falls to the registered entity whose associated persons do the arranging, negotiating or executing, so the CIK that needs EDGAR access is that entity’s. The non-U.S. affiliate is the party relying on the exception the notice supports.

The rule text, as amended in December 2024, requires the notice to be filed electronically on EDGAR in accordance with the Filer Manual and Regulation S-T. It also covers withdrawal: a registered entity whose associated persons will no longer conduct the activity may withdraw its notice, and an entity that no longer meets paragraph (d)(1) must promptly withdraw it, in both cases by filing on EDGAR. Notices and withdrawals are publicly disseminated through EDGAR.

The EDGAR requirement came from the electronic submission amendments the Commission adopted on 16 December 2024 (Exchange Act Release No. 101925, 90 FR 7250). The compliance date was 1 January 2026; Release No. 33-11386 extended it by twelve months to 1 January 2027. Release 26.3 supplied the filing route:

• A “File ANE Exception Notice” link on the EDGAR Filing website, with two submission types: ANE EXCEP NOTICE and ANE EXCEP NOTICE-W.
• Two screens: Filer Information (CIK, CCC, contact and notification addresses) and Documents.
• One notice document per submission, in .txt, .htm or .pdf, with an optional .jpg or .gif graphic, and a 200 MB cap per submission.
• Filer-constructed XML under the EDGAR ANE Exception Notice XML Technical Specification Version 1.0 (September 2026).

Until 31 December 2026 the email route stays open for notices and withdrawal requests. From 1 January 2027, the release says, email filings of ANE Exception Notices and withdrawals will not be accepted.

Agents building the XML will hit a naming mismatch. Section 8.2.44.2 of Volume II lists the withdrawal attachment type as “ANE NTC-W.” The XML schema in the technical specification enumerates the attachment types as ANE EXCEP NTC and ANE EXCEP NTC-W, and the specification requires a filer-constructed submission to conform to its schema files.

The release is silent on one practical point. Neither the release nor Volume II says whether a notice already filed by email, and not withdrawn, must be filed again on EDGAR once the email route closes. The release names contacts in the Division of Trading and Markets for questions about ANE submissions, and that question belongs with them.

Form 1 on EDGAR: nine submission types and one Inline XBRL exhibit

Form 1 is the application for registration as a national securities exchange, or for exemption from registration based on limited volume, under Exchange Act Rule 6a-1, together with the amendments and supplemental filings required by Rules 6a-2 and 6a-3. Release 26.3 gives it an online interface on the EDGAR Filing website and a Form 1 XML Technical Specification (Version 1.0, 14 September 2026) for filer-constructed submissions. Paper remains acceptable until 1 March 2027. From 2 March 2027 paper filings will not be accepted; that compliance date was extended from 2 March 2026 by Release No. 33-11386.

Volume II lists nine submission types. The deadlines in the right-hand column come from Rules 6a-2 and 6a-3 as they appear in the 2025 edition of 17 CFR.

The format change is larger than a switch from paper to PDF. The Version 78 exhibit table assigns a format to each of the fourteen exhibits: A, B, D, E, F and G as PDF uploads; C and H as XML data entry or PDF; J, K, L, M and N as XML data entry; and Exhibit I, the audited financial statements, as Inline XBRL.

The Inline XBRL scope is where the documents disagree. The December 2024 adopting release required Inline XBRL for Exhibits D, E (in part) and I. On 11 September 2026 the Commission issued an exemptive order (Release No. 34-106339) relieving Form 1 filers of the Inline XBRL requirement for the whole form except Exhibit I. The Volume II exhibit table matches the order, showing D and E as PDF.

Section 8.2.42.10 of the same volume still says Exhibits D, E and I “should be uploaded as Inline XBRL.” The order and the exhibit table agree with each other; the attachment list is the outlier.

For Exhibit I, the EDGAR XBRL Guide supplies the build rules. It defines instance type AF.SRO for attachment EX.I.FORM1, an .htm file that must reference either the us-gaap or the ifrs entry point, and its consequences table says XBRL errors in an AF.SRO instance lead to suspension of the submission.

One field on the Form 1 landing page needs a deliberate answer: whether the submission is an electronic copy of an official filing previously made on paper. Volume II also warns that an “accepted” status from EDGAR says nothing about whether the SEC has approved the application.

The calendar gives exchanges a fixed first test. Rule 6a-2(b) requires Exhibits D and I as of the latest fiscal year end on or before 30 June each year, so the 2027 annual amendment is the first annual Exhibit I filing due after the paper route closes. The next triennial filing under Rule 6a-2(c) falls on 30 June 2028.

Converting a paper CIK before the first electronic filing

For both the ANE notice and Form 1, the release adds the same instruction: filers who have not filed electronically on EDGAR before must submit Form ID to convert their CIK from paper to electronic filing. It points to the SEC.gov guidance for applicants with an EDGAR CIK account but no access codes, and specifically to the route for a broker-dealer or “paper filer” seeking electronic access for the first time.

The heading of that guidance states the trap. A CIK assigned through FINRA WebCRD or through earlier paper filings comes without EDGAR access codes. The SEC’s guidance covers exactly that population: applicants who have made only paper filings, or who hold a CIK from a related filing system such as FINRA WebCRD.

The applicant logs into the EDGAR Filer Management website with Login.gov individual account credentials, opens “Apply for EDGAR Access,” selects an existing EDGAR account, enters the CIK, picks the broker-dealer or paper filer option, and completes the Form ID that appears. Approval is emailed to the account administrators named on the application. The SEC’s Form ID page states that individuals and single-member companies list one account administrator and all other filers list two. Volume II’s own filing checklist starts from the same place, asking whether the filer has individual account credentials and a user or account administrator role, with a reference to the EDGAR Filer Access and Account Management release (Release No. 33-11313, 89 FR 106108) and Rule 10 of Regulation S-T.

SEC staff review each Form ID before access is granted, which puts a lead time in front of the 1 January 2027 and 2 March 2027 cutovers.

Release 26.3 specification changes for filing agents

The Federal Register release describes four changes. The SEC’s technical specifications page shows more, because several Release 26.3 changes live only in the specifications.

The SBS Entity Forms changes affect security-based swap entities and their agents, and none of them appears in the Federal Register release. The specification’s summary of changes for Release 26.3 lists more than the four items below. It also corrects maximum lengths (firstName 40 to 30, suffix 30 to 10, phone 9 to 20, signerTitle 150 to 60, irsEmplIdentNo 150 to 9) and requirement indicators in Tables 3.6, 3.8 and 3.9, so check the full summary before changing a build. Four of its items:

• raised the maximum length of the Street1 and Street2 address fields from 40 to 150 characters in the service of process section of SBSE-BD and the address sections of SBSE-W;
• added LIVE_TEST_TYPE constraints for SBSE-BD, SBSE-W and SBSE-CCO-RPT, and BASE_DOCUMENT_TYPE constraints for SBSE-BD and SBSE-CCO-RPT;
• corrected a typo in table 3.4, where an element listed as filerCik is filerCcc;
• changed the flags and overrideInternetFlag fields from mandatory to optional for SBSE-BD, SBSE-W and SBSE-CCO-RPT, “to accurately reflect the system behavior.”

The last item means the previous table overstated what EDGAR required. The typo correction cuts the other way: anyone who coded from the table text, rather than the schema file, picked up the wrong element name.

The ANE specification adds a warning that applies to every filer-constructed format: the schema files cannot enforce every content rule, and a submission can satisfy all the schema constraints and still be suspended by EDGAR. The release offers TEST submissions on production EDGAR from 14 September 2026, alongside the Beta environment.

Frequently Asked Questions

We email an ANE Exception Notice in December 2026 and need to withdraw it in February 2027. Which channel do we use?

From 1 January 2027 the release accepts ANE withdrawals only through EDGAR, as an ANE EXCEP NOTICE-W submission or a filer-constructed equivalent. The release does not describe how an EDGAR withdrawal identifies a notice that was originally sent by email, so the mechanics are worth confirming with the Division of Trading and Markets before the withdrawal falls due. Rule 3a71-3(d)(1)(vi) requires a prompt withdrawal once the registered entity no longer meets paragraph (d)(1).

Does the 11 September 2026 exemptive order take Form X-17A-5 Part III or Form 17-H off EDGAR?

No. The order exempts Form X-17A-5 Part III, Form 17-H, the SBS Entity chief compliance officer report, Form CA-1 (except Exhibit H) and Form 1 (except Exhibit I) from the Inline XBRL format requirement. It states that it provides no exemption from the requirement to file or submit those forms and reports electronically on EDGAR. The format relief and the channel requirement are separate.

Can an exchange redact information in an Inline XBRL Exhibit I?

The EDGAR XBRL Guide’s table of instance types and acceptable formats marks redaction as allowed for AF.SRO, the Exhibit I instance type, and section 11.17 of the guide sets out how redaction works in Inline XBRL. Whether particular information may be withheld from a Form 1 is a question for the Exchange Act confidentiality rules, which the guide does not decide.

A procedures manual records which Filer Manual version governed each filing. What goes in the record for a filing made on 20 September 2026?

Two facts that do not line up. EDGAR was running Release 26.3, and Volume II Version 78 is dated 14 September 2026. Rule 301 as published in the Code of Federal Regulations named Version 77 until the amendment took effect on 6 October 2026. The release explains the short effective date as a way to coordinate the manual with the system upgrades; it does not address filings made in the gap.

Our exchange posts its rulebook on its website. Does the Form 1 interface support that instead of uploading Exhibits A and B every triennial cycle?

The interface has a “Provide Alternative Means” action for the exhibits that Rule 6a-2(d) covers: Exhibits K, M and N in annual filings and Exhibits A, B, C and J in triennial filings. It offers three options: Rule 6a-2(d)(1), available by publication; (d)(2), available upon request; and (d)(3), available on a website the exchange controls, with a certification that the information is accurate and freely accessible to the public, plus the URL. Whether a given exchange qualifies is a Rule 6a-2(d) question, outside what the interface can test.

An action on 23 February 2027 triggers a Rule 6a-2(a) amendment due within 10 days. Paper or EDGAR?

EDGAR. The Version 78 release says Form 1 and its variants may be filed on paper until 1 March 2027, but Release No. 33-11386, which sets the compliance date, applies the new Form 1 requirements, including the amended Rules 6a-1 to 6a-3 that require electronic filing on EDGAR, to filings due on or after 2 March 2027. On that text, an amendment triggered on 23 February 2027 falls due on 5 March 2027 and comes under the electronic requirement even if it is ready before 2 March. Filing it LIVE on EDGAR, where Form 1 submissions have been accepted since 14 September 2026, satisfies both releases.

Related Articles

• Form PF Reporting: Thresholds, Deadlines and the July 2027 Form Switch: SEC Form PF thresholds, filing deadlines and the postponed compliance date for private fund advisers.
• ESMA ESEF Taxonomy 2025: What Changes for 2026 IFRS Filings: the ESEF taxonomy update of 21 April 2026 and what issuers and software vendors need to change.
• ESRS XBRL Taxonomy: Digital Tagging Before the Mandate: EFRAG’s draft XBRL taxonomy for sustainability reporting and the consultation around it.
• FR 2028 Reporting: New FR 2028D Questions, Redesign Still Pending: another US reporting form update from late September 2026, with its proposed redesign still pending.

Key Takeaways

• Map each non-U.S. affiliate relying on Rule 3a71-3(d) to the registered entity that files its ANE notice, and confirm that entity’s EDGAR access ahead of 1 January 2027.
• Exchanges: build and TEST the Exhibit I Inline XBRL instance (AF.SRO) before the first Form 1 or 1/A-A submission that includes Exhibit I; the last paper day for Form 1 and its variants is 1 March 2027.
• For Form 1 Exhibits D and E, follow the Volume II exhibit table and the 11 September 2026 order (PDF), and read the D, E and I list in section 8.2.42.10 against that order.
• Regenerate 13F XML against eis_13F_Filer.xsd from specification Version 2.0 before the next filer-constructed 13F-HR, 13F-NT or 13F-CTR submission, including amendments.
• Re-key XBRL validation runbooks from manual section numbers (6.5.x) to the EDGAR XBRL Guide’s own sections and the Chapter 6 link.
• Cite the compliance-date extension as Release No. 33-11386, 90 FR 43552 (10 September 2025).

Sources and References

• SEC, Adoption of Updated EDGAR Filer Manual, final rule, Release Nos. 33-11438; 34-106345; 39-2565; IC-36326, 91 FR 63476 (6 October 2026): Federal Register PDF
• SEC rule page for Release No. 33-11438: sec.gov
• SEC, Current EDGAR Filer Manual (Volume I Version 43; Volume II Version 78): sec.gov
• EDGAR Filer Manual, Volume II: “EDGAR Filing,” Version 78 (14 September 2026): PDF
• EDGAR XBRL Guide, prepared by SEC staff (August 2026): PDF
• SEC, EDGAR technical specifications (Form 1, ANE Exception Notice, Form 13F and SBS Entity Forms XML specifications): sec.gov
• EDGAR Form 13F XML Technical Specification, Version 2.0 (September 2026): specification package
• EDGAR ANE Exception Notice XML Technical Specification, Version 1.0 (September 2026): specification package
• EDGAR SBS Entity Forms XML Technical Specification, Version 2.0 (September 2026): specification package
• SEC, Form 13F (SEC 1685, 07-23), General Instructions and Special Instructions: PDF
• SEC, Order Granting Exemptive Relief from Inline XBRL Requirements for Portions of Form CA-1 and Form 1 and for Form X-17A-5 Part III, Form 17-H, and Security-Based Swap Entity’s Annual Compliance Report, Release No. 34-106339 (11 September 2026): PDF
• SEC, Extension of Compliance Dates for Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report, Release Nos. 33-11386; 34-103877; IC-35738, 90 FR 43552 (10 September 2025): Federal Register PDF
• SEC, Electronic Submission of Certain Materials Under the Securities Exchange Act of 1934; Amendments Regarding the FOCUS Report, Exchange Act Release No. 101925 (16 December 2024), 90 FR 7250 (21 January 2025): Federal Register
• SEC, Adoption of Updated EDGAR Filer Manual, Release No. 33-11411 (issued 16 March 2026; published 16 April 2026): sec.gov
• 17 CFR 240.3a71-3 (2025 edition), including paragraph (d)(1)(vi): govinfo
• 17 CFR 240.6a-2, Amendments to application (2025 edition): govinfo
• 17 CFR 240.6a-3, Supplemental material to be filed by exchanges (2025 edition): govinfo
• 17 CFR 240.6a-1, Application for registration as a national securities exchange or exemption from registration based on limited volume (2025 edition): govinfo
• SEC, Apply for EDGAR Access: Applicants with an EDGAR CIK Account but No Access Codes: sec.gov
• SEC, Prepare and Submit My Form ID Application for EDGAR Access: sec.gov

The first EDGAR-only dates on the calendar

The first cutover is 1 January 2027, and it belongs to the ANE notice. By then a registered broker-dealer or security-based swap dealer filing an ANE notice will need EDGAR credentials under its own CIK, an approved Form ID if that CIK has only been used on paper, and the notice document in .htm, .txt or .pdf for an ANE EXCEP NOTICE submission. Exchanges follow on 2 March 2027, when Form 1 and all eight of its variants move to EDGAR.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.