SEC Guidance on Government Shutdown: What Filers Should Know

October 1, 2025

A government shutdown is in effect as of Oct. 1, 2025, and this will impact some SEC operations related to filings. As of yesterday, the Division of Corporation Finance has updated their guidance during a government shutdown. We can also rely on the SEC’s Operations Plan Under a Lapse in Appropriations and Government Shutdown.

Below, we’ve outlined some key points filers should consider during this time.

The EDGAR filing system will remain open during a shutdown.

• Filers will be able to electronically submit all filings under the Securities Act of 1933 or the Securities Exchange Act of 1934.
• All filing deadlines will still apply and days leading up to a filing deadline during a shutdown will still be considered “business days.”
• Filers can continue to enroll in EDGAR Next and submit Form IDs to gain EDGAR access.

Registration statements will be affected.

• The SEC will not review or grant approvals for applications for registration submitted by entities such as investment advisers, broker-dealers, transfer agents, nationally recognized statistical rating organizations, investment companies, and municipal advisors.
• EDGAR will accept registration statements and other filings; however, during a shutdown, the SEC will not be able to review or accelerate the effectiveness of registration statements.

The Division of Corporation Finance and Division of Investment Management activities will be limited.

• The Division of Corporation Finance will not be able to accelerate the effectiveness of registration statements.
• The Division of Corporation Finance will not be able to review or respond to other requests for written or oral guidance on legal and interpretive questions during a shutdown.
• The Division of Corporation Finance will not post Correspondence submissions or provide responses to comment letters, however, they will continue to be accepted on EDGAR.
• The Division of Corporation Finance will not review or respond to 14a-8 no-action requests during a shutdown.
• The Division of Investment Management will not be available to respond to any inquiries regarding pending matters.
• The Division of Investment Management will have limited staff available to answer fee-related questions.

What does this mean for me?

All filers should continue to submit all filings in a timely manner. While the Division’s activities will be limited, EDGAR will remain open, and the SEC recommends all filers continue to submit filings, as filing deadlines will remain unchanged. Additionally, if a filer is not already enrolled in EDGAR Next, we suggest enrolling as soon as possible and prior to any upcoming filing deadlines to avoid interruptions when filing.