Upcoming Deadline for New Structured Data Requirement for Schedule 13G and 13D Filings

As part of the SEC’s 2023 amendments to the rules governing beneficial ownership reporting on Schedules 13G and 13D, the SEC adopted rules that require these filings to be made using a structured, machine-readable data language (XML) in order to make it easier for market participants to access, compile and analyze the information in Schedule 13G and 13D filings.  Filers need to comply with this requirement starting on Dec. 18, 2024.

While there are no changes to the substantive disclosure requirements, the new structured data requirement may necessitate certain formatting and other technical changes.  

If you are using an outside printer or third-party software to make your filings, we recommend contacting your printer or vendor to ensure that the filings will be made in compliance with the new structured data requirement no later than Dec. 18, 2024.

Authored by Ele Klein, Adriana Schwartz, Clara Zylberg, Brandon S. Gold and Arelys Reyes.

If you have any questions concerning this Alert, please contact your attorney at Schulte Roth & Zabel or one of the authors. 

---

This communication is issued by Schulte Roth & Zabel LLP for informational purposes only and does not constitute legal advice or establish an attorney-client relationship. In some jurisdictions, this publication may be considered attorney advertising. © 2024 Schulte Roth & Zabel LLP. All rights reserved. SCHULTE ROTH & ZABEL is the registered trademark of Schulte Roth & Zabel LLP.