On February 6, 2026, the Securities and Exchange Commission (SEC) announced that, beginning March 16, 2026, EDGAR will suspend filings that contain incorrect or incomplete structured filing fee-related information, rather than simply issuing warnings. The announcement follows the lengthy phase-in period of the structured filing fee rules that contemplated a transition to suspensions for errors.^[1] Filers and their agents can utilize tools and test filings to avoid errors that could result in filing suspensions.

As background, all fee‑bearing forms—including Forms S-1, S-3, S-4, S-8, and others—must include the full set of required fee‑calculation data in a structured format, enabling automated validation and reducing the volume of manual error‑corrections historically borne by SEC staff. Since July 31, 2025, all filers have been required to comply with the amended rules.

The SEC announcement directs filers to several key resources, including the EDGAR Filer Manual, the XBRL Guide, and the EDGAR Filing Fee Interface Courtesy Guide, as well as the SEC’s “How Do I: Prepare an Inline XBRL Filing Fee Exhibit” resource for detailed instructions on meeting these requirements.

Filers should continue to review carefully their fee-calculation tables and filing fee exhibits to ensure accurate and complete information. They should also continue to work closely with their third-party filing services providers in applying the SEC’s Filing Fee Disclosure (FFD) taxonomy and engaging in pre‑submission validation processes.

^[1] See Filing Fee Disclosure and Payment Methods Modernization, Release No. 33‑10997, at pg. 40 (Oct. 13, 2021) [86 FR 70166, 70177-8 (Dec. 9, 2021)].