On March 12, 2026, the SEC staff issued two new FAQs related to the Holding Foreign Insiders Accountable Act (HFIA Act). The FAQs noted the HFIA Act requirements are resulting in an unusually large number of EDGAR access applications, which suggests that the staff may be unable to provide EDGAR codes for all applicants in advance of the March 18, 2026, filing deadline. As a result, the staff provided limited no-action relief from the filing requirements. Specifically, the FAQs state that the staff will not recommend enforcement action against a director or officer of a foreign private issuer, or a domestic issuer, for the untimely filing of a Section 16(a) report caused by lack of EDGAR code access as long as specified conditions are met—including having filed the Form ID application and required documentation to obtain EDGAR codes before March 18, 2026. The person must file the report as soon as possible, but no later than April 1, 2026. In the case of domestic issuers, the FAQs clarify that any late filings must still be disclosed in the issuer’s proxy statement per Item 405 of Regulation S-K.Continue Reading SEC Gives Enforcement Relief to Section 16 Persons of Foreign Private Issuers—and Domestic Issuers—If They Are Unable to Timely File Because They Cannot Obtain EDGAR Codes in Time