- with Finance and Tax Executives
- in United Kingdom
- with readers working within the Accounting & Consultancy, Banking & Credit and Construction & Engineering industries
Guy Ben-Ami writes about a reminder for Form 3 Obligation.
Effective March 18, 2026, directors and officers of foreign private issuers (FPIs) must comply with SEC Section 16(a) reporting, ending previous exemptions.
Insiders must file an initial Form 3 by this date, followed by Form 4 within two business days for subsequent trades.
Key steps include obtaining EDGAR credentials, identifying insiders, and mapping ownership.
Steps by March 18, 2026:
Obtain EDGAR Access: Directors and officers must obtain credentials for the EDGAR Next system, which requires filing a notarized Form ID.
File Initial Form 3: All directors and officers (as defined under Rule 16a-1(f)) must file an initial Form 3, disclosing beneficial ownership of all equity securities.
Establish Reporting Procedures: Set up internal processes to report changes in ownership on Form 4 within two business days.
Identify Section 16 Insiders: Determine which individuals qualify as officers under the new rules.
This change, driven by the Holding Foreign Insiders Accountable Act (HFIAA), applies to all FPIs with equity securities registered under Section 12 of the Exchange Act. Unless further exemptions or extensions are announced.
We have partnered with an online notary as well, that can help you notarize your forms and gain access to EDGAR, if you need it.
We can guide you throughout the process in the most efficient way.
For further details: https://www.clm.com/foreign-private-issuers-must-report-all-insider-trades-section-16a-march-2026/
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
