FINRA Updates Electronic Filing Requirements for Broker-Dealers

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The Financial Industry Regulatory Authority (FINRA) has released an Information Notice on November 14, 2025, announcing important amendments to the electronic filing process for broker-dealer annual reports and Financial and Operational Combined Uniform Single (FOCUS) filings. These updates, which align with the SEC’s broader shift toward fully electronic submissions under SEA Rule 17a-5, represent more than just a procedural change — they carry significant implications for how broker-dealers prepare, sign and file their financial statements.

As an accounting and advisory firm, we want our clients and industry partners to understand that these amendments will directly affect audit coordination, filing workflows and document retention practices. The move to electronic filing and e-signatures introduces both efficiencies and new compliance considerations that firms need to address before their next reporting cycle.

Under the new guidance, the overall amendments were as follows:

Electronic Signatures

• Electronic signatures are now permitted for all reports required to be filed pursuant to SEA Rule 17a-5, including the Annual Report and the FOCUS report.
• The instructions for the FOCUS Report Part II and Part IIA have been revised to require the signature of a single principal officer — specifically, either the principal executive officer or the principal financial officer (or their equivalent).

Oath or Affirmation

• The requirement to have the “Oath or Affirmation” accompanying the annual report notarized has been removed.

Electronic Submission of Annual Reports, Supplemental Reports and Form 17-H on Electronic Data Gathering, Analysis and Retrieval (EDGAR)

• Member firms must now submit an audited annual report to the SEC electronically through the FINRA Gateway. The SEC will no longer accept paper submissions of the Annual Report, as well as the supplemental reports and statements filed.
• Every member must obtain EDGAR access credentials in order to submit their filings to the SEC.
• Instructions on how to file annual reports through EDGAR may be found on the SEC website at: Electronic Filing of Form X-17A-5 Part III (Broker-Dealer, Security-Based Swap Dealer, and Major Security-Based Swap Participant Annual Reports)

Interactive Data File Requirement

The SEC’s amendments require all broker-dealers to submit their annual and supplemental reports under SEA Rule 17a-5, as well as Form 17-H under SEA Rule 17h-2T, as “Interactive Data Files” in accordance with Rule 405 of Regulation S-T. In the Extension Release, the SEC postponed the compliance dates for these requirements as follows:

• For firms with a minimum fixed-dollar net capital requirement of $250,000 or more as of December 31, 2025, the requirements will apply to filings due on or after June 30, 2027.
• For firms with a minimum fixed-dollar net capital requirement of less than $250,000 as of December 31, 2025, the requirements will apply to filings due on or after June 30, 2029.

FINRA encourages firms to review their internal systems and filing procedures to ensure they meet these updated electronic requirements ahead of their next reporting cycle. Member firms that have not previously filed on EDGAR should plan accordingly and give themselves sufficient time.

Read FINRA’s full Information Notice here.

Contact Us

If you have questions about how these updates could affect your reporting process, please contact your PKF O’Connor Davies client service team or:

Anthony Sebastiani, CPA, CFE, MBA
Manager
asebastiani@pkfod.com | 646.449.6354

Victor Peña, CPA, CGMA
Partner
vpena@pkfod.com | 646.449.6380

Rachel DiDio, CPA
Partner
rdidio@pkfod.com | 954.947.3941

Don Melody, CPA, CFE
Partner
dmelody@pkfod.com | 646.893.0178