FINRA Information Notice (11/14/2025): Preparing for Electronic Filing of FOCUS & Annual Reports

FINRA’s latest Information Notice highlights recent SEC amendments under SEA Rule 17a-5 that require broker-dealers to transition fully to electronic filing for Annual Reports and make updates to the FOCUS Report. These changes support the SEC’s broader push toward modernization and digital submission.

Key Updates

• Electronic Filing Now Mandatory: Annual and supplemental reports must be filed on EDGAR in PDF format. Paper submissions will no longer be accepted.
• Compliance Date: Firms must file Annual Reports electronically for fiscal years ending on or after June 30, 2025.
• FOCUS Report Changes: Certain components of the FOCUS Report have been amended; firms will continue to submit through FINRA’s eFOCUS system, but should review changes to the underlying requirements.
• Electronic Signatures Allowed: Electronic signatures are permitted for all SEA Rule 17a-5 filings, provided firms follow the required signing process.
• Record Retention: Signed Oaths or Affirmations must be retained for six years, with the first two years easily accessible.
• Interactive Data (XBRL) Requirements:
  • Firms with ≥ $250,000 minimum net capital (as of 12/31/25): compliance for filings on or after June 30, 2027.
  • Firms with < $250,000 minimum net capital: compliance for filings on or after June 30, 2029.

What Firms Should Do Now

• Secure EDGAR Credentials: Firms new to EDGAR must file Form ID to obtain access.
• Update Internal Processes: Incorporate electronic signatures and ensure electronic retention procedures meet SEC requirements.
• Plan Ahead: Mark all key compliance dates, especially the June 30, 2025 transition to mandatory electronic Annual Report filing.