The Ultimate 2025 Year-End Compliance Checklist for IR Teams

The year-end sprint is on. For your Investor Relations team, the time between now and the end of Q1 2026 will be packed with financial reporting, proxy statements, and regulatory filings.

But there’s also a shift happening. Alongside the usual deadlines, the SEC has launched a new Cyber and Emerging Technologies Unit, scheduled public discussions on AI-related disclosure impacts, and paused or revisited portions of its climate and ESG rulemaking.

In Canada, the CSA has paused work on its proposed climate and diversity disclosure rules while reminding issuers that material climate risks must still be disclosed under existing securities law.

Navigating this isn’t just about meeting deadlines. It’s about protecting your market credibility, clarity, and investor trust.

We built this guide to be your single source of truth for the season. It’s not just a list of dates — it’s a strategic checklist designed to help your team stay aligned, informed, and ready for 2026.

Short on time?  Download the complete 2-page PDF checklist to print and share with your team.

1. Immediate Action Required: The Final EDGAR Next Cutoff (Dec 19)

Before looking at 2026 dates, there is one immediate hurdle for U.S. Filers.

The initial EDGAR Next deadline passed on September 15, 2025. If you have not yet enrolled, your ability to file is currently blocked.

• The Window: You can still enroll via the dashboard until Friday, December 19, 2025.

• The Risk: If you miss this December 19 cutoff, you can no longer self-enroll. You will be forced to submit an Amended Form ID, which requires manual SEC review and additional documentation.

• Action Item: Do not risk entering the 10-K season with a blocked account. If you are unsure of your status, contact the TMX Newsfile filing desk.

2. Your 2026 Key Filing Deadlines (U.S. & Canada)

First, let's lock in the dates. Missing these is not an option. The following table assumes a December 31, 2025, fiscal year-end.

U.S. SEC EDGAR Deadlines

Filing	Filer Status	Deadline (Days after FYE)	2026 Due Date
Form 10-K	Large Accelerated Filer	60 days	Monday, March 2, 2026
Form 10-K	Accelerated Filer	75 days	Monday, March 16, 2026
Form 10-K	Non-Accelerated Filer	90 days	Tuesday, March 31, 2026
Form 13F (Q4)	Institutional Managers	45 days after quarter-end	Tuesday, February 17, 2026
Proxy (DEF 14A)	All Filers	120 days after FYE	Thursday, April 30, 2026

• Pro Tip: Your Form 10-K and your Annual Report to Shareholders are separate. Ensure your TMX Newsfile distribution, your 10-K filing, and your website update are perfectly coordinated.

Canadian CSA SEDAR+ Deadlines

Filing	Issuer Type	Deadline (Days after FYE)	2026 Due Date
Annual Fin. Statements	TSX Issuers	90 days	Tuesday, March 31, 2026
Annual Fin. Statements	TSX Venture Issuers	120 days	Thursday, April 30, 2026
AIF, MD&A	All (non-Venture)	90 days	Tuesday, March 31, 2026
AIF, MD&A	TSX Venture Issuers	120 days	Thursday, April 30, 2026

• SEDAR+ Check-in: The March 2025 updates to SEDAR+ refined prospectus filing and fee calculations. Ensure your profile's "Type of investment fund" and "Category of investment fund" are correct to avoid fee miscalculations.

3. Four Disclosure Hotspots to Review Now (U.S. & Canada)

Deadlines are just one part of the challenge. The content of your disclosures is under more scrutiny than ever. Here are the three topics that must be on your radar for your 2025 10-K and 2026 proxy.

Cybersecurity: The 4-Day Rule is in Effect

The SEC's new cybersecurity rules are no longer hypothetical.

• What's New: You now have four business days to disclose a "material" cybersecurity incident via Form 8-K.

• Your Year-End Action: This isn't just an IR task; it's an enterprise-wide one. Your 10-K must now include a detailed description of your "processes for assessing, identifying, and managing material risks from cybersecurity threats."

• Key Question: Does your IR team have a direct, 24/7 line to your CISO and legal counsel? You must be able to close the loop from detection to determination of materiality to filing within that 4-day window.

Artificial Intelligence: The Rise of "AI Washing"

There is no "Form AI," but SEC scrutiny is extremely high. SEC Chair Gensler has been clear: if you are making claims about AI, they must be accurate.

• What's New: Investors and regulators are actively hunting for "AI washing"—making misleading claims about your AI capabilities to boost your stock price.

• Your Year-End Action: Review your 10-K Risk Factors and MD&A.

  • Are you using AI? Disclose how it impacts your business, financial performance, and potential risks (e.g., data privacy, "hallucinations," model integrity).

  • Are you not using AI? You may need to disclose if not adopting AI poses a material competitive risk.

• Key Question: Are your marketing claims about AI supported by the same evidence as your financial statements?

ESG & Climate: Prepare for Data-Driven Disclosures

With the CSA pausing new climate-related rules, the core requirement remains the same: if climate risks are material, they must still be disclosed in your AIF, MD&A, 10-K, or proxy — just like any other business risk.

What’s New: Canada now has voluntary CSDS 1 and CSDS 2 standards, aligned with ISSB S1 and S2. They aren’t mandatory, but they’re quickly becoming a go-to reference for credible climate and sustainability reporting, and the CSA has encouraged issuers to use them when preparing voluntary disclosures.

Your Year-End Action: Treat climate and ESG as part of your financial risk narrative, not a separate sustainability story. Make sure any ESG or sustainability reporting aligns with what appears in your regulatory filings.

Key Question: Can your team clearly show how climate-related risks or opportunities may affect performance or long-term strategy?

Reviewing Your Risk Factors & Safe Harbor Language

This is the perfect time to ensure your "Forward-Looking Statements" (Safe Harbor) language isn't on autopilot. Your boilerplate from last year may not adequately cover the new, less predictable risks you're facing.

Your Year-End Action: Review your risk factors and safe harbor disclaimer with legal counsel. Ask: Does our language specifically account for the uncertainties of new technologies like AI, the unpredictable nature of cybersecurity threats, or the evolving landscape of climate-related events? Updating this language is a critical, high-level exercise to protect your leadership.

4. Your Downloadable PDF: The Ultimate Checklist

This is a lot to manage. To help you and your team stay aligned, we've distilled all these deadlines, new rules, and best practices into a single, two-page PDF.

Use this checklist to:

• Align your IR, Legal, Finance, and IT teams.

• Verify every step in your filing process.

• Ensure no new disclosure requirement is missed.

CLICK HERE TO DOWNLOAD YOUR FREE 2025 YEAR-END COMPLIANCE CHECKLIST PDF

5. Beyond the Filing: How TMX Newsfile Is Your Partner

A flawless year-end is about more than just hitting "submit" on EDGAR and SEDAR+. It's about ensuring your message reaches the market with confidence and clarity.

This is where we help.

• 24/7/365 Expert Support: Our filing desk has successfully managed over 200,000 regulatory filings. When you're working late on a Friday before a deadline, so are we. We are your fail-safe.

• Seamless SEDAR+ & EDGAR Integration: We are not just experts in one system. We are a single, seamless partner for all your North American regulatory and distribution needs.

• Amplify Your Message: Don't just file your 10-K. Use TMX Newsfile's unparalleled global distribution to amplify your year-end narrative, ensuring your story reaches key analysts, investors, and financial media at the exact moment it becomes public.

The 2026 reporting season will be the most complex yet. But with the right plan and the right partner, you can navigate it with confidence.

Ready for a smoother filing season? Talk to a TMX Newsfile expert today and see how we can streamline your year-end process.