2025-21826Notice

SEC clings to S-3 form, burdening firms with massive paperwork costs

Published Date: 12/3/2025

Notice

Summary

The SEC is asking to keep using Form S-3, which companies use to register their securities and share important info with investors. About 1,467 companies file this form yearly, spending lots of time and money—over $300 million—mostly on outside experts. You can comment on this plan until January 5, 2026, so don’t miss your chance to speak up!

Analyzed Economic Effects

3 provisions identified: 1 benefits, 2 costs, 0 mixed.

High external professional fees to prepare Form S-3

The SEC estimates 75% of the 458.87 hours per filing is performed by outside professionals at an estimated $600 per hour. That external work creates an estimated annual cost burden of $302,923,031 across all filers.

Large annual time burden for issuers

Companies that file Form S-3 spend about 458.87 hours on the form once per year. About 1,467 issuers file it annually, and the SEC estimates 25% of that time is handled internally for a total annual internal burden of 168,291 hours.

Form S-3 makes issuer information public on EDGAR

Form S-3 collects information that the SEC says is intended to ensure adequate information for investors, and the completed Form S-3 is publicly available on the SEC's EDGAR system. This means people who invest can view issuer disclosures filed on Form S-3.

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Key Dates

Published Date
12/3/2025

Department and Agencies

Department
Independent Agency
Agency
Securities and Exchange Commission
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