SEC Proposal to Make Electronic Delivery the Default - What Firms Need to Know

What the source says:

The Journal of Accountancy describes an SEC proposal that would permit a range of regulated entities - including issuers, broker-dealers and investment advisers - to send communications to investors electronically as a default, without first obtaining affirmative consent. The reporting frames this as a change from the current consent-first approach to a model that presumes electronic delivery is acceptable unless otherwise specified.

Why this matters to CPA firms:

If the SEC adopts a default e-delivery regime, firms that serve SEC-registered clients or that support reporting and investor communications functions will likely need to reassess document production and distribution workflows. Administrative steps currently devoted to collecting and documenting affirmative consent could diminish, shifting labor from consent management to ensuring secure, auditable e-delivery mechanisms and fallback processes for clients who still require paper.

Practical implications for workflows and risk management:

Firms providing accounting, tax, or advisory services to affected clients should evaluate how e-delivery changes impact evidentiary trails, record retention, and client communications policies. Systems and controls will need to demonstrate that electronic delivery was successful and that investor preferences or opt-outs are respected. That can increase demand for IT integration, secure portals, and change controls - potentially increasing upfront costs even as recurring administrative tasks fall. From a professional judgment and compliance perspective, auditors and advisers will need documented procedures that address authentication, delivery confirmation, and potential regulatory or client-specific exceptions, and to consider how these practices affect liability and client service economics.