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Emergency Rule 3-13 waiver requests during government shutdown

Hot Topic | October 2025

KPMG highlights the SEC’s Q&A on requests for emergency relief under Rule 3-13 during the government shutdown. 

The SEC’s Division of Corporation Finance issued a Q&A on emergency Rule 3-13 waiver requests. We offer insights into seeking emergency relief during the US federal government shutdown. 

Applicability

SEC.gov | Division of Corporation Finance

  • Public companies, including domestic and foreign private issuers

Relevant dates

  • Effective immediately

Key impacts

On October 1, 2025, the SEC closed, except for limited essential personnel, resulting from the partial US federal government shutdown. 

Waiver requests under Rule 3-13 of Regulation S-X will only be considered by the staff of the SEC’s Division of Corporation Finance (Corp Fin) in emergency situations.

This publication discusses:

  • the Corp Fin Q&A on emergency relief under Rule 3-13 during the shutdown;
  • considerations for determining whether an emergency exists; and
  • requirements for submitting an emergency relief request.

Report contents

  • Applicability
  • Fact and impacts
  • Emergency waiver requests
  • KPMG observations
  • Additional Corp Fin Q&As

Download the document:

Rule 3-13 waiver

Download PDF

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Timothy Brown
Partner, Dept. of Professional Practice, KPMG US
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Erin McCloskey
Partner, Dept. of Professional Practice, KPMG US

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