Emergency Rule 3-13 waiver requests during a government shutdown

Hot Topic | October 2025

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

The SEC’s Division of Corporation Finance (Corp Fin) issued a Q&A on emergency Rule 3-13 waiver requests made during a US federal government shutdown.

Update on November 13, 2025. With the re-opening of the US federal government, Corp Fin has resumed normal operations. Beginning on November 13, 2025 , companies should follow the process to submit requests for Rule 3-13 waivers as detailed in the SEC’s Financial Reporting Manual. To assist companies that filed registration statements and other forms during the government shutdown, Corp Fin published another set of Q&As that are intended to help companies address common questions associated with pending filings made during the shutdown. You can learn more about these Q&As here

Applicability

SEC.gov | Division of Corporation Finance

  • Public companies, including domestic and foreign private issues
  • Companies that have filed or will be filing registration statements in public offerings during a government shutdown

Relevant dates

  • Effective during US federal government shutdowns

Key impacts

During a US federal government shutdown, the SEC is usually closed, except for limited essential personnel. As a result of a shutdown and limited resources available, waiver requests under Rule 3-13 of Regulation S-X will only be considered by the staff of Corp Fin in emergency situations.

This publication discusses:

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

Report contents

  • Source and applicability
  • Fast facts, impacts and actions
  • Emergency waiver requests
  • 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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