DRS Submissions for EDGAR: How Confidential Draft Filings Work

A DRS submission is a draft registration statement a company sends to the SEC through EDGAR for staff review before the offering becomes public. It is a real EDGAR submission type, but it stays confidential: nobody outside the SEC and the company sees it until the company later makes its offering public, at which point the draft and any amendments to it appear on EDGAR alongside the public filing.

What a DRS submission actually is

Form DRS is the EDGAR submission type for a nonpublic draft of a registration statement, most often the draft of an S-1 or F-1 ahead of an IPO. The company builds it in EDGAR like any other filing, under the EDGARLink Online submission process, but marks it for confidential staff review rather than public release. A confidential DRS submission does not count as a "filing" for purposes of Section 5(c) of the Securities Act, which is what lets a company get SEC staff comments on its draft before the securities offering is publicly announced.

Who can use a DRS submission, and how that has grown

The DRS process did not start open to every company:

The 2025 guidance, issued by the SEC's Division of Corporation Finance staff, removed the prior limits tied to how recently a company became a reporting company and extended confidential review to Section 12(b) and 12(g) registrations. The condition attached to that broader category: the issuer must confirm in a cover letter that it will publicly file the registration statement, with the public filing coming at least two business days before any requested effective date.

How the submission and public filing fit together

A DRS submission by itself changes nothing about what the public can see on EDGAR. The sequence that makes a draft registration statement visible looks like this:

1. The company submits Form DRS (and any DRS/A amendments) confidentially through EDGAR while SEC staff review it.
2. Once the staff review is substantially complete, the company publicly files the registration statement itself, for example an S-1 or F-1, which is a normal public EDGAR filing.
3. At that point, EDGAR also discloses the earlier DRS and DRS/A submissions, so the public record shows the draft history alongside the final public filing.

Because of that last step, a DRS submission only becomes visible in EDGAR full text search or in a filing index search after the company has already decided to go forward publicly. There is no way to see a company's confidential draft while it is still under nonpublic review, by design.

Finding DRS filings once they are public

Once a DRS submission is disclosed, it is a normal EDGAR filing with its own accession number and form type, so it can be searched the same way as any other filing type. SecFeed's filing search covers every EDGAR filing, including disclosed DRS and DRS/A submissions, by form type and company:

curl -G "https://secfeedapi.com/v1/filings" \
  --data-urlencode 'query=formType:"DRS" AND cik:1830029' \
  -H "Authorization: Bearer YOUR_API_KEY"

from secfeed import Client

sf = Client("YOUR_API_KEY")
drs_filings = sf.filings(query='formType:"DRS" AND filedAt:[2026-01-01 TO 2026-10-31]', size=20)
for f in drs_filings["data"]:
    print(f["filedAt"][:10], f["companyName"], f["accessionNo"])

This returns the same filing record structure as a search for any other form, with cik, companyName, filedAt and accessionNo, so a DRS search slots into an existing EDGAR search workflow rather than needing separate handling. For the full set of search fields, including filtering by a date range or combining form types in one query, see the filings search reference.

Why DRS data looks thinner than other form types

Because confidential drafts stay hidden until a company chooses to go public, and because not every company that files a DRS ultimately completes its offering, the disclosed DRS record will always undercount how many draft registration statements the SEC actually reviewed. A company that withdraws its offering before filing publicly leaves no public trace of its DRS submission at all. Keep that gap in mind if you are trying to measure IPO or follow-on pipeline activity from DRS filings alone, rather than treating the public DRS count as the full picture of confidential review activity.

Frequently asked questions

Is a DRS submission the same as filing an S-1?

No. A DRS submission is a confidential draft, typically of an S-1 or F-1, submitted for SEC staff review before the company commits to a public offering. The S-1 or F-1 itself is the public registration statement the company files once it is ready to proceed, at which point the earlier DRS submissions also become public.

Who can submit a DRS confidentially today?

As of SEC staff guidance issued March 3, 2025, nearly any issuer can submit an initial registration statement confidentially as a DRS, including companies that have been public reporting companies for a while and de-SPAC transactions, and the accommodation now reaches Exchange Act registrations on Forms 10, 20-F and 40-F, not just Securities Act offerings.

When does a DRS submission become public?

It becomes public once the company publicly files the related registration statement, which EDGAR then shows alongside the previously confidential DRS and any DRS/A amendments. The company must publicly file before the offering can become effective, and recent SEC staff guidance requires that public filing at least two business days before any requested effective date for issuers using the broadened 2025 accommodation.

What is DRS/A?

DRS/A is an amendment to an already submitted DRS, filed the same way, confidentially, while the original draft is still under nonpublic SEC staff review. Like the original DRS, it only becomes public once the company files the registration statement publicly.

Can I find a company's DRS submission before it goes public?

No. A DRS submission that is still under confidential review is not visible on EDGAR to the public under any search, including EDGAR full text search, because it has not been disclosed yet. You can only find it after the company publicly files its registration statement.