Form IRANNOTICE Files Dataset

The Form IRANNOTICE Files Dataset is a complete EDGAR archive of every Form IRANNOTICE submission filed under Section 13(r) of the Securities Exchange Act of 1934, the disclosure regime created by Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 (ITRSHRA). One record represents one IRANNOTICE accession — the short cover letter that an SEC-registered issuer files concurrently with a 10-K, 10-Q, 20-F, or 40-F whenever the periodic report contains a Section 13(r)(1) disclosure of Iran-related, Hezbollah-related, Syrian-government-related, IRGC-related, or proliferation-related activity by the issuer or any of its affiliates. Each record bundles the IRANNOTICE HTML cover letter, a structured metadata.json view of the EDGAR submission header, and (where archived) EDGAR's complete-submission .txt for the accession. The dataset begins in January 2013 — the first periodic-reporting cycles after the statute took effect — and is delivered as monthly ZIP containers.

Dataset APIs

Dataset Files

What This Dataset Contains

The dataset is built around Form IRANNOTICE, a short, dedicated EDGAR notice form created to satisfy Section 219 of ITRSHRA, which added Section 13(r) to the Exchange Act. Section 13(r) requires a reporting issuer that has, directly or through any affiliate, knowingly engaged in specified Iran-related activities (and a small set of related sanctioned-entity activities involving Hezbollah, Syrian government counterparties, IRGC-designated persons, and certain proliferation-related entities) to (1) include a separate disclosure inside its next Exchange Act periodic report on Form 10-K, Form 10-Q, Form 20-F, or Form 40-F under Section 13(r)(1), and (2) concurrently file a separate notice on EDGAR under Section 13(r)(3) informing the Commission that the periodic report contains such a disclosure. Form IRANNOTICE is the second item. The Commission, on receipt, transmits the disclosure on to the President and to the relevant Congressional committees as required by Section 219.

Functionally the IRANNOTICE document is a one-page cover letter from the issuer to the SEC. It does not restate the underlying activity disclosure; it points the Commission at the periodic report that contains it. Because the obligation is triggered by content already in a 10-K, 10-Q, 20-F, or 40-F, IRANNOTICE filings appear in lock-step with periodic-report filing dates, and the filer population is concentrated in large, internationally exposed registrants — multinational banks, retailers, medical-device makers, basic-materials producers, and other global enterprises whose affiliates or counterparties have touched the Section 13(r) activity list.

The dataset covers the entire IRANNOTICE filer population from January 2013 onward, packaging every submission as a per-accession folder inside monthly ZIP containers. The file types found in the dataset are HTML, JSON, and TXT.

Content Structure of a Single Record

What one record represents

A single record in the Form IRANNOTICE Files Dataset is one EDGAR submission of Form IRANNOTICE, identified by its 18-character accession number. Physically the record is the per-accession folder inside a monthly ZIP container; the folder name is the accession number with hyphens stripped (e.g., accession 0000104169-25-000139 becomes folder 000010416925000139). The folder holds the documents transmitted to EDGAR for that filing together with a metadata.json describing the submission.

One record therefore equals one IRANNOTICE notice filing. It is not one Section 13(r) disclosure event and not one Iran-related transaction. The substantive description of the activity, counterparties, gross revenues, net profits, and the issuer's intent regarding continuation lives in the periodic report that the IRANNOTICE references, not in the IRANNOTICE itself.

Content layout of a single record

A single record consists of two layers inside one accession folder:

1. A metadata.json object that mirrors the EDGAR submission header at the filing level — form type, accession number, filed-at timestamp, filer entity identifiers, document inventory, and canonical EDGAR URLs.
2. The submission's documents as transmitted to EDGAR, with image attachments removed. In practice this is one IRANNOTICE HTML document and, in some monthly archives, EDGAR's complete-submission text file (.txt) for the accession; graphics referenced by documentFormatFiles (rare on this form, e.g., a logo .jpg) are excluded from the archive payload by dataset policy.

The HTML file carries the notice itself, the JSON file carries the structured filing metadata, and the TXT file — when present — is EDGAR's full-submission text bundle (referenced by linkToTxt and by the trailing entry of documentFormatFiles). Filers do not author a standalone ASCII notice; the TXT bundle is mechanically generated by EDGAR.

The IRANNOTICE HTML document

Each IRANNOTICE HTML file is wrapped in EDGAR's SGML document envelope, with the actual notice as inline HTML inside the <TEXT> block. The envelope carries five header tags and the body:

          1
          <DOCUMENT>
        

          2
          <TYPE>IRANNOTICE
        

          3
          <SEQUENCE>1
        

          4
          <FILENAME>irannoticeq22025.htm
        

          5
          <DESCRIPTION>IRANNOTICE
        

          6
          <TEXT>
        

          7
          <html> ... cover-letter body ... </html>
        

          8
          </TEXT>
        

          9
          </DOCUMENT>
        

<TYPE> is always IRANNOTICE. <SEQUENCE> is 1 because the notice is the only substantive document in the submission. <FILENAME> is filer-chosen and varies in form (irannoticeq22025.htm, irannotice829.htm, irannoticeq1fy26.htm, a20250630q2irannotice.htm, livn-2025630xirannotice.htm, and similar patterns that encode the period or quarter). <DESCRIPTION> is a free-text label, conventionally IRANNOTICE.

The HTML body inside <TEXT> is short — typically a single page, on the order of 4 to 7 kilobytes — and follows a stable cover-letter template:

• Issuer letterhead block — company name, principal-office address, and sometimes a telephone or contact line. Often rendered with the issuer's letterhead styling.
• Date line — the date of the notice, usually aligned with the filing date of the related periodic report.
• Addressee block — [U.S. Securities and Exchange Commission](https://www.sec.gov/), the relevant division (commonly the Office of Global Security Risk within the Division of Corporation Finance), and the Commission's Washington, D.C. address.
• Re-line — identifies the related periodic report by issuer name, form type (10-K, 10-Q, 20-F, or 40-F), reporting period, and frequently the Commission file number.
• Body paragraph(s) — states that, pursuant to Section 13(r) of the Exchange Act, the referenced periodic report contains a disclosure of activities described in Section 13(r)(1), and that this notice is being filed pursuant to Section 13(r)(3). Some filers add a sentence cross-referencing the precise location inside the periodic report (commonly Item 5 of Part II of Form 10-Q under "Other Information," or the equivalent placement in Form 10-K) where the disclosure appears.
• Signature block — signatory name, title, and corporate role. Signatories are typically a corporate secretary, deputy general counsel, or senior counsel for finance and corporate governance, rather than an executive officer.

Concrete examples that illustrate the template's stability include Walmart Inc.'s notice signed by Gordon Y. Allison, Senior Vice President and Chief Counsel for Finance and Corporate Governance, referencing the 10-Q for the period ended July 31, 2025; JPMorgan Chase & Co.'s notice signed by Reid R. Broda, Corporate Secretary, referencing the 10-Q for the quarter ended June 30, 2025; and similar one-page cover letters from Medtronic plc, Century Aluminum Co., and LivaNova PLC referencing their respective Q1 FY26 and Q2 2025 quarterly reports. The body never repeats the substantive Iran-related facts; those remain inside the referenced periodic report.

The IRANNOTICE itself contains no structured data of its own beyond what the metadata captures and the cover-letter narrative states. There are no schedules, tables of transactions, counterparty lists, dollar amounts, or tagged fields. Any reader needing the underlying activity description, counterparties, gross revenues, net profits, or stated intent regarding continuation must follow the Re-line back to the referenced 10-K, 10-Q, 20-F, or 40-F.

The metadata.json object

metadata.json is a single JSON object that mirrors the EDGAR submission header for the accession and adds canonical EDGAR URLs. Its fields fall into three groups.

Filing-level descriptors

• formType — always "IRANNOTICE".
• accessionNo — the EDGAR accession number with hyphens preserved (e.g., "0000104169-25-000139").
• filedAt — ISO-8601 timestamp with offset, marking EDGAR acceptance time of the submission.
• description — boilerplate description of Form IRANNOTICE.
• id — an opaque 32-character hex identifier used for cross-referencing within the publisher's catalog.

Link block — direct URLs back to EDGAR for verification or cross-fetching:

• linkToFilingDetails — URL of the primary HTML notice document.
• linkToHtml — URL of the EDGAR filing index page for the accession.
• linkToTxt — URL of the complete-submission text file.
• linkToXbrl — empty string for IRANNOTICE.

Document inventory and entity block

• documentFormatFiles — array of all attachments in the submission. Each element carries sequence, size (bytes, as a string), documentUrl, description, and type. The first element is invariably the IRANNOTICE HTML (type "IRANNOTICE", sequence "1"); the trailing element with a single-space sequence and type is EDGAR's complete-submission TXT. Where a filer attached a graphic — a logo, scanned signature, or letterhead element — it appears here with type "GRAPHIC", but the graphic itself is excluded from the archive payload.
• dataFiles — empty array (IRANNOTICE has no Financial Report data files).
• seriesAndClassesContractsInformation — empty array (the form is not used by investment-company series and classes reporting).
• entities — array of entities tied to the submission. For IRANNOTICE this is always a single filer entity, with the following fields:
  • companyName — registrant name with role suffix (e.g., "Walmart Inc. (Filer)", "JPMORGAN CHASE & CO (Filer)").
  • cik — the registrant's Central Index Key without zero-padding.
  • irsNo, fileNo, filmNo — IRS Employer Identification Number, Commission file number, and EDGAR film number for the submission.
  • fiscalYearEnd — in MMDD form (e.g., "0131" for Walmart, "0424" for Medtronic, "1231" for calendar-year filers).
  • stateOfIncorporation — two-character state code, with non-US issuers carrying EDGAR's foreign codes (e.g., "X0").
  • act — the governing act for the filing; always "34" (Securities Exchange Act of 1934) for IRANNOTICE.
  • sic — SIC code with description (e.g., "5331 Retail-Variety Stores", "6021 National Commercial Banks", "3845 Electromedical & Electrotherapeutic Apparatus").
  • type — "IRANNOTICE".
  • tickers — array of trading symbols for the filer; typically a single common-stock ticker, but financial issuers frequently expose many preferred-share class symbols (a single bank holding company may carry a dozen or more, e.g., JPMorgan Chase listing JPM alongside JPM.PA through JPM.PM, CMB, AMJB, VYLD, and AMJ).

These metadata fields are the principal source of structured, machine-readable information about an IRANNOTICE record, because the HTML body is essentially a free-text cover letter.

What the dataset record includes

• The IRANNOTICE HTML document as filed, retaining the EDGAR SGML wrapper headers (<DOCUMENT>, <TYPE>, <SEQUENCE>, <FILENAME>, <DESCRIPTION>, <TEXT>) and the inline-HTML cover letter inside <TEXT>.
• The full structured metadata.json view of the EDGAR submission header.
• Where archived for that filing, the complete-submission .txt produced by EDGAR — the SGML bundle that concatenates every document in the submission.

What is excluded or held separately

• Image attachments. Any GRAPHIC items listed in documentFormatFiles (logos, scanned letterhead, signature images) are excluded from the archive payload, even though they remain referenced in the metadata inventory.
• The substantive Section 13(r) disclosure narrative. The IRANNOTICE points at the periodic report; the actual description of the Iran-related (or Section 13(r)-listed) activity, the counterparties, the gross revenues, the net profits, and the issuer's stated intent regarding continuation all live inside the related 10-K, 10-Q, 20-F, or 40-F. Those periodic reports are separate EDGAR submissions with their own accession numbers and are not part of this dataset.
• Correspondence and staff interactions. Comment letters, no-action requests, and other staff exchanges tied to the filing are not included.

Stability of structure since 2013

Form IRANNOTICE was created by ITRSHRA in August 2012 and went live on EDGAR in early 2013. Compared with most EDGAR forms it has been remarkably stable. The notice has, since its introduction, consisted of a short cover letter pointing to a periodic report, with no required schedules, exhibits, or tagged data. The document type code (IRANNOTICE), the SGML envelope, the placement of inline HTML inside <TEXT>, the sequence numbering (almost always 1), and the role of the document as a pointer rather than a substantive disclosure have not changed.

The substantive content of Section 13(r) — the list of triggering activities — has been reshaped over time by external policy events: the 2015 Joint Comprehensive Plan of Action and the temporary relaxation of certain Iran sanctions, the 2018 reimposition under Executive Order 13846, and various Treasury OFAC actions on Syria and on additional sanctioned persons. Those policy shifts changed which activities required disclosure and therefore which issuers had a triggering event in any given quarter, but they did not change the structure or required content of Form IRANNOTICE itself. The textual description of the activity, counterparty names, and gross revenues / net profits have remained where they always lived: inside the related periodic report, not inside the IRANNOTICE.

Format conventions

Form IRANNOTICE has, from its 2013 inception, been filed as an HTML notice inside EDGAR's SGML submission envelope. Plain-ASCII .txt notices analogous to the pre-2001 EDGAR norm for many other forms do not occur on this form because IRANNOTICE post-dates EDGAR's HTML era; the TXT file type that appears in the dataset is EDGAR's auto-generated complete-submission bundle, not a separately authored ASCII notice. Inline XBRL and standalone XBRL have never been applicable — linkToXbrl is empty and dataFiles is empty for every record. Format evolution has therefore been minimal: the cover letter was HTML inside SGML in 2013 and remains HTML inside SGML today, with only cosmetic variation in filer-chosen filenames, letterhead styling, and the precise wording of the cross-reference paragraph.

Interpretation and extraction notes

Several anatomical nuances matter for downstream interpretation and extraction:

• The IRANNOTICE is a pointer, not a disclosure. Programs trying to extract counterparties, transaction amounts, or activity descriptions from the notice will return effectively nothing of substance. Resolving an IRANNOTICE to its underlying disclosure requires fetching the related 10-K, 10-Q, 20-F, or 40-F and locating the Section 13(r) discussion (commonly under "Other Information," often Item 5 of Part II in Form 10-Q).
• The Re-line is the principal extractable signal in the cover letter. It typically encodes the form type and reporting period of the related periodic report; combined with entities[0].cik and filedAt from the metadata, it allows reliable linkage from an IRANNOTICE record to the specific periodic-report accession that holds the underlying disclosure.
• Re-line mismatches occur. Filers sometimes mislabel the related report — for instance describing a 10-Q period as an "Annual Report on Form 10-K" — so the Re-line text should be cross-checked against filedAt and the issuer's fiscalYearEnd before being trusted as ground truth.
• The signatory is rarely a Section 16 officer. The signature block should be treated as a corporate-secretarial or general-counsel identifier, not as an executive disclosure. The relevant statute here is Section 16 of the Exchange Act.
• Tickers arrays can be long for financial issuers. Bank holding companies and similar issuers may list many preferred-share class symbols. Downstream join keys should prefer cik over ticker for stability; the first array entry is usually the common-stock symbol when that distinction matters.
• Multi-quarter recurrence is the norm. An issuer with ongoing Section 13(r)-triggering exposure typically files an IRANNOTICE every quarter alongside its 10-Q and again with its 10-K. Each filing is a separate accession and a separate record in the dataset, even when the underlying activities are unchanged from the prior period. Deduplicating to "issuer-quarter" pairs requires using cik together with the periodic-report period parsed from the Re-line, not the IRANNOTICE alone.
• entities always has length one. There is no co-filer, subject-company, or reporting-owner / issuer pairing on this form, so downstream pipelines can flatten entities[0] directly without entity-type branching.
• Image attachments will not resolve on disk. Pipelines that walk the metadata inventory should expect GRAPHIC entries (when present) to be missing from the payload and should fall back to documentUrl when the original image is required.
• The SGML envelope is part of the payload. Parsers must strip or skip the <DOCUMENT>, <TYPE>, <SEQUENCE>, <FILENAME>, <DESCRIPTION>, and <TEXT> tags before handing the inner <html> body to a standard HTML parser; treating the file as pure HTML will leave the envelope tags as stray text in extracted output.

Who Files or Publishes This Dataset, and When

Who files

The filer of a Form IRANNOTICE is always the SEC-registered issuer whose periodic report contains the underlying Section 13(r) disclosure. The reporting population is limited to issuers with an active reporting obligation under Section 13 or Section 15(d) of the Securities Exchange Act of 1934, specifically:

• Domestic issuers filing annual reports on Form 10-K and quarterly reports on Form 10-Q.
• Foreign private issuers filing annual reports on Form 20-F.
• Canadian issuers using the Multijurisdictional Disclosure System (MJDS) filing annual reports on Form 40-F.

Filer status (smaller reporting company, accelerated filer, large accelerated filer, well-known seasoned issuer, emerging growth company) is irrelevant; any registrant in those four form classes is in scope when a covered activity occurs.

The disclosure obligation reaches conduct of the issuer or any of its affiliates (entities controlling, controlled by, or under common control with the issuer). An IRANNOTICE may therefore be triggered by activity of a foreign subsidiary, a controlled joint venture, a parent, or a sister entity, but the IRANNOTICE itself is filed in the registered issuer's own name and CIK. Affiliates do not file separately.

When the notice is required

The obligation is event-driven and conditional. Under Section 219 of ITRSHRA, enacted August 10, 2012, the trigger sequence is:

1. The issuer or an affiliate knowingly engages in (or fails to terminate) an activity covered by Section 13(r)(1) during the period covered by an annual or quarterly report. Covered activities include:
   • Transactions sanctionable under Sections 5(a) or 5(b) of the Iran Sanctions Act of 1996 (energy, shipping, related sectors).
   • Dealings in Iran's domestic petroleum production, importation of refined products, or development of petroleum resources where prohibited by U.S. sanctions.
   • Activities supporting Iran's WMD programs or its support for international terrorism.
   • Transactions or dealings with the Government of Iran, with the Islamic Revolutionary Guard Corps (IRGC) or its agents, or with persons whose property is blocked under Iran-related authorities (including Executive Orders 13224 and 13382) or under the Syria human-rights authorities incorporated by reference.
2. The issuer includes the required Section 13(r)(1) disclosure (nature and extent of activity, gross revenues and net profits attributable to it, and intent to continue) in the body of its 10-K, 10-Q, 20-F, or 40-F.
3. Concurrently with that periodic report, the issuer files a separate Form IRANNOTICE on EDGAR. The notice flags the disclosure to Commission staff so that the Commission can perform the onward transmittal to the President and the designated Congressional committees required by the statute.

If no Section 13(r)(1) disclosure appears in the periodic report, no IRANNOTICE is filed. There is no "negative" or "no-activity" filing; the form exists only to mark affirmative disclosures.

Filing deadline

Form IRANNOTICE is a same-day, parallel submission. It is not deferred and is not furnished separately before or after the periodic report. Its deadline therefore inherits the deadline of the underlying report:

• 10-K: 60, 75, or 90 days after fiscal year end depending on filer status.
• 10-Q: 40 or 45 days after quarter end depending on filer status.
• 20-F: four months after fiscal year end.
• 40-F: due on the same schedule as the issuer's home-country annual report.

Amendments are uncommon and arise mainly when an amended periodic report changes or adds Section 13(r) content.

Important distinctions

• Notice, not disclosure. The IRANNOTICE is a short cover letter to the SEC. The substantive Section 13(r) discussion lives in the related 10-K, 10-Q, 20-F, or 40-F (commonly under "Other Information," e.g., Item 5 of Part II of Form 10-Q).
• Issuer is always the legal filer. Even when the covered activity was conducted entirely by a non-registered foreign affiliate, the registered parent files in its own name; Section 13(r) attributes affiliate conduct to the issuer.
• Current reports do not trigger. Form 8-K (domestic) and Form 6-K (foreign private issuer) furnishings do not trigger an IRANNOTICE. The obligation is keyed only to 10-K, 10-Q, 20-F, and 40-F.
• Non-periodic-report filers are out of scope. Private companies, voluntary filers without a periodic-reporting obligation, Regulation A issuers, asset-backed issuers reporting on Form 10-D, and registered investment companies reporting on Form N-CSR fall outside the regime, because the trigger is tied specifically to a Section 13(r)(1) disclosure inside a 10-K, 10-Q, 20-F, or 40-F.
• "Knowing" standard. Disclosure is required for knowing engagement; inadvertent or unknown counterparty exposure is not by itself a trigger, although issuers sometimes disclose conservatively when sanctioned-person involvement is later identified.
• Dataset start date. Section 13(r) was enacted in August 2012 and Form IRANNOTICE went live on EDGAR in early 2013. The form has no paper-era or pre-EDGAR analog; the dataset begins with the first periodic-reporting cycles after the statute took effect.

How This Dataset Differs From Similar Datasets or Filings

Form IRANNOTICE is easy to confuse with several neighbors: the periodic reports that actually carry the Section 13(r) narrative, other socially-mandated SEC disclosures, event-driven notices, OFAC sanctions reports, and the unrelated "13"-numbered Exchange Act filings. The comparisons below sharpen the boundaries.

Periodic reports carrying the Section 13(r) disclosure: 10-K, 10-Q, 20-F, 40-F

The substantive Iran/Syria disclosure required by Section 13(r) lives inside the issuer's periodic report (10-K annual, 10-Q quarterly, 20-F foreign private issuer annual, 40-F Canadian MJDS annual) — usually as a discrete item or exhibit. IRANNOTICE is not that disclosure; it is a one-page pointer filed contemporaneously to flag that such a disclosure exists in a specific accompanying periodic filing.

The two are functionally inverted:

• The periodic report carries the narrative — counterparties, gross revenues, net profits, decision to continue or terminate the activity.
• IRANNOTICE carries the metadata pointer — issuer, CIK, accession-number reference to the periodic report, and a short recital of the trigger.

For substance (counterparty identity, dollar amounts, exit decisions), use the periodic report. For enumerating the universe and timing of Section 13(r) events without full-text-searching millions of pages, IRANNOTICE is the cleaner index. They are complements: enumerate with IRANNOTICE, then join back to the periodic report. (See also the Form 10-K dataset and Form 10-Q dataset for the full text of those periodic reports.)

Form SD (Conflict Minerals, Resource Extraction)

Form SD shares legislative DNA with IRANNOTICE — both are policy-driven disclosure regimes (Dodd-Frank Sections 1502/1504 for Form SD; ITRSHRA for Section 13(r)) layered onto the Exchange Act. The mechanics, however, differ sharply:

• Structure. Form SD is a self-contained disclosure form with its own body and (for conflict minerals) a separate Conflict Minerals Report. IRANNOTICE is a thin pointer to a periodic report.
• Cadence. Form SD is annual on a fixed calendar (May 31 for conflict minerals). IRANNOTICE follows the issuer's 10-K/10-Q/20-F/40-F schedule and is filed only when a triggering activity occurred.
• Subject matter. Form SD covers DRC-region conflict minerals and resource-extraction payments to foreign governments. IRANNOTICE covers Iran/Syria transactions and dealings with certain designated persons.
• Population. Form SD has thousands of filers per year; IRANNOTICE has a much narrower filer base because the trigger is narrow.

Sibling regimes; no content overlap.

Form 8-K

8-K and IRANNOTICE both look like "alert" filings, but the resemblance is superficial:

• 8-K is event-driven with prescribed item categories and a four-business-day deadline running from the triggering event. IRANNOTICE is periodic-report-tethered, filed on the same date as the related 10-K/10-Q/20-F/40-F.
• 8-K bodies typically carry the substantive disclosure (often via Exhibit 99.1 press releases). IRANNOTICE bodies redirect to the periodic report.
• 8-K is broad and high-volume (hundreds of thousands of filings); IRANNOTICE is narrow and low-volume.

8-K does not capture sanctions disclosure outside the periodic-report cycle, and IRANNOTICE does not capture event-driven news.

OFAC and Treasury sanctions reporting

IRANNOTICE and OFAC reporting concern the same statutory ecosystem (ITRSHRA, related Executive Orders, and the broader sanctions framework), but the regulatory channels are entirely separate:

• Recipient. IRANNOTICE is filed with the SEC and is public on EDGAR. OFAC blocking reports, rejected-transaction reports, license applications, and voluntary self-disclosures go to Treasury and are largely non-public.
• Filer population. IRANNOTICE is limited to SEC registrants and their affiliates. OFAC reporting reaches any U.S. person or entity subject to U.S. jurisdiction, regardless of SEC status.
• Trigger. Section 13(r) requires disclosure of defined Iran/Syria activities by issuers and affiliates regardless of whether sanctioned, licensed, or violative. OFAC reports track specific blocking, rejection, and licensing events.
• Public availability. IRANNOTICE provides complete public coverage from January 2013 forward. There is no analogous public dataset for most OFAC filings.

For what U.S. public companies have publicly admitted about Iran/Syria exposure, IRANNOTICE (joined to the periodic report) is the only systematic public source. For enforcement actions, SDN designations, and licensing, use OFAC, DOJ, and Treasury sources — none of which appear in EDGAR.

Schedule 13D, Schedule 13G, and Form 13F

The shared "13" label is a drafting coincidence. Section 13(r) has no substantive relationship to Sections 13(d), Sections 13(g), or Section 13(f):

• Schedule 13D / Schedule 13G are beneficial-ownership disclosures filed by holders of more than 5% of a class of registered equity securities. They concern equity stakes and investor intent.
• Form 13F is a quarterly tabular holdings report by institutional investment managers exceeding the $100 million threshold, covering Section 13(f) securities. See also the Form 13F dataset.
• Form IRANNOTICE carries no ownership or holdings content and no overlap in filer population beyond coincidence.

Never substitute these for one another.

Form CB and other thin notice/cover filings

The closest structural analogs inside EDGAR are short procedural-alert filings whose function is to flag something else rather than to carry primary disclosure: Form CB (cover-page notification accompanying cross-border tender or rights offers filed primarily abroad), NT 10-K / NT 10-Q (late-filing notifications), and Form 25 (delisting notification). All share IRANNOTICE's metadata-heavy, pointer-style structure but differ entirely in trigger, audience, and what they point to. None covers Iran/Syria activity or any sanctions-adjacent subject.

Boundary summary

What makes the IRANNOTICE Files Dataset distinct is the combination of three properties no neighboring dataset replicates: (1) it is the only EDGAR filing type triggered specifically by Section 13(r) Iran/Syria disclosure; (2) it isolates the exact population of issuers that have ever made such a disclosure, in a way no full-text search across periodic reports can match; and (3) it is a structurally thin pointer whose research value depends on being joined back to the corresponding 10-K/10-Q/20-F/40-F. Use IRANNOTICE to enumerate the universe and timing of Section 13(r) events; use the periodic reports for substance; use Form SD for adjacent socially-mandated regimes; use 8-K for unrelated event-driven alerts; use OFAC sources for sanctions enforcement; and treat 13D, 13G, and 13F as wholly unrelated.

Who Uses This Dataset

Form IRANNOTICE is a low-volume, high-stakes filing that flags Section 13(r) disclosures involving Iran, terrorism-designated parties, and certain Syria-related conduct. A narrow set of professionals consult it, each focused on a compact field set: issuer name and CIK, filed date, the cover-letter Re-line pointing to the relevant 10-K, 10-Q, or 20-F, and the cross-reference to the underlying 13(r) narrative.

Sanctions and export-control compliance teams

OFAC, sanctions, and trade-compliance officers at multinational issuers — global banks, large retailers with international operations, medical-device and life-sciences manufacturers, primary-metals producers, and diversified industrials — pull peer IRANNOTICE history by CIK to benchmark disclosure language. They use the filed date to align with internal screening events and read the linked 13(r) section to study how peers frame humanitarian licenses, wind-down activity, correspondent-banking flows, or inherited subsidiary conduct. Output: drafting templates, materiality calibration, and red-flag inventories for legacy-relationship reviews.

ESG and sustainable-investing analysts

Responsible-investment teams and sustainable-fund managers screen the dataset for Iran and Syria exposure under negative-screen and norms-based exclusion frameworks. CIK and filed date drive portfolio flagging and recency tracking; the underlying 13(r) narrative determines severity (incidental wind-down vs. ongoing commercial activity). Feeds exclusion lists, controversy memos, engagement priorities, and proxy-voting rationales.

Sanctions-focused journalists, policy researchers, and NGOs

Investigative reporters at financial and national-security outlets, analysts at sanctions and Middle East policy think tanks, and NGOs tracking corporate ties to sanctioned regimes use the dataset as a structured feed of self-reported exposure. Issuer name, CIK, and filed date build longitudinal filer timelines; the linked 13(r) section yields counterparties, transaction types, and revenue figures for articles, watchdog reports, congressional testimony, and public 13(r) databases.

Counter-proliferation and national-security analysts

Analysts at policy research organizations and risk consultancies covering proliferation finance, terrorist financing, and Iran sanctions mine the linked 13(r) narratives for shipping routes, port calls, vessel names, financial intermediaries, and named foreign entities. Output: link-analysis memoranda, sanctioned-entity dossiers, and proliferation-finance typology studies.

Divestment screeners and index/ETF providers

Index methodologists building Iran-free or sanctions-screened benchmarks and divestment screening vendors serving U.S. state pension systems (several mandated by statute to maintain Iran exclusion lists) treat IRANNOTICE as a primary input. Issuer name and CIK map filers to investable securities; filed date drives list refresh cycles; the 13(r) narrative supports consistent application of de minimis and humanitarian carve-outs. Drives index constituents, prospectus screens, and trustee exclusion reports.

Securities counsel and outside disclosure lawyers

Sanctions counsel and disclosure lawyers advising registrants on whether a transaction triggers Section 13(r) use the dataset as a precedent corpus. They study peer cover-letter language, Re-line conventions, and how others frame ambiguous activity — humanitarian, wind-down, acquired-subsidiary, agency, or frozen-funds transactions — to calibrate filing strategy and build drafting checklists for first-time or repeat filers.

SEC, Treasury, and State staff

Division of Corporation Finance staff treat IRANNOTICE as the operational trigger for the Section 13(r)(2) referral chain to the President, congressional committees, Treasury, and State. Downstream sanctions-policy and enforcement personnel use issuer name, CIK, filed date, and the periodic-report cross-reference to open files, prioritize review, and coordinate with OFAC licensing records. Aggregate filings also support internal trend and compliance analyses.

Academic researchers

Researchers in international finance, sanctions effectiveness, disclosure regulation, and political risk use the dataset as a panel of self-reported sanctions events. CIK merges IRANNOTICE with fundamentals datasets; filed date and Re-line align with quarterly event windows; 13(r) text supports hand-coded variables for activity type, counterparty, and revenue. Underpins event studies on market reactions, political-economy work on compliance behavior, and cross-issuer self-reporting patterns.

Specific Use Cases

The IRANNOTICE Files Dataset is consulted as a structured index of Section 13(r) disclosure events. The five workflows below show how compact metadata.json fields and the cover-letter Re-line drive practical outputs across compliance, investing, policy research, securities counsel, and academia.

1. Quarterly sanctions-compliance monitoring of peer disclosures

Sanctions and OFAC compliance teams at global banks, retailers, medical-device makers, and primary-metals producers run a recurring job that pulls every new IRANNOTICE accession by formType and filedAt, groups records by entities[0].cik and sic, and follows each cover letter's Re-line back to the referenced 10-K, 10-Q, 20-F, or 40-F. The output is a peer-benchmarked register of how counterparties, humanitarian licenses, correspondent-banking flows, and wind-down activity are being framed in the current reporting cycle, used to calibrate the issuer's own draft 13(r) narrative and refresh red-flag inventories for legacy relationships.

2. ESG and divestment screening for Iran-free portfolios and indices

Responsible-investment analysts and index methodologists building Iran-free or sanctions-screened benchmarks (including vendors serving U.S. state pension systems with statutory exclusion mandates) ingest the full dataset as a primary screening feed. They use entities[0].cik and tickers to map filers onto investable securities, filedAt to drive list-refresh cycles, and the linked 13(r) narrative in the periodic report to apply de minimis and humanitarian carve-outs consistently. The result is an updated set of index constituents, prospectus exclusion lists, controversy memos, and trustee divestment reports.

3. Sanctions-policy and counter-proliferation research

Think-tank researchers, NGOs, and risk consultancies covering Iran sanctions effectiveness, proliferation finance, and terrorist financing use IRANNOTICE as the enumeration layer for the universe of self-reported Section 13(r) events since 2013. They build longitudinal filer timelines from cik and filedAt, segment by sic and stateOfIncorporation, and parse the underlying periodic reports for vessel names, port calls, financial intermediaries, and named sanctioned counterparties. Output: typology studies, link-analysis dossiers, congressional testimony, and public 13(r) trackers that quantify how policy shifts (JCPOA relaxation, the 2018 reimposition, OFAC Syria actions) reshape the filer population.

4. Securities-counsel risk assessment and precedent drafting

Sanctions counsel and outside disclosure lawyers advising registrants on whether a particular transaction triggers Section 13(r) use the dataset as a precedent corpus. They retrieve cover-letter HTML across similarly situated filers (matched by sic, size proxy from tickers breadth, and stateOfIncorporation), study Re-line conventions and signatory titles, and pull the cross-referenced periodic-report passages to see how peers handled ambiguous fact patterns — acquired-subsidiary conduct, agency relationships, frozen funds, and humanitarian activity. The output is a filing-strategy memo, a drafting checklist, and a template cover letter aligned with prevailing market practice.

5. Academic event-study and disclosure-regulation research

Researchers in international finance and disclosure regulation treat IRANNOTICE as a clean panel of self-reported sanctions events. cik merges the records with CRSP, Compustat, or other fundamentals datasets; filedAt and the Re-line define quarterly event windows for abnormal-return tests around 13(r) disclosures; sic and stateOfIncorporation support cross-sectional cuts; and hand-coded variables drawn from the underlying 10-K/10-Q/20-F/40-F text capture activity type, counterparty, gross revenues, net profits, and continuation intent. This underpins event studies on market reactions to sanctions disclosure, political-economy work on compliance behavior, and analyses of selective self-reporting across issuers.

Dataset Access

Dataset Index JSON API: https://api.sec-api.io/datasets/form-irannotice-files.json

This endpoint returns the dataset metadata, including name, description, last updated timestamp, earliest sample date, total records and total size, covered form types, container format, and file types. It also lists every container file in the dataset with its size, record count, last updated timestamp, and direct download URL. Polling this endpoint is the recommended way to monitor which containers were refreshed in the latest run and to decide which ones to re-download on a given day. No API key is required to call this endpoint.

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          {
        

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            "datasetId": "1f13365b-9ae0-6960-8212-6ce5444d19c8",
        

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            "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-irannotice-files.zip",
        

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            "name": "Form IRANNOTICE Files Dataset",
        

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            "updatedAt": "2026-04-25T03:02:57.540Z",
        

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            "earliestSampleDate": "2013-01-01",
        

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            "totalRecords": 4400,
        

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            "totalSize": 10208958,
        

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            "formTypes": ["IRANNOTICE"],
        

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            "containerFormat": "ZIP",
        

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            "fileTypes": ["HTML", "JSON", "TXT"],
        

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            "containers": [
        

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              {
        

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                "downloadUrl": "https://api.sec-api.io/datasets/form-irannotice-files/2026/2026-04.zip",
        

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                "key": "2026/2026-04.zip",
        

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                "size": 162874,
        

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                "records": 38,
        

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                "updatedAt": "2026-04-25T03:02:57.540Z"
        

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              }
        

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            ]
        

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          }
        

Download Entire Dataset: https://api.sec-api.io/datasets/form-irannotice-files.zip?token=YOUR_API_KEY

Use this URL to download the complete dataset as a single ZIP archive containing every Form IRANNOTICE filing from January 2013 onward. This endpoint requires a valid API key.

Download Single Container: https://api.sec-api.io/datasets/form-irannotice-files/2026/2026-04.zip?token=YOUR_API_KEY

Each container is a monthly ZIP archive bundling the metadata file and original EDGAR documents for all filings submitted in that month. Download individual containers when you only need a specific time range or want to apply incremental updates based on the updatedAt values returned by the dataset index. This endpoint requires a valid API key.

Frequently Asked Questions

What form does this dataset cover?

The dataset covers Form IRANNOTICE, the dedicated EDGAR notice form created to satisfy Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which added Section 13(r) to the Securities Exchange Act of 1934. The notice flags that an issuer's accompanying periodic report contains a Section 13(r)(1) disclosure of Iran-related, Hezbollah-related, Syrian-government-related, IRGC-related, or proliferation-related activity.

What does one record in this dataset represent?

One record is one EDGAR submission of Form IRANNOTICE, identified by its 18-character accession number and stored as a per-accession folder inside a monthly ZIP container. Each folder contains the IRANNOTICE HTML cover letter, a metadata.json mirroring the EDGAR submission header, and (where archived) the complete-submission .txt produced by EDGAR.

Who is required to file Form IRANNOTICE?

The filer is always the SEC-registered issuer whose periodic report contains the underlying Section 13(r) disclosure — domestic issuers filing 10-K or 10-Q, foreign private issuers filing 20-F, and Canadian MJDS issuers filing 40-F. Affiliate conduct is attributed to the registered parent; affiliates do not file separately.

When is an IRANNOTICE filed?

It is a same-day, parallel submission filed concurrently with the related 10-K, 10-Q, 20-F, or 40-F whenever that report contains a Section 13(r)(1) disclosure. The deadline inherits the periodic report's deadline (60/75/90 days after fiscal year end for 10-K, 40 or 45 days after quarter end for 10-Q, four months after fiscal year end for 20-F, and the home-country annual schedule for 40-F).

Does the IRANNOTICE itself contain the substantive Iran/Syria disclosure?

No. The IRANNOTICE is a one-page cover letter that points the Commission at the periodic report. The substantive description of the activity, counterparties, gross revenues, net profits, and the issuer's stated intent regarding continuation lives inside the related 10-K, 10-Q, 20-F, or 40-F — commonly under "Other Information," for example Item 5 of Part II of Form 10-Q.

What time period does the dataset cover, and what file format is it distributed in?

The dataset begins on January 1, 2013 — the first periodic-reporting cycles after Section 13(r) took effect — and continues to present. It is delivered as monthly ZIP containers; the file types inside the containers are HTML (the notice itself), JSON (the structured metadata.json), and TXT (EDGAR's complete-submission bundle, where archived).

How does this dataset differ from Form SD and Schedule 13D/13G/13F?

Form SD is a separate socially-mandated disclosure regime covering DRC-region conflict minerals and resource-extraction payments under Dodd-Frank Sections 1502/1504, filed annually and self-contained — IRANNOTICE, by contrast, is a thin pointer triggered only by a Section 13(r) disclosure in a periodic report. Schedules 13D and 13G and Form 13F are unrelated beneficial-ownership and institutional-holdings filings under Sections 13(d), 13(g), and 13(f); the shared "13" label is coincidental, and there is no overlap in subject matter or filer population.