Form NRSRO-CE Files Dataset

The Form NRSRO-CE Files Dataset is a per-accession collection of Form NRSRO annual certifications and amendments filed to EDGAR by Nationally Recognized Statistical Rating Organizations (NRSROs) under Rule 17g-1(f) of the Securities Exchange Act of 1934. Each record is one EDGAR submission — either a NRSRO-CE annual certification or a NRSRO-CE/A amendment — materialized as a single accession-number directory containing an EDGAR-derived metadata.json plus the Form NRSRO primary document and any attached Exhibits 1 through 13 as PDFs. The filer population is small and closed: only the ten credit rating agencies currently registered as NRSROs under Section 15E of the Exchange Act — including Moody's Investors Service, S&P Global Ratings, Fitch Ratings, Morningstar DBRS, Kroll Bond Rating Agency, A.M. Best, Egan-Jones, HR Ratings de Mexico, JCR, and Demotech — file these certifications, each due no later than 90 calendar days after the end of each calendar year. The dataset begins with the March 2016 EDGAR collection window and extends through the present, with filings clustered heavily in March of each year because of the calendar-driven deadline. Content is delivered as monthly ZIP containers holding PDF exhibit documents and JSON metadata.

Update Frequency
Daily
Updated at
2026-04-15
Earliest Sample Date
2016-03-01
Total Size
2.0 GB
Total Records
1,140
Container Format
ZIP
Content Types
PDF, JSON
Form Types
NRSRO-CE, NRSRO-CE/A

Dataset APIs

Programmatically retrieve the full list of dataset archive files, download URLs and dataset metadata.

Dataset Index JSON API

Download the entire dataset as a single archive file.

Download Entire Dataset:

Download a single container file (e.g. monthly archive) from the dataset.

Download Single Container:

Dataset Files

34 files · 2.0 GB
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2026-03.zip185.0 MB102 records
2025-10.zip1.4 MB3 records
2025-07.zip735.1 KB2 records
2025-03.zip126.3 MB92 records
2024-12.zip1.6 MB2 records
2024-03.zip108.5 MB100 records
2023-03.zip129.1 MB91 records
2022-11.zip7.0 MB3 records
2022-10.zip6.8 MB8 records
2022-06.zip27.1 MB6 records
2022-03.zip125.1 MB82 records
2021-07.zip1.5 MB2 records
2021-04.zip7.0 MB10 records
2021-03.zip210.4 MB81 records
2020-10.zip686.3 KB3 records
2020-09.zip5.0 MB2 records
2020-04.zip18.3 MB10 records
2020-03.zip155.3 MB82 records
2019-09.zip38.5 MB12 records
2019-03.zip149.9 MB90 records
2018-11.zip12.7 MB4 records
2018-08.zip29.6 MB20 records
2018-04.zip308.5 KB2 records
2018-03.zip265.7 MB90 records
2017-11.zip2.8 MB2 records
2017-08.zip544.9 KB4 records
2017-07.zip10.5 MB15 records
2017-03.zip172.5 MB89 records
2016-12.zip4.0 MB2 records
2016-10.zip770.8 KB2 records
2016-08.zip13.9 MB5 records
2016-07.zip64.5 MB29 records
2016-06.zip33.1 MB8 records
2016-03.zip67.6 MB85 records

What This Dataset Contains

The dataset captures the public, recurring disclosure stream that NRSROs furnish to the SEC under the Rule 17g-1 / Section 15E regime. Each record corresponds to one EDGAR submission of Form NRSRO filed as an annual certification (form type NRSRO-CE) or as a partial-update amendment to a previously filed annual certification (form type NRSRO-CE/A). Both share an identical per-accession folder structure and differ only in the form-type label, the description string, the primary document's type code, and (typically) the number of exhibit PDFs attached.

The substantive disclosure of any NRSRO-CE submission lives almost entirely in its Exhibits 1 through 13, which are fixed in number and meaning by the Form NRSRO instructions and each address one regulatory disclosure category — performance measurement statistics, methodologies, MNPI policies, organizational structure, code of ethics, conflicts of interest, analyst counts and qualifications, compliance officer disclosures, audited financial statements, revenue by source, and aggregate revenue concentration. The cover Form NRSRO document is thin; the exhibit body is heavy and carries the operational, methodological, organizational, and financial disclosure.

The dataset is delivered as monthly ZIP containers organized by year. The path pattern is form-nrsroce-files/YYYY/YYYY-MM.zip, and inside each ZIP the top-level folder is YYYY-MM/, under which sits one directory per accession number. Because Form NRSRO-CE has a calendar-driven 90-day deadline, March containers are dense (annual certifications cluster there) while most other months hold only a handful of amendment filings. The dataset spans March 2016 through the present and includes only PDF and JSON files; image files from the original EDGAR submission are excluded.

Content Structure of a Single Record

What one record represents

One record in the Form NRSRO-CE Files Dataset is a single EDGAR submission of Form NRSRO filed as an annual certification under Rule 17g-1(f) of the Securities Exchange Act of 1934, materialized on disk as one accession-number directory. Each directory carries an EDGAR-derived metadata.json describing the submission header and a set of PDF documents corresponding to the Form NRSRO update itself and to any Form NRSRO exhibits attached to that certification.

What the underlying SEC submission is

Form NRSRO is the registration and disclosure form for a nationally recognized statistical rating organization under Section 15E of the Exchange Act, added by the Credit Rating Agency Reform Act of 2006 and expanded by Sections 932 and 938 of the Dodd-Frank Act (the SEC's final NRSRO rulemaking became effective in 2014–2015). Rule 17g-1(f) requires each registered NRSRO to refile and re-certify its Form NRSRO no later than 90 days after the end of each calendar year. The "CE" suffix denotes that certification event: the filer reaffirms its registration, restates the certifications by qualified institutional buyers that supported its initial application, and updates any Form NRSRO exhibits whose contents have changed since the prior year.

A NRSRO-CE/A filing is a post-hoc amendment to a previously filed annual certification, typically attaching only the revised exhibit(s) plus a short "FORM NRSRO UPDATE" cover PDF rather than the full exhibit set.

Container layout

Accession folders are named with the 18-digit no-dashes form of the EDGAR accession number (for example, 0001962109-25-000004 becomes 000196210925000004).

Per-accession folder contents

Every accession folder contains:

  1. metadata.json — a structured JSON object derived from the EDGAR submission header. Always present.
  2. The primary Form NRSRO document as a PDF — typically named with a filer-chosen short token such as dt_formnrsro.pdf, formnrsro.pdf, or nrsro.pdf. For amendments the document is often labeled "FORM NRSRO UPDATE".
  3. Zero or more exhibit PDFs to Form NRSRO, with filer-chosen names that frequently encode the exhibit number and sometimes a date (e.g., Ex1_20250717.pdf, ex2.pdf, Exhibit3.pdf, Performance_Statistics.pdf).

The file-types found in the dataset are PDF and JSON. Image files from the original EDGAR submission are excluded, and no SGML wrapper, HTML, or XBRL files are stored locally. Where a downstream consumer needs the original SGML submission text or the EDGAR index page, the relevant URLs are exposed inside metadata.json.

The authoritative mapping from a PDF on disk to its regulatory role is the documentFormatFiles array inside metadata.json: each entry's documentUrl ends in the local file's name, and each entry's type field identifies the document as the Form NRSRO itself or as a specific numbered exhibit.

metadata.json shape

metadata.json is a single flat object mirroring the EDGAR submission header for the accession. Its top-level fields are:

  • formType"NRSRO-CE" for an annual certification or "NRSRO-CE/A" for an amendment.
  • accessionNo — EDGAR accession number in dashed canonical form NNNNNNNNNN-YY-NNNNNN.
  • description — EDGAR submission description string, e.g., "Form NRSRO-CE/A - [Amend]".
  • filedAt — ISO-8601 timestamp with US Eastern timezone offset capturing EDGAR's accept time.
  • linkToFilingDetails — direct URL to the primary document on www.sec.gov/Archives/edgar/....
  • linkToTxt — URL of the full submission as a single SGML .txt wrapper on EDGAR.
  • linkToHtml — URL of the EDGAR filing index page (-index.htm).
  • linkToXbrl — empty string for this form type.
  • id — opaque 32-character hex identifier, stable per filing.
  • seriesAndClassesContractsInformation — array, empty for NRSRO certifications (the field exists for cross-dataset schema consistency with fund-series filings).
  • dataFiles — array of structured data attachments, empty for NRSRO certifications.

documentFormatFiles

An array describing every attachment listed in the EDGAR submission header. Each element has:

  • sequence — string-valued integer ("1", "2", …) for actual documents. The synthetic "complete submission" line uses a single space " " and should be filtered out when sorting numerically.
  • size — byte size as a numeric string.
  • documentUrl — direct EDGAR download URL. Its final path segment is the on-disk filename inside the accession folder.
  • description — filer-supplied human-readable label, e.g., "FORM NRSRO UPDATE", "EXHIBIT 1 REVISED", "PERFORMANCE STATISTICS", "EXHIBIT 2".
  • type — SEC document type code. For NRSRO submissions the values are:
    • NRSRO-CE or NRSRO-CE/A — the primary Form NRSRO document.
    • EX-99.E1 NRSRO through EX-99.E13 NRSRO — Exhibits 1 through 13 to Form NRSRO.
    • A trailing row with type: " " and description: "Complete submission text file" referring to the EDGAR SGML wrapper, which is not stored locally.

entities

An array of header parties. For NRSRO-CE there is normally a single entry: the filer NRSRO itself. Per-entity fields include companyName with a role suffix such as "(Filer)", cik (numeric string, no padding), fileNo (NRSROs use the 110-XXXXX file-number series), filmNo, type mirroring the submission's form type, act (typically "34" for the 1934 Exchange Act under which Section 15E governs NRSROs), fiscalYearEnd as MMDD, irsNo (IRS employer identification number, digits only), and stateOfIncorporation as a two-letter state code.

Form NRSRO body and Exhibits 1 through 13

The primary PDF in each accession folder is the Form NRSRO document itself. It carries the registrant identification block (legal name, address, contact, NRSRO file number in the 110-XXXXX series), the certification language confirming continued eligibility for registration as an NRSRO, the credit-rating class designations for which the NRSRO is registered (financial institutions, insurance companies, corporate issuers, asset-backed securities, government securities, and so on), an inventory of which exhibits are being submitted with the certification, and the signature and date block for the duly authorized officer executing the certification.

Exhibits 1 through 13 are fixed in number and meaning by Form NRSRO and Rule 17g-1, and any subset may be re-submitted in a given certification or amendment. The EX-99.E1 NRSRO through EX-99.E13 NRSRO type codes map to the following content:

  • Exhibit 1 — Credit ratings performance measurement statistics, including transition and default rates by rating category and rated-entity class over 1-, 3-, and 10-year horizons.
  • Exhibit 2 — Procedures and methodologies used to determine credit ratings.
  • Exhibit 3 — Policies or procedures to prevent the misuse of material non-public information.
  • Exhibit 4 — Organizational structure of the NRSRO.
  • Exhibit 5 — Code of ethics of the NRSRO, or an explanation of why one is not provided.
  • Exhibit 6 — Identification and management of conflicts of interest.
  • Exhibit 7 — Policies and procedures with respect to actual and potential conflicts of interest.
  • Exhibit 8 — Information about credit analysts and analyst supervisors, including counts, qualifications, and training.
  • Exhibit 9 — Information regarding the designated compliance officer.
  • Exhibit 10 — Information regarding the compliance officer's reports.
  • Exhibit 11 — Audited financial statements of the NRSRO.
  • Exhibit 12 — Information about revenue, categorized by source and by credit-rating versus non-credit-rating services.
  • Exhibit 13 — Aggregate revenue from the 20 largest issuers and subscribers using the NRSRO's credit-rating services.

Exhibit content is overwhelmingly narrative and legal (Exhibits 2, 3, 5, 6, 7), partially tabular (Exhibits 1, 8, 12, 13), and accounting-document in form (Exhibit 11). Each exhibit is filed as its own PDF, and presentation, pagination, table formatting, and chart styling vary widely across NRSROs and across years for the same NRSRO.

NRSRO-CE versus NRSRO-CE/A structural difference

An initial annual NRSRO-CE filing for a given calendar year typically attaches a substantial set of exhibits — often the full Exhibit 1 through Exhibit 13 sequence, or whichever subset the filer is updating relative to the most recent on-file version. The accession folder for such a filing is correspondingly large and may contain a dozen or more PDFs in addition to the primary Form NRSRO document.

A NRSRO-CE/A amendment is structurally narrower. It almost always attaches a short "FORM NRSRO UPDATE" PDF plus only the specific revised exhibit(s) being amended, with descriptions like "EXHIBIT 1 REVISED" flagging the targeted disclosure. The differences from an initial certification are confined to a small set of signals:

  • formType switches from "NRSRO-CE" to "NRSRO-CE/A".
  • The per-entity type field and the primary document's documentFormatFiles[].type field switch in the same way.
  • description gains an "[Amend]" token (e.g., "Form NRSRO-CE/A - [Amend]").
  • documentFormatFiles is correspondingly shorter, typically a primary document plus one or two revised exhibits plus the synthetic complete-submission row.

Apart from these signals the per-accession folder layout, the metadata schema, the file-naming conventions, and the exhibit-numbering scheme are identical to the initial certification.

What is included

Each record packages the EDGAR header metadata as metadata.json, the primary Form NRSRO PDF for that certification or amendment, and the PDF attachments for every Form NRSRO exhibit that was filed in the submission. Together these capture the entire substantive disclosure of the annual certification or its amendment as it was filed.

What is excluded or separate

Image files from the original EDGAR submission are excluded from the on-disk record. The SGML "complete submission text file" referenced by the trailing documentFormatFiles row with type: " " is also not stored locally; only its EDGAR URL is exposed via linkToTxt. The EDGAR filing index page is similarly external and reached via linkToHtml. The seriesAndClassesContractsInformation and dataFiles arrays exist for cross-dataset schema consistency but are empty for NRSRO certifications, and linkToXbrl is an empty string because the regulatory regime for Form NRSRO does not impose XBRL tagging.

Prior-period filings are also outside the record: each NRSRO-CE accession is a fresh annual certification submitted as a standalone EDGAR submission and does not incorporate the prior year's exhibits by reference inside the dataset. Reconstructing a longitudinal view of an NRSRO's disclosures therefore requires joining multiple annual records by filer CIK.

Historical and format evolution

Form NRSRO-CE has been a stable form type across the dataset's coverage. The 90-day post-year-end deadline, the two-form-type structure (NRSRO-CE and NRSRO-CE/A), and the Exhibit 1 through Exhibit 13 numbering and content scheme have all remained intact from 2016 to the present, so the per-record anatomy does not show the section-by-section evolution that older long-running form datasets exhibit. The only meaningful presentation variation across years is filer-driven: individual NRSROs change exhibit naming conventions, page layouts, table formatting, and chart styling from one annual certification to the next, while the regulatory anatomy of the record is constant.

Form-wise, NRSRO-CE filings have been submitted to EDGAR consistently as PDF documents wrapped in the standard EDGAR SGML envelope. The dataset stores the PDFs and the parsed header; there is no ASCII-text-to-HTML transition relevant to this form.

Interpretation and extraction notes

  • The accession folder name is the dashless 18-digit form of the EDGAR accession; matching it back to dashed form requires inserting hyphens after the 10th and 12th digits.
  • To map an arbitrary PDF in the folder to a specific Form NRSRO exhibit, take the last path segment of each documentFormatFiles[*].documentUrl and join against the local filenames; the type field on the matched row identifies which exhibit (or the primary form document) the PDF represents. Filer-chosen filenames are not a reliable signal on their own.
  • sequence is a string and includes a synthetic single-space value for the SGML "complete submission" row that does not correspond to any locally stored file, so numeric sorting must coerce types and filter that row.
  • Exhibit counts per folder vary widely: an initial annual certification can carry the full exhibit set, while an amendment may carry only a single revised exhibit. Code that walks the dataset should not assume any fixed exhibit count and should iterate documentFormatFiles instead.
  • An amendment can be distinguished from an initial certification by formType, by the [Amend] token in description, and by the typically much smaller documentFormatFiles array; consumers reconstructing the "as-current" certification for a filer must overlay each NRSRO-CE/A on the most recent prior NRSRO-CE for the same CIK.
  • Because the regulatory disclosure burden of an NRSRO-CE filing sits almost entirely inside the exhibit PDFs, downstream extraction of substantive content (performance statistics, methodologies, conflict-of-interest policies, audited financials, revenue concentration) generally requires PDF parsing rather than reading the metadata alone. The metadata identifies which exhibit a PDF represents but does not encode any of the exhibit's contents.

Who Files or Publishes This Dataset, and When

Who files or discloses the record

The filer is always the registered NRSRO legal entity itself. It is not the issuers, obligors, or instruments that the NRSRO rates, and not unregistered affiliates within the same corporate group. NRSRO-CE/A amendments are filed by the same registered NRSRO that filed the original certification.

Filing population

The population is unusually small. Only ten credit rating agencies currently hold NRSRO status, and only these entities can file Form NRSRO-CE:

Each NRSRO is registered in one or more of the five rating classes defined by Section 3(a)(62) of the Exchange Act: (1) financial institutions, brokers, or dealers; (2) insurance companies; (3) corporate issuers; (4) issuers of asset-backed securities; and (5) issuers of government, municipal, or foreign-government securities. The annual certification covers only the classes for which the firm is registered.

Non-registered credit rating agencies, deregistered or withdrawn NRSROs, and unregistered affiliates of NRSROs do not file Form NRSRO-CE.

When the record is created or required

Form NRSRO-CE is a periodic, calendar-driven certification with one fixed trigger and one event-driven trigger.

  • Annual trigger (NRSRO-CE). Under Rule 17g-1(f) under the Exchange Act, each NRSRO must furnish an annual certification on Form NRSRO no later than 90 calendar days after the end of each calendar year. The reporting period is always January 1 through December 31, regardless of the registrant's fiscal year. The deadline is fixed and applies uniformly: there are no accelerated-filer tiers in the NRSRO regime. In practice, filings cluster in late February through March 31, with most appearing in March. The dataset's earliest sample date of 2016-03-01 reflects the start of EDGAR-based collection during one of these March waves.
  • Amendment trigger (NRSRO-CE/A). A registered NRSRO must promptly file an amendment if information previously furnished on Form NRSRO (including the most recent annual certification or its exhibits) becomes materially inaccurate or incomplete. Common triggers include changes in officers, methodology disclosures, conflicts-of-interest policies, code of ethics, performance statistics, or other material exhibit updates. NRSRO-CE/A filings can appear in any month.

Regulatory and statutory framework

  • Credit Rating Agency Reform Act of 2006 (CRARA). Added Section 15E to the Exchange Act and created the formal NRSRO registration regime, replacing the prior informal designation.
  • Section 15E of the Exchange Act (15 U.S.C. 78o-7). Requires NRSROs to register on Form NRSRO, keep registration current, and comply with substantive requirements covering conflicts of interest, internal controls, recordkeeping, and methodology and performance disclosure.
  • Rule 17g-1 under the Exchange Act. Implements Section 15E and prescribes the Form NRSRO regime. Paragraph (f) imposes the 90-day annual certification requirement that generates the records in this dataset. Paragraph (i) governs public availability of Form NRSRO and its exhibits.
  • Dodd-Frank Sections 932 and 938 (2010). Section 932 expanded internal-controls, governance, conflict-of-interest, and disclosure obligations and strengthened SEC oversight through the Office of Credit Ratings. Section 938 added requirements on the definition, consistency, and disclosure of rating symbols. Both expanded the substantive exhibit content that the annual certification re-attests.

Consequences of failing to certify

The annual certification is mandatory, not discretionary. Failure to furnish Form NRSRO-CE within the 90-day window is a violation of Rule 17g-1(f) and Section 15E. Under Section 15E(d), the Commission may, after notice and hearing, censure an NRSRO, place limitations on its activities, suspend its registration for up to 12 months, or revoke its registration for failure to comply with Section 15E or the rules thereunder. Loss of NRSRO status eliminates the regulatory recognition that allows the firm's ratings to be used in SEC and other federal rules that reference NRSRO ratings, which can effectively end the firm's business. Late or deficient filings also commonly produce Office of Credit Ratings examination findings, deficiency letters, and Division of Enforcement referrals; recent SEC enforcement actions against NRSROs have resulted in multi-million-dollar civil penalties.

Important distinctions

  • NRSRO-CE vs. NRSRO vs. NRSRO-UPD. The same underlying Form NRSRO supports initial registration (NRSRO), annual certification (NRSRO-CE), and material updates between annual cycles (NRSRO-UPD). This dataset covers only NRSRO-CE and NRSRO-CE/A.
  • Filer vs. rated entity. Issuers, obligors, and instruments rated by the NRSRO are not filers and never appear in the dataset as filers, though they may be aggregated within the exhibits.
  • Foreign-domiciled NRSROs. HR Ratings de Mexico and JCR file the same Form NRSRO-CE as U.S.-domiciled registrants; the obligation attaches to SEC registration, not U.S. domicile. There is no Form 20-F equivalent for NRSROs.
  • Legal-entity scope. Registration is at the legal-entity level. Within global rating groups, only the specifically registered legal entities file NRSRO-CE; unregistered sister entities do not, even if they perform similar rating work abroad.
  • Withdrawal. An NRSRO that voluntarily withdraws registration is no longer obligated to file Form NRSRO-CE after withdrawal becomes effective. Pre-withdrawal certifications from former NRSROs may still appear in the dataset.
  • Furnished vs. filed. Rule 17g-1(f) requires the certification to be "furnished," not "filed," but the public exhibits required by Rule 17g-1(i) accompany the submission on EDGAR and are captured in this dataset.

How This Dataset Differs From Similar Datasets or Filings

Form NRSRO-CE belongs to a small filing family used by NRSROs under Section 15E of the Exchange Act and the Rule 17g series. The closest comparison targets are the other Form NRSRO variants tied to different points in the registration lifecycle, plus Form ADV as an outside-the-regime structural analog.

Form NRSRO (initial application for registration)

Form NRSRO in its base form is the one-time application a credit rating agency files to become registered. It uses the same form template and exhibit structure as NRSRO-CE — performance statistics, ratings counts, financial statements, organizational and procedural disclosures — which is the main source of confusion. The difference is purely lifecycle: the initial Form NRSRO establishes registration once at entry; NRSRO-CE is the annual Rule 17g-1(f) certification that re-attests the same exhibit set every calendar year. What makes NRSRO-CE different: it is the recurring annual snapshot, not the one-time entry record.

Form NRSRO-UPD (material change update under Rule 17g-1(e))

Form NRSRO-UPD filings are event-driven amendments triggered when previously reported Form NRSRO information becomes materially inaccurate. They are submitted promptly after the triggering event, on no fixed schedule, and update only the specific exhibits affected (e.g., a code-of-ethics revision, a credit analyst headcount change, a procedural disclosure update). What makes NRSRO-CE different: it is calendar-driven (due within 90 days of year-end), comprehensive across all exhibits, and confirmatory rather than reactive. NRSRO-UPDs capture intra-year deltas; NRSRO-CE captures the end-of-year consolidated state.

Form NRSRO-FR (annual financial reports under Rule 17g-3)

Form NRSRO-FR is the other annual NRSRO filing but is financial-only: audited financial statements, unaudited revenue reports, schedules of credit-ratings revenue, and reports on internal controls and compliance. It runs on the Rule 17g-3 schedule, not the Rule 17g-1(f) certification deadline. NRSRO-CE does include a financial-statements exhibit, but it is materially shallower than NRSRO-FR and contains no audited financials or internal-controls reporting. What makes NRSRO-CE different: it covers ratings volumes, procedural frameworks, and organizational structure — the operational and qualitative disclosures NRSRO-FR omits. The two are complementary, not substitutes.

Form NRSRO-WCR (withdrawal from registration)

NRSRO-WCR is the one-time termination filing used when an NRSRO exits the regime. It is procedural and carries essentially none of the substantive exhibit content — no performance statistics, no ratings counts, no operational disclosures. What makes NRSRO-CE different: it is the source for the running annual exhibit content while the registrant is active; NRSRO-WCR only marks the exit event.

Form NRSRO supplemental ratings statistics filings

Supplemental Form NRSRO filings carrying category-specific ratings statistics overlap with NRSRO-CE on ratings counts and performance statistics but are narrower, more tabular, and targeted to a specific statistical disclosure rather than the full exhibit package. What makes NRSRO-CE different: it bundles the complete Form NRSRO exhibit set — including non-numeric procedural, organizational, and methodology disclosures — as a single annual recertification, where supplemental filings isolate one slice of tabular data.

Form ADV (investment adviser annual updating amendment)

Form ADV is the closest structural analog outside the credit-rating regime: both are annual, comprehensive, certification-style filings due within 90 days of year-end in which an SEC registrant refreshes a master disclosure document. The substantive content has no overlap. Form ADV is filed by investment advisers under the Advisers Act and covers AUM, client types, custody, and adviser-specific disclosures; NRSRO-CE is filed by credit rating agencies under Section 15E and covers ratings outstanding, performance statistics, and ratings methodologies. What makes NRSRO-CE different: different statute, different registrant population, and exhibit content with no Form ADV counterpart. The comparison is useful as a model for understanding the annual-recertification mechanic, not as an alternative data source.

Boundary summary

NRSRO-CE is the once-per-year, all-exhibits recertification in the NRSRO regime. It is structurally distinct from NRSRO-UPD (event-driven, narrow), substantively distinct from NRSRO-FR (financials-only under a different rule), lifecycle-distinct from the initial Form NRSRO (registration) and NRSRO-WCR (withdrawal), broader than supplemental ratings-statistics filings, and outside the registrant population of Form ADV. For the canonical year-end snapshot of an NRSRO's ratings activity, organizational structure, procedural framework, and compliance posture, NRSRO-CE is the authoritative source; the other filings in the series are complements, not substitutes.

Who Uses This Dataset

Form NRSRO-CE annual certifications are the only regular, comparable, public window into how registered rating agencies operate, what they rate, how their ratings perform, how they are funded, and how they manage conflicts. Because every NRSRO repeats the same exhibit structure each year, a defined set of professional users mines it for cross-agency, multi-year comparisons.

Buy-side fixed-income credit analysts

Credit analysts at asset managers, insurance general accounts, pension plans, and credit hedge funds work behind the ratings they consume. They pull Exhibit 1 default and transition statistics by asset class (corporate, financial, insurance, sovereign, structured) to decide which agency's rating binds in internal credit policy, calibrate expected-loss models, and justify notching overrides. Exhibit 2 methodology disclosures explain rating-action waves.

Bank treasury, risk, and regulatory capital teams

Banks reference NRSRO ratings for risk-weighted assets, HQLA classification, and repo collateral eligibility. Treasury and capital teams use Items 6 and 7 to confirm each agency's registration scope covers the asset classes they rely on, watch Exhibit 2 for methodology changes that could move RWA, and cite Exhibits 9 and 10 to evidence that the agencies they reference remain in good regulatory standing.

Sell-side structured-finance and corporate-credit research

Strategists publishing client-facing notes benchmark agencies using Exhibit 1 (performance, defaults, transitions by asset class), Exhibit 2 (methodology comparisons), Exhibit 12 (rating vs. non-rating revenue and top-client concentration), and Exhibit 13 (analyst and supervisor headcount as a capacity proxy). Outputs include annual rating-agency reviews, sector primers on relative agency severity, and structured-finance market-share dashboards.

Compliance officers at NRSROs and at registrants citing NRSRO ratings

In-house compliance teams at the agencies use prior-year filings, their own and peers', as a drafting reference for Exhibit 8 (conflicts), Exhibit 9 (compliance program), and Exhibit 10 (designated compliance officer). Issuer-side compliance officers whose offering documents, indentures, or covenants reference NRSRO ratings use the filings to verify continued registration in the relevant class and to document agency due diligence.

Academic researchers and policy economists

Researchers studying rating-agency competition, issuer-pays conflicts, and rating accuracy build long panels from Exhibit 1 (performance, procyclicality), Exhibit 12 (revenue and client concentration), Exhibit 13 (analyst workload), and Exhibits 8 and 9 (qualitative coding of governance). Outputs are working papers and rule-comment submissions on rating-agency reform.

SEC Office of Credit Ratings examination and enforcement staff

OCR examiners treat each NRSRO-CE certification, with its senior officer attestation, as the agency's own representation about how it operated during the prior calendar year. Annual Section 15E examinations compare Exhibit 1 against internal performance data, Exhibits 8 and 9 against observed conflicts and compliance practice, Exhibit 10 against the org chart, and Exhibits 11 and 12 against books and records. Discrepancies support deficiency findings or enforcement referrals.

Litigation support and forensic accounting consultants

Forensic accountants and testifying experts in rating-related disputes (structured-finance securities class actions, indenture and covenant disputes, issuer-agency contract claims) reconstruct what an agency disclosed at a specific point in time. The NRSRO-CE/A amendment trail anchors what the agency knew and stated in a given year; Exhibit 1 statistics and Exhibit 2 methodology language are routinely quoted in expert reports.

Investor relations and corporate finance teams

Treasurers, capital-markets bankers, and IR teams selecting or rotating rating agencies compare Exhibit 1 transition and default behavior in their sector, Exhibit 2 methodology disclosures to anticipate driving factors, Exhibit 13 headcount as a proxy for analytical attention per issuer, and Exhibit 12 revenue concentration to gauge commercial dependence on their industry. The comparison feeds the decision memo to the CFO or treasurer.

Financial journalists and specialist data providers

Credit-markets reporters and data vendors maintaining NRSRO market-share databases extract ratings outstanding by class and asset type (Exhibit on ratings outstanding), revenue by activity and geography (Exhibit 12), headcount trends (Exhibit 13), and year-over-year changes in conflicts and compliance disclosures (Exhibits 8, 9, 10). Outputs are league tables, competitive-landscape pieces, and subscription products tracking the industry.

LLM and RAG developers in credit and regulatory analytics

Teams building retrieval-augmented systems for credit research, regulatory monitoring, and compliance Q&A ingest the full corpus to ground model answers in agency methodologies, performance histories, and governance disclosures. PDF exhibits plus JSON metadata from 2016 onward give a citation-ready corpus, with accession numbers serving as stable evidence anchors.

Specific Use Cases

The dataset's value sits inside a stable handful of exhibits filed by every NRSRO each calendar year. The use cases below assume PDF extraction over the exhibits identified by the type codes (EX-99.E1 NRSRO through EX-99.E13 NRSRO) in metadata.json.

Building a multi-year NRSRO performance panel

Pull Exhibit 1 PDFs (type = EX-99.E1 NRSRO) across every accession from 2016 forward, joined by filer CIK and the year derived from filedAt. Extract 1-, 3-, and 10-year transition and default rates by rating category and rated-entity class (corporate, financial, insurance, sovereign, ABS, government) into a single long-format table. The deliverable is a cross-agency, multi-year performance panel for calibrating expected-loss models, notching overrides in internal credit policy, or producing annual rating-agency review notes.

Methodology-change diff for surveillance triggers

For a target NRSRO, walk its accession folders chronologically and diff Exhibit 2 PDFs (type = EX-99.E2 NRSRO) between consecutive annual NRSRO-CE filings, overlaying any NRSRO-CE/A amendments labelled EXHIBIT 2 REVISED in documentFormatFiles[].description. The output is a dated change-log of methodology revisions that buy-side credit and bank RWA teams use to anticipate rating-action waves and re-test internal capital models.

Revenue-concentration and capacity dashboard

Parse Exhibit 12 (EX-99.E12 NRSRO) and Exhibit 13 (EX-99.E13 NRSRO) across all filers to assemble two time series per NRSRO: revenue split by credit-rating versus non-credit-rating activity (Exhibit 12) and aggregate revenue from the 20 largest issuer and subscriber clients (Exhibit 13). Combine with the analyst and supervisor headcounts from Exhibit 8 (EX-99.E8 NRSRO) to publish a competitive-landscape dashboard tracking commercial dependence, client concentration, and analytical capacity per agency.

Conflicts and compliance governance corpus

Collect Exhibits 3, 6, 7, 9, and 10 (EX-99.E3 / E6 / E7 / E9 / E10 NRSRO) for each filer-year and index them as a citation-ready governance corpus. Compliance teams at NRSROs use it as a peer drafting reference; OCR examination staff use it to compare each agency's stated policies on MNPI, conflicts management, and the designated compliance officer against observed practice; litigation experts use it to anchor what an agency had on file at a given accession date.

Amendment trail for forensic reconstruction

For a disputed period, filter metadata.json to records where formType = "NRSRO-CE/A" (or description contains "[Amend]") for the target CIK, then overlay the revised exhibits onto the most recent prior NRSRO-CE to reconstruct the "as-current" certification on any specific date. The deliverable for forensic accountants and testifying experts is a time-stamped exhibit chain — accession numbers as evidence anchors — supporting expert reports in structured-finance, indenture, or issuer-agency disputes.

RAG corpus for credit and regulatory analytics

Ingest the entire on-disk record set: every PDF in each accession folder chunked, embedded, and tagged with the exhibit type, filer CIK, accessionNo, and filedAt lifted from metadata.json. The result is a retrieval index that grounds LLM answers about NRSRO methodologies, performance histories, conflicts policies, and revenue disclosures in primary-source text, with accession numbers serving as stable citations back to the EDGAR record.

Dataset Access

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

This endpoint returns metadata describing the Form NRSRO-CE Files Dataset, including the dataset name, description, last update timestamp, earliest sample date, total record count, total dataset size, form types covered (NRSRO-CE, NRSRO-CE/A), container format (ZIP), and content file types (PDF, JSON). It also provides the full dataset download URL and a list of individual container files, each with its own size, record count, last updated timestamp, and download URL. Use this endpoint to monitor which containers have been refreshed in the most recent update run and to decide which containers to download incrementally on a day-by-day basis. No API key is required to call this endpoint.

Example response:

Example
1 {
2 "datasetId": "1f13365b-9ae0-69ff-bde6-493c8bfbd0c5",
3 "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-nrsroce-files.zip",
4 "name": "Form NRSRO-CE Files Dataset",
5 "updatedAt": "2026-04-15T18:19:23.448Z",
6 "earliestSampleDate": "2016-03-01",
7 "totalRecords": 1140,
8 "totalSize": 1983675133,
9 "formTypes": ["NRSRO-CE", "NRSRO-CE/A"],
10 "containerFormat": "ZIP",
11 "fileTypes": ["PDF", "JSON"],
12 "containers": [
13 {
14 "downloadUrl": "https://api.sec-api.io/datasets/form-nrsroce-files/2026/2026-03.zip",
15 "key": "2026/2026-03.zip",
16 "size": 13818783,
17 "records": 24,
18 "updatedAt": "2026-04-15T18:19:23.448Z"
19 }
20 ]
21 }

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

Downloads the complete Form NRSRO-CE Files Dataset as a single ZIP archive covering all filings from March 2016 to the present. This endpoint requires a valid API key.

Download Single Container: https://api.sec-api.io/datasets/form-nrsroce-files/2026/2026-03.zip?token=YOUR_API_KEY

Downloads a single monthly container file instead of the full archive. Replace the year and month segments with any container key listed in the dataset index to retrieve filings for that period. This endpoint requires a valid API key.

Frequently Asked Questions

What form does this dataset cover?

The dataset covers Form NRSRO filed as annual certifications under form type NRSRO-CE and amendments to those annual certifications under form type NRSRO-CE/A. Both are submitted to EDGAR pursuant to Rule 17g-1(f) of the Securities Exchange Act of 1934. The dataset does not include initial registration filings (Form NRSRO), event-driven material-change updates (NRSRO-UPD), annual financial reports under Rule 17g-3 (NRSRO-FR), or withdrawal filings (NRSRO-WCR).

What does one record in this dataset represent?

One record is a single EDGAR submission, materialized on disk as one accession-number directory containing an EDGAR-derived metadata.json and the Form NRSRO primary document plus any attached Exhibits 1 through 13 as PDFs. An initial NRSRO-CE accession typically carries a large set of exhibits; an NRSRO-CE/A amendment is narrower and usually contains a short "FORM NRSRO UPDATE" PDF plus only the revised exhibit(s).

Who is required to file this form?

Every credit rating agency registered as a Nationally Recognized Statistical Rating Organization under Section 15E of the Exchange Act must file Form NRSRO-CE. The current population is ten registered NRSROs, including Moody's Investors Service, S&P Global Ratings, Fitch Ratings, Morningstar DBRS, Kroll Bond Rating Agency, A.M. Best, Egan-Jones, HR Ratings de Mexico, JCR, and Demotech. Non-registered credit rating agencies, deregistered NRSROs, and unregistered affiliates do not file.

When must Form NRSRO-CE be filed?

Rule 17g-1(f) requires each registered NRSRO to furnish its annual certification on Form NRSRO no later than 90 calendar days after the end of each calendar year, regardless of the registrant's fiscal year. The deadline is fixed and uniform across all NRSROs, with no accelerated-filer tiers. In practice, filings cluster in late February through March 31, which is why March monthly containers are the densest in the dataset. NRSRO-CE/A amendments can be filed in any month when previously furnished information becomes materially inaccurate or incomplete.

What time period does the dataset cover?

The dataset begins on 2016-03-01 — the earliest sample date, which falls within the first March certification wave captured under EDGAR-based collection — and extends through the present. Coverage is continuous; every Form NRSRO-CE and NRSRO-CE/A submission to EDGAR within that window is included.

What file format is the dataset distributed in?

The dataset is delivered as monthly ZIP containers organized by year, following the path pattern form-nrsroce-files/YYYY/YYYY-MM.zip. Inside each ZIP, accession folders contain a metadata.json file plus PDF documents for the Form NRSRO primary document and each filed exhibit. Image files from the original EDGAR submission are excluded, and the SGML wrapper, HTML index page, and XBRL data are not stored locally — their EDGAR URLs are exposed in metadata.json for downstream retrieval.

How does this dataset differ from Form NRSRO-FR (annual financial reports)?

NRSRO-CE and NRSRO-FR are both annual filings under the Rule 17g series, but they serve different purposes. NRSRO-FR runs on the Rule 17g-3 schedule and is financial-only — audited financial statements, unaudited revenue reports, schedules of credit-ratings revenue, and reports on internal controls and compliance. NRSRO-CE, by contrast, is the Rule 17g-1(f) all-exhibits recertification that re-attests performance statistics, methodologies, organizational structure, conflict-of-interest policies, code of ethics, analyst headcount, compliance officer disclosures, and revenue concentration. The two are complementary, not substitutes.