The Form NRSRO-UPD Files dataset is a complete, accession-keyed archive of every Form NRSRO-UPD submission filed on EDGAR by registered Nationally Recognized Statistical Rating Organizations (NRSROs). One record corresponds to one EDGAR submission and contains the canonical EDGAR submission descriptor (metadata.json) together with the primary Form NRSRO-UPD PDF and every EX-99.E<n> NRSRO exhibit PDF the registrant attached. NRSRO-UPD is the Rule 17g-1(e) "update of registration" filing that an NRSRO must make promptly whenever any item or exhibit in its underlying Form NRSRO becomes materially inaccurate, so each record documents a dated, exhibit-level amendment to a credit rating agency's regulatory disclosures on methodologies, conflicts of interest, organizational structure, compliance leadership, performance statistics, audited financials, and revenue concentration. Filers are limited to the small population of SEC-registered NRSROs identified by file numbers in the 110-* series (currently nine agencies including Moody's, S&P, Fitch, DBRS, KBRA, A.M. Best, Egan-Jones, HR Ratings, and JCR). Coverage begins September 2015, the point at which NRSRO-UPD became a distinct EDGAR form type under the Commission's 2014 NRSRO rulemaking, and continues through the current refresh.
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:
The dataset captures every EDGAR submission of Form NRSRO-UPD, the Section 15E / Rule 17g-1(e) update vehicle for credit rating agencies that have already registered as NRSROs on Form NRSRO. NRSRO-UPD is not a stand-alone application; it is a delta filing that re-states, corrects, or replaces specific exhibits or disclosures from the underlying Form NRSRO. Each NRSRO-UPD typically attaches only the exhibits that have actually changed, so a record's exhibit inventory is itself a deliberate signal of which disclosures the registrant identified as having become materially inaccurate.
Form NRSRO defines thirteen numbered exhibits (Exhibits 1 through 13), each filed on EDGAR under the document-type label EX-99.E<n> NRSRO. A single NRSRO-UPD accession may carry one such exhibit, several, or, in rare comprehensive updates, the full set. The dataset preserves every retained EDGAR attachment in its original byte form; the only category of attachment the publisher drops is standalone image files. Records are distributed as PDFs (the filing and exhibit content) paired with JSON (the per-record metadata descriptor), packaged as accession-keyed folders inside per-month ZIP containers organized by year. Coverage runs from September 2015 forward.
One record in the Form NRSRO-UPD Files dataset corresponds to a single EDGAR submission of Form NRSRO-UPD by a registered NRSRO. The record is materialized as an accession-keyed folder containing the canonical EDGAR submission descriptor (metadata.json) together with every primary and exhibit document attached to that submission, preserved in their original PDF form. Image-only attachments are the single category of file the publisher drops; everything else the registrant submitted is retained byte-for-byte.
The folder is named with the bare EDGAR accession number (digits only, no dashes), nested inside a year/month directory inside a per-month ZIP archive (<year>/<year>-<month>.zip). The dashed accession number is preserved inside metadata.json as accessionNo, so the folder name and the metadata identifier reconcile by trivial string normalization.
A record therefore has two distinct layers: the EDGAR submission as filed (a primary Form NRSRO-UPD PDF plus zero or more EX-99.E<n> NRSRO exhibit PDFs, plus an EDGAR-generated complete-submission text bundle), and the dataset packaging layer that pairs those documents with a structured JSON descriptor of the submission.
Form NRSRO-UPD is the SEC's update vehicle for credit rating agencies that have already registered as NRSROs on Form NRSRO under Section 15E of the Securities Exchange Act of 1934 and Rule 17g-1 thereunder. After initial NRSRO registration, an NRSRO must promptly file an NRSRO-UPD whenever the information or documents previously furnished on Form NRSRO become materially inaccurate. The NRSRO-UPD is therefore not a free-standing application; it is a delta filing that re-states, corrects, or replaces specific exhibits or disclosures from the underlying Form NRSRO. Each NRSRO-UPD typically attaches only the exhibits that have actually changed, rather than the entire Form NRSRO exhibit set.
Form NRSRO defines thirteen numbered exhibits (Exhibits 1 through 13). On EDGAR each is filed under the document-type label EX-99.E<n> NRSRO (for example, EX-99.E1 NRSRO for Exhibit 1, EX-99.E4 NRSRO for Exhibit 4). A single NRSRO-UPD accession may carry one such exhibit, several, or, in rare comprehensive updates, the full set.
The governing exhibit catalogue under Form NRSRO is, in order:
Within an NRSRO-UPD accession only the subset of these exhibits the registrant is updating is attached. The presence of EX-99.E4 NRSRO alone, for instance, indicates an update limited to the organizational-structure disclosure; the presence of EX-99.E11 NRSRO indicates a refresh of audited financials; and so on.
Each record sits inside a ZIP container partitioned by year and month. Inside the ZIP, the per-month folder contains one subdirectory per accession; that subdirectory holds:
metadata.json — the EDGAR submission descriptor, always present.tm2518019d1_nrsroupd.pdf). EDGAR types this attachment as NRSRO-UPD and assigns it sequence "1".tm2425888d1_ex99-ra4nrsro3.pdf). EDGAR types each as EX-99.E<n> NRSRO with sequential "2", "3", ... sequence numbers.The complete-submission text wrapper (<accession>.txt) that EDGAR builds is referenced from metadata.json by URL but is not extracted into the folder, since its content duplicates the individual attachments wrapped in EDGAR's SGML envelope. Standalone image attachments to the original submission are stripped by the dataset publisher. Inline images embedded inside a retained PDF are preserved as part of that PDF.
The file types found in the dataset are PDF (the actual filing and exhibit content) and JSON (the per-record metadata descriptor).
metadata.json — record descriptormetadata.json is the canonical EDGAR submission summary for one NRSRO-UPD filing. Its top-level fields are:
formType — Always "NRSRO-UPD".accessionNo — The dashed EDGAR accession number (e.g., 0001104659-25-059785); strip the dashes to recover the folder name.linkToFilingDetails — URL to the primary filing document on sec.gov/Archives/edgar.description — Short EDGAR description string, typically "Form NRSRO-UPD -".linkToTxt — URL to the complete EDGAR submission text bundle.linkToHtml — URL to the EDGAR filing index page (-index.htm).linkToXbrl — Empty string for NRSRO-UPD filings.filedAt — ISO-8601 timestamp with timezone (Eastern), e.g., 2025-06-16T13:21:40-04:00.id — A 32-character hexadecimal stable internal record identifier.documentFormatFiles — Array describing every document attached to the EDGAR submission.entities — Array describing the filer entity or entities.dataFiles — Empty array for NRSRO-UPD filings.seriesAndClassesContractsInformation — Empty array for NRSRO-UPD; carried over from the generic EDGAR header schema used by investment-company filings.documentFormatFiles[]Each element describes one EDGAR attachment with the following keys:
sequence — String integer assigned by EDGAR ("1" for the primary, "2", "3", ... for exhibits). The complete-submission text file carries a single-space placeholder.size — Byte size of the attachment, as a string.documentUrl — Direct URL to the document on EDGAR.description — Human-readable label such as "NRSRO-UPD", "EXHIBIT 99.E4 NRSRO", or "Complete submission text file".type — EDGAR document-type code such as "NRSRO-UPD" or "EX-99.E4 NRSRO". The complete-submission text file uses a single-space placeholder.entities[]Each element describes a filer registered on EDGAR. Keys include:
companyName — Filer name with role suffix, e.g., "DBRS, Inc. (Filer)".cik — Central Index Key.fileNo — SEC file number; for NRSROs the prefix is 110-, the file-number series reserved for credit rating agency registrations.irsNo — IRS employer identification number.stateOfIncorporation — Two-letter US state code.act — Governing securities act, "34" for the Securities Exchange Act of 1934.fiscalYearEnd — MMDD string.filmNo — EDGAR film number assigned to the submission.type — Echo of the form type.For NRSRO-UPD filings the entities array is small, usually just the registered NRSRO itself acting as filer.
Every NRSRO-UPD record carries one or more PDF attachments alongside metadata.json.
The primary attachment is the actual Form NRSRO-UPD cover/update document. Its EDGAR type is NRSRO-UPD and EDGAR sequence is "1". Internally it identifies the registrant, the file number under the 110- series, the date of the update, and lists or describes which Form NRSRO exhibit slots are being updated by this submission. Embedded XMP metadata typically reveals the authoring workflow (frequently a Microsoft Office application post-processed through Adobe Acrobat), with an internal author tag identifying the preparer. Because the source authoring tool is most often a presentation or word-processor application converted to PDF, the primary document is a fully rendered, page-paginated PDF rather than a structured form with parseable fields.
Each exhibit being updated is attached as its own PDF, sequenced after the primary document and typed by EDGAR as EX-99.E<n> NRSRO. The exhibit's content is dictated by the corresponding Form NRSRO exhibit instructions:
In an NRSRO-UPD filing only the exhibits actually being updated are attached. A given accession may therefore contain a single exhibit (correcting one disclosure), several exhibits (multiple disclosures changing contemporaneously), or, occasionally, a comprehensive refresh of most or all exhibits. The exhibit documents themselves vary in shape: performance-statistics exhibits (E1) are dense tables; methodology exhibits (E2) are long-form narrative; organizational exhibits (E4) often combine narrative with org charts; financial-statements exhibits (E11) reproduce auditor-signed statements with notes.
For each accession, the record contains:
metadata.json descriptor, including identifiers (accessionNo, id, cik, fileNo, filmNo), filing timestamp (filedAt), URLs back to EDGAR (linkToFilingDetails, linkToTxt, linkToHtml), and the complete documentFormatFiles and entities inventories.EX-99.E<n> NRSRO) attached to the submission, preserved in original byte form with original filer-supplied filenames.<accession>.txt) generated by EDGAR is referenced via linkToTxt in metadata.json but is not extracted into the accession folder; its content is the SGML-wrapped concatenation of the same documents already stored individually.Form NRSRO and Form NRSRO-UPD were established under the Credit Rating Agency Reform Act of 2006 and the SEC's implementing rules in 2007. The subsequent expansion of the exhibit set and the substantive content of several exhibits was driven primarily by Title IX, Subtitle C of the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010) and the SEC's Nationally Recognized Statistical Rating Organizations rule release adopted in August 2014 (effective in 2015). Because the dataset begins with EDGAR submissions in September 2015, every record is governed by the post-2014 rule package. Within that period, substantive changes affecting NRSRO-UPD filings have been internal to specific exhibits — refinements to the standardized performance-statistics templates required by Exhibit 1, expanded conflict-of-interest disclosures in Exhibits 6 and 7, and ongoing attention to revenue-concentration disclosures in Exhibits 10 and 12 in light of subsequent rulemakings and staff guidance. The headline structure (Exhibits 1 through 13, EDGAR EX-99.E<n> NRSRO typing, the obligation to file promptly upon material inaccuracy) has remained stable.
NRSRO-UPD filings have, since their introduction on EDGAR, been submitted as PDF documents — both for the primary Form NRSRO-UPD and for each exhibit. Unlike text-based EDGAR forms (which transitioned through ASCII, then HTML, then iXBRL), this form has consistently been filed as PDF throughout its EDGAR history, and the dataset reflects that consistency: PDF for the filing content, JSON for the per-record descriptor. Underlying authoring workflows have evolved — older PDFs frequently originate from word processors of their era while more recent PDFs are commonly produced from Microsoft 365 Office applications and post-processed in Adobe Acrobat — so embedded XMP metadata, font subsets, and PDF version vary across the dataset. The EDGAR-level document typing (NRSRO-UPD, EX-99.E<n> NRSRO) and the descriptor schema are uniform across the September-2015-to-present coverage window.
EX-99.E<n> is itself informative.110-00122) is the persistent identifier tying every NRSRO-UPD by a given registrant back to that registrant's underlying NRSRO registration. The CIK identifies the EDGAR filer entity, but the 110- file number identifies the NRSRO registration itself, which is the more durable join key for longitudinal analysis across reorganizations or filer-name changes.description field on documentFormatFiles[] and the type field together identify which Form NRSRO exhibit slot a given PDF corresponds to. The textual description (for example, "EXHIBIT 99.E4 NRSRO") is sometimes more legible than the EDGAR type ("EX-99.E4 NRSRO"); the digit after the E maps directly to the Form NRSRO exhibit number.tm<digits>d<n>_<slug>.pdf) follow EDGAR conventions and frequently encode the document's role in their slug (_nrsroupd, _ex99-ra4nrsro3), but the authoritative classification is the EDGAR type field, not the filename.entities[].fileNo (the 110- registration) and then by the presence of the relevant EX-99.E<n> NRSRO type in documentFormatFiles[].Each record in this dataset is an EDGAR submission filed by a credit rating agency that holds an active Commission order granting it status as a Nationally Recognized Statistical Rating Organization under Section 15E of the Exchange Act. The filer is always the registered NRSRO entity itself, identified on EDGAR by a file number in the 110-* series (for example 110-1, 110-2, 110-3) and a corresponding CIK. No other class of EDGAR registrant files Form NRSRO-UPD.
The filer population is unusually narrow. As of the current period there are nine SEC-registered NRSROs, and essentially all NRSRO-UPD filings come from this group:
NRSRO registration is voluntary. A credit rating agency that has not obtained NRSRO status has no obligation under Section 15E or Rule 17g-1 and does not appear in the 110-* file-number series or in this dataset. Conversely, once registered, the NRSRO is bound by the updating obligations described below.
Form NRSRO is the underlying registration application and disclosure form. It collects identifying information, the rating categories sought, performance statistics, methodologies, MNPI controls, organizational structure, conflicts disclosures, the designated compliance officer, financial information, and Exhibits 1 through 13.
Form NRSRO-UPD is not a stand-alone form. It is Form NRSRO submitted with the "update of registration" box checked, used to update or amend information previously furnished. EDGAR captures these update submissions under the distinct form type NRSRO-UPD. Each filing typically includes a cover sheet identifying the filer and the nature of the change, plus the affected exhibit(s).
The disclosure obligation arises under Section 15E of the Exchange Act (added by the Credit Rating Agency Reform Act of 2006 and expanded by Subtitle C of Title IX of Dodd-Frank in 2010), implemented through Rule 17g-1. The two operative provisions for this dataset are:
Rule 17g-1(i) sets the EDGAR procedural filing requirements and also requires the NRSRO to keep its current Form NRSRO publicly available on its own website.
The core trigger for an NRSRO-UPD filing is materiality. When any information or document previously furnished on Form NRSRO (cover-page items or any of Exhibits 1 through 13) becomes materially inaccurate, the NRSRO must promptly file an update correcting it. "Promptly" is not a fixed number of days; it means as soon as reasonably practicable after the NRSRO becomes aware of the material inaccuracy.
Common triggering events include:
NRSRO-UPD is event-driven, not periodic. An NRSRO may file zero updates in a year if no material changes occur, or many in a year as methodologies, organizational structures, or compliance personnel change. Larger global NRSROs (Moody's, S&P, Fitch) tend to file more frequently than smaller registrants because of higher methodology and entity-structure churn.
The separate annual certification under Rule 17g-1(f) follows a fixed schedule: within 90 days after calendar year-end. It is filed under the NRSRO form type, not NRSRO-UPD, although in practice an NRSRO may pair material updates with its annual certification when changes have accumulated.
The dataset begins in September 2015, which corresponds to when NRSRO-UPD became a distinct EDGAR form type. The substantive obligation itself dates to Rule 17g-1's adoption in 2007, with significant expansions through Dodd-Frank (2010) and the Commission's 2014 NRSRO rulemaking effective in 2015.
Form NRSRO-UPD sits inside a tight cluster of EDGAR filings made by Nationally Recognized Statistical Rating Organizations under Section 15E of the Exchange Act and Rule 17g-1. The most useful comparisons are the other forms in the NRSRO family, the Rule 15Ga-2 branch of ABS-15G, and the NRSRO's own website-hosted disclosures.
The complete baseline disclosure: corporate structure, classes of ratings registered for, performance statistics, methodologies, conflicts policies, code of ethics, designated compliance officer, and the full Rule 17g-1 exhibit set.
NRSRO-UPD is the targeted patch to that baseline. Updates typically replace specific exhibits rather than re-furnishing the whole filing.
A calendar-driven annual certification under Section 15E(b)(2) and Rule 17g-1(f) that the existing Form NRSRO record remains accurate and that lists material changes since the last certification.
NRSRO-CE confirms; NRSRO-UPD amends. NRSRO-CE is recurring, scheduled, and largely a pointer back to the substantive NRSRO/NRSRO-UPD record. NRSRO-UPD is event-triggered, irregular, and is where the new exhibit content actually lives. A material change between annual cycles produces an NRSRO-UPD first; the next NRSRO-CE then ratifies that the record (as updated) is current.
The Rule 17g-3 annual financial report: audited financials, revenue by line of business including rating-related services, and counts of credit ratings issued and outstanding by class. Numeric and accountancy-oriented.
NRSRO-UPD updates the qualitative and structural disclosures of Form NRSRO (organization, methodologies, conflicts, compliance officer, Exhibit 8 revenue descriptions). The two intersect on revenue but answer different questions.
A terminal, one-time filing that ends NRSRO status (in whole or by rating class). Use NRSRO-WCLS to identify exits from the regime; use NRSRO-UPD for life-cycle changes during active registration. A complete agency history chains: NRSRO -> recurring NRSRO-CE and NRSRO-FR -> intermittent NRSRO-UPD -> eventual NRSRO-WCLS.
Both touch credit-rating workflows, which is where the confusion arises. The filer and unit of analysis are different.
| Dimension | ABS-15G (Rule 15Ga-2) | NRSRO-UPD |
|---|---|---|
| Filer | Issuer, securitizer, or originator of an ABS transaction | The rating agency itself, as a registered NRSRO |
| Statutory basis | Exchange Act Rule 15Ga-2 (ABS rules) | Exchange Act Section 15E / Rule 17g-1 |
| Unit of disclosure | A specific securitization and the third-party due diligence performed for it | The agency's institutional record (methodologies, conflicts, governance) |
| Trigger | Five business days before first ABS rating is furnished | Material inaccuracy in the most recent Form NRSRO |
| Links to specific deals | Yes | No |
Rule 17g-1(i) requires each NRSRO to host its current Form NRSRO and Exhibits 1-9 on its corporate website. Those pages show only the current state; superseded versions are typically removed when a new one is posted, and there is no uniform timestamping across agencies.
The EDGAR set captured in this dataset is the regulatorily filed version: each submission has an accession number, an acceptance timestamp, and is permanently archived. Every prior version is preserved.
NRSROs are often part of larger financial groups whose affiliates file under other regimes. None of the following contain NRSRO methodology, conflicts, or compliance content:
Form NRSRO-UPD is the only dataset focused on event-driven amendments to registered credit rating agency disclosures. It is:
Choose this dataset when the research question is about when, why, and how rating agency methodologies, conflicts policies, organizational structure, or compliance leadership changed over time.
The dataset's users treat it as a primary source on rating-agency methodology change, conflict disclosures, revenue concentration, and compliance governance. They span credit and risk professionals who depend on rating outputs, supervisors and compliance officers who oversee the rating process, litigators and trustees who reconstruct historical disclosures, competitive analysts at peer NRSROs, academic researchers, and the data and AI teams operationalizing all of the above.
Sell-side and buy-side credit analysts diff successive Exhibit 2 (procedures and methodologies) submissions to detect criteria changes before public rating actions. They also track Exhibit 1 performance statistics and transition matrices to anticipate which outstanding ratings could migrate on the next surveillance cycle.
In-house methodology teams at asset managers, insurers, and consultancies version-control NRSRO criteria libraries from Exhibits 2 and 3 (rating scales and definitions) plus Exhibit 7 (conflict-of-interest policies). Accession number, filing date, and exhibit index drive the version control. Output feeds model validation files, IPS language, and ratings-eligibility tests in collateral schedules.
Risk managers using NRSRO ratings for standardized risk weights, NAIC designations, RBC charges, HQLA classification, or permitted-investment thresholds monitor changes in Exhibits 1 and 3 that alter how internal mapping tables translate ratings into capital outcomes. They also track Exhibit 2 amendments that signal a coming wave of re-notchings.
Examination staff at the regulator overseeing NRSROs use the full UPD population to test whether registrants amend promptly when prior representations become materially inaccurate, as required by Section 15E and Rule 17g-1. Focus areas: timeliness of filings against known organizational events, Exhibit 7 conflict revisions, designated compliance officer identification, and Exhibit 6 revenue-concentration disclosure including the top-20-client list. Foreign supervisors recognizing NRSRO designations use the same content for equivalence assessments.
Designated compliance officers and legal teams at registrants use the dataset to benchmark Exhibit 7, the code of ethics, and internal-control descriptions against peer registrants while drafting their own next NRSRO-UPD. Compliance-officer turnover across the industry is observable from amendments that change the named officer in the cover page and Exhibit 11.
Methodology committees at other registered NRSROs monitor peer Exhibit 2 updates, revised criteria, and reorganized conflict procedures in Exhibit 7. Org-chart changes in Exhibit 8 signal new analytical groups or sector coverage. Output feeds benchmarking memos, rule-comment letters, and decisions to revise published criteria.
Counsel involved in rating-related disputes use UPD filings as timestamped evidence of what an NRSRO represented to its regulator on a given date. Key fields: accession metadata, Exhibit 2 procedures, Exhibit 7 conflict policies, and Exhibit 6 revenue concentration with rated issuers or arrangers. Used in document review, deposition prep, and expert reports comparing filed procedures against actual rating conduct.
Trustees operating under instruments that reference specific rating thresholds use Exhibits 1 and 3 to confirm rating definitions and scales remain consistent with trust documents, and to flag methodology updates that may trigger rating-trigger covenants or collateral-eligibility reassessment.
CROs and CCOs at broker-dealers using NRSRO ratings inside net capital calculations, customer suitability, money market fund eligibility, or repo collateral schedules monitor Exhibit 2 and 3 changes that affect haircuts, eligibility, or product governance.
Researchers in finance, accounting, and law use the full accession population for empirical work on rating quality, conflicts, and methodology drift. Standardized exhibit categories support text-based diff measures across registrants; dated exhibits support event-time analysis. Outputs include working papers, comment letters, and replication panels.
Engineering teams ingesting the dataset build methodology-change timelines, conflict-policy corpora, revenue-mix histories, and compliance-officer panels. They rely on JSON metadata for normalization, accession IDs for joins to other EDGAR datasets, and the consistent exhibit structure for repeatable extraction and alerting.
Teams building retrieval systems for supervisory technology or in-house compliance assistants use the dated PDFs plus structured metadata as a citation surface for grounded answers on which methodology was on file at a given date, which compliance officer was named, or how a registrant's conflict disclosures evolved.
The use cases below are organized around concrete workflows that exploit the dataset's exhibit-level granularity, dated accession history, and per-record metadata.json plus PDF pairing.
Credit research and methodology teams filter records by entities[].fileNo (the persistent 110-series NRSRO registration) and by the presence of EX-99.E2 NRSRO in documentFormatFiles[], then run text extraction and section-level diffs across successive filings ordered by filedAt. The output is a dated change log per asset class showing when scoring weights, notching adjustments, or stress assumptions were revised, used to anticipate surveillance actions and to update internal model-validation files before peer registrants publish their next criteria notice.
Compliance officers and supervisory examiners pull every accession that attaches EX-99.E6 NRSRO or EX-99.E7 NRSRO, line up the policy text against the prior version on file, and tag added or removed conflict categories, new escalation procedures, and changes to analyst-issuer separation rules. The workflow drives examination scoping memos, peer-benchmark tables for in-house policy drafting, and timestamped evidence packages in litigation document review.
Analysts studying NRSRO commercial dependence extract the largest-user list from EX-99.E10 NRSRO and the revenue-by-source breakouts from EX-99.E12 NRSRO, joining successive filings on the 110- file number to build a multi-year panel of revenue mix and client concentration. The output supports issuer-pays-bias studies, supervisory equivalence assessments by foreign regulators, and risk-committee briefings on which arrangers or issuers a rating agency cannot afford to lose.
Researchers and recruiters identify changes in the named compliance officer by detecting accessions that carry only EX-99.E9 NRSRO (or that pair it with EX-99.E4 NRSRO organizational updates), using filedAt to date each transition. The result is an industry-wide compliance-officer tenure panel useful for governance research, examination prioritization, and competitive intelligence on compliance-function reorganizations.
Indenture and securitization trustees pull EX-99.E1 NRSRO performance statistics and EX-99.E2 NRSRO methodology narratives for the specific NRSRO referenced in their trust documents, then verify that rating-scale definitions and transition behaviour still match the covenant language that triggers replacement, posting of additional collateral, or accelerated amortization. The dated EDGAR record (rather than the agency website, which only shows current state) lets counsel demonstrate which methodology was on file at the moment a rating action occurred.
metadata.json with exhibit PDFsSupTech and in-house compliance assistant developers index each accession folder as a citation unit, embedding exhibit PDFs chunk-by-chunk and attaching accessionNo, filedAt, cik, fileNo, and the EX-99.E<n> exhibit tag as retrieval metadata. Queries such as "which version of DBRS Exhibit 2 for structured finance was on file in March 2022" return the correct PDF passage with a verifiable EDGAR link via linkToFilingDetails, which is the citation property regulated-finance reviewers require.
Methodology committees at peer registrants assemble a cross-agency corpus by filtering all accessions on a given exhibit type (most often EX-99.E2 NRSRO for criteria, EX-99.E7 NRSRO for conflict procedures, or EX-99.E4 NRSRO for organizational structure) across every 110- file number in the dataset. The comparative read informs decisions to revise published criteria, drafting of comment letters on SEC NRSRO rulemakings, and internal positioning memos on where one agency's disclosed practice diverges from the rest of the industry.
Dataset Index JSON API: https://api.sec-api.io/datasets/form-nrsroupd-files.json
This endpoint returns dataset metadata including the dataset name, description, last updated timestamp, earliest sample date, total record count, total dataset size, form types covered (NRSRO-UPD), container format (ZIP), and the file types contained (PDF, JSON). It also returns the download URL for the entire dataset and a list of all individual container files with per-container metadata such as size, record count, last updated timestamp, and a direct download URL. Use this endpoint to monitor which containers were updated in the most recent refresh run and decide which containers to re-download on a daily basis.
This endpoint does not require an API key.
Example response:
1
{
2
"datasetId": "1f13365b-9ae0-69df-b3f5-e3ff1d10ddde",
3
"datasetDownloadUrl": "https://api.sec-api.io/datasets/form-nrsroupd-files.zip",
4
"name": "Form NRSRO-UPD Files Dataset",
5
"updatedAt": "2026-04-15T12:32:17.068Z",
6
"earliestSampleDate": "2015-09-01",
7
"totalRecords": 1041,
8
"totalSize": 999155884,
9
"formTypes": ["NRSRO-UPD"],
10
"containerFormat": "ZIP",
11
"fileTypes": ["PDF", "JSON"],
12
"containers": [
13
{
14
"downloadUrl": "https://api.sec-api.io/datasets/form-nrsroupd-files/2026/2026-04.zip",
15
"key": "2026/2026-04.zip",
16
"size": 13818783,
17
"records": 12,
18
"updatedAt": "2026-04-15T12:32:17.068Z"
19
}
20
]
21
}
Download Entire Dataset: https://api.sec-api.io/datasets/form-nrsroupd-files.zip?token=YOUR_API_KEY
Downloads the complete dataset as a single ZIP archive containing every container file from the earliest sample date (2015-09-01) onward. This endpoint requires an API key passed as the token query parameter.
Download Single Container: https://api.sec-api.io/datasets/form-nrsroupd-files/2026/2026-04.zip?token=YOUR_API_KEY
Downloads one individual monthly container as a ZIP file instead of the full dataset, which is useful for incremental syncing or fetching only recently updated periods. This endpoint requires an API key passed as the token query parameter.
The dataset covers Form NRSRO-UPD, the EDGAR form type used by registered Nationally Recognized Statistical Rating Organizations to file updates to a previously furnished Form NRSRO under Section 15E of the Securities Exchange Act of 1934 and Rule 17g-1(e). NRSRO-UPD is a delta filing that re-states, corrects, or replaces specific exhibits or disclosures from the underlying Form NRSRO, rather than a free-standing application.
One record corresponds to a single EDGAR submission of Form NRSRO-UPD by one registered NRSRO. The record is materialized as an accession-keyed folder containing the EDGAR submission descriptor (metadata.json) plus the primary Form NRSRO-UPD PDF and every EX-99.E<n> NRSRO exhibit PDF that was attached, preserved in original byte form. Standalone image attachments are the only category of file dropped by the publisher.
Only credit rating agencies that hold an active Commission order granting NRSRO status under Section 15E may file Form NRSRO-UPD, and they are obligated to do so promptly whenever any item or exhibit on their Form NRSRO becomes materially inaccurate. The filer population is unusually narrow — currently nine SEC-registered NRSROs including Moody's, S&P, Fitch, DBRS, KBRA, A.M. Best, Egan-Jones, HR Ratings, and JCR — and each is identified on EDGAR by a file number in the 110-* series.
NRSRO-UPD is event-driven, not periodic: filings appear when a registrant identifies a material inaccuracy in its Form NRSRO record. An NRSRO may file zero updates in a year if no material changes occur, or many in a year as methodologies, organizational structures, or compliance personnel change, with larger global NRSROs typically filing more frequently than smaller registrants.
The dataset begins on 2015-09-01, the point at which NRSRO-UPD became a distinct EDGAR form type following the SEC's August 2014 NRSRO rulemaking (effective in 2015), and continues through the most recent refresh. Every record in the dataset is therefore governed by the post-2014 rule package.
Each record contains PDFs (the primary Form NRSRO-UPD document and each EX-99.E<n> NRSRO exhibit, preserved with original filer-supplied filenames) plus a metadata.json descriptor with EDGAR identifiers, filing timestamp, document inventory, and entity information. Records are packaged into per-month ZIP containers laid out as <year>/<year>-<month>.zip.
Form NRSRO is the complete baseline disclosure (organization, methodologies, conflicts, the full Exhibit 1-13 set), and Form NRSRO-CE is a calendar-driven annual certification that the existing record remains accurate. NRSRO-UPD, by contrast, is the event-triggered amendment vehicle where new exhibit content actually lives — it is narrower than NRSRO and differently triggered than NRSRO-CE, and is the only EDGAR source that preserves dated, exhibit-level historical versions of an NRSRO's disclosures.