Form SE Files Dataset

The Form SE Files Dataset is a closed corpus of EDGAR submissions on SEC Form SE — the cover form prescribed for transmitting paper-format exhibits that accompany filings otherwise required to be made electronically under Regulation S-T. Each record represents a single Form SE accession, identified by its 18-digit EDGAR accession number, and pairs a structured metadata.json filing header with the original scanned PDF carrying the Form SE cover sheet and the paper exhibit it transmits. The form is filed by any electronic filer on EDGAR — Securities Act registrants, Exchange Act reporting companies, Trust Indenture Act filers, and Investment Company Act registrants — when Rule 201 (temporary hardship), Rule 202 (continuing hardship), or Rule 311 (paper-format exhibits) of Regulation S-T permits or compels paper submission. The dataset begins in February 2001 and is updated as new Form SE filings are accepted by EDGAR.

Dataset APIs

Dataset Files

What This Dataset Contains

The Form SE Files Dataset captures every Form SE submission accepted by EDGAR. Form SE is the cover form prescribed by the SEC for the submission of paper-format exhibits relating to filings that are otherwise made electronically through EDGAR. It is adopted under four statutes simultaneously — the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, and the Investment Company Act of 1940 — and operates in conjunction with Rules 201, 202, and 311 of Regulation S-T.

The form's instructions require the filer to send four complete paper copies of both the cover form and the accompanying exhibit to the Commission. EDGAR captures the cover form, and typically a scanned image of the underlying paper exhibit, as the electronic record of that paper transmission. The form thus functions as a bridge: it lives inside EDGAR as a structured filing with a regular accession number, but it points outward to a paper original held physically by the Commission.

A distinctive consequence of the paper-hardship origin is the EDGAR pseudo-CIK 9999999997. EDGAR uses this reserved CIK in the filer position of accession numbers issued for paper-only and hardship submissions. Form SE accession numbers therefore characteristically take the shape 9999999997-YY-NNNNNN, even though the substantive registrant — the company whose paper exhibit is being transmitted — has its own real CIK that appears inside entities[].cik and inside the /edgar/data/<cik>/ segment of the document URLs. The dataset is distributed as monthly ZIP containers and ships only PDF and JSON file types; the dataset window begins February 2001 and extends to the present.

Content Structure of a Single Record

A single record in the Form SE Files dataset corresponds to one Form SE submission to EDGAR, identified by its 18-digit EDGAR accession number. Physically, the record is an accession folder living one level beneath a YYYY-MM/ directory inside a year-month ZIP container. The folder name is the accession number with hyphens stripped (for example 999999999721004917 for accession 9999999997-21-004917). Inside that folder sit two kinds of artifacts that together constitute the record:

1. a metadata.json describing the filing in machine-readable form, and
2. one or more original EDGAR documents — for Form SE, almost always a single scanned PDF carrying the paper-format cover sheet together with the exhibit it transmits.

A record has two structural layers:

1. A structured metadata layer (metadata.json) capturing the filing header, party identifiers, document inventory, and EDGAR-side links exactly once per accession.
2. A document layer consisting of the original EDGAR-submitted exhibit files, preserved with their original filenames. For Form SE this is almost always a single PDF holding both the cover sheet and the paper exhibit.

The aggregate SGML submission envelope (the .txt file EDGAR generates for every accession) is referenced by URL inside the metadata but is not bundled inside the ZIP. Image attachments from the original submission are likewise excluded by dataset policy. The file-types shipped in the dataset are PDF and JSON.

The accession folder

The folder is the atomic record unit. Its name is the 18-digit hyphen-stripped accession number, globally unique within EDGAR. The path shape is YYYY-MM/<accessionNoNoDashes>/. Contents are flat — there are no nested subdirectories.

metadata.json

Every record contains exactly one metadata.json, always under that exact name, on the order of 1–2 KB in size. It conveys, in a machine-readable structure, the same filing-header information that EDGAR exposes on its filing-index page, plus a manifest of the documents that belong to the submission. The fields populated for Form SE records are:

• formType — the form code, always "SE" for this dataset.
• accessionNo — the canonical hyphenated accession number, e.g. "9999999997-21-004917". The 9999999997 prefix reflects the paper-hardship pseudo-CIK convention.
• filedAt — ISO 8601 timestamp with timezone offset (Eastern, e.g. "2021-09-27T15:47:52-04:00") marking EDGAR acceptance of the cover form.
• effectivenessDate — ISO date (YYYY-MM-DD) marking the filing's effective date, frequently the same calendar day as filedAt.
• description — free-text label, typically "Form SE - Exhibits".
• linkToFilingDetails — absolute URL into https://www.sec.gov/Archives/edgar/data/<cik>/<accessionNoNoDashes>/ resolving to the primary exhibit document (the PDF).
• linkToTxt — URL to the complete SGML-wrapped submission .txt on EDGAR; the envelope itself is not included in the ZIP.
• linkToHtml — URL to the EDGAR filing-index HTML page for the accession (the -index.htm page).
• linkToXbrl — empty string for Form SE; this form type does not carry XBRL.
• documentFormatFiles[] — ordered array of document descriptors. Each entry contains sequence (a 1-based EDGAR document sequence number as a string, or a single space " " for the synthetic complete-submission entry), size (byte size as a string), documentUrl (absolute URL on sec.gov), type (the EDGAR document type code: "SE" for the cover/exhibit document, a single space " " for the aggregate text file), and, for the aggregate-text entry, description: "Complete submission text file". Entries with substantive type codes resolve to files physically present in the folder; the aggregate-text entry is an EDGAR-only reference.
• dataFiles[] — empty for Form SE; the form has no associated financial-report or XBRL data files.
• seriesAndClassesContractsInformation[] — empty for Form SE; this array is reserved for investment-company series/class identifiers.
• entities[] — array of party objects describing registrants and other parties of record. Each object carries:
  • cik — the real registrant CIK (distinct from the pseudo-CIK in the accession), e.g. "1679198".
  • companyName — name with a parenthetical role suffix such as " (Filer)" or " (Subject)".
  • type — the party-level form code, typically "SE".
  • fileNo — SEC file number tying the paper exhibit to its related electronic registration (e.g. "333-213968").
  • irsNo — IRS Employer Identification Number; often "000000000" when not assigned (e.g. for foreign sovereigns).
  • fiscalYearEnd — four-digit MMDD string (e.g. "0331" for a March 31 fiscal year-end).
  • stateOfIncorporation — EDGAR's two-character jurisdiction code, including foreign codes such as "M0" for Japan.
  • sic — four-digit SIC industry code with descriptive label, e.g. "8888 Foreign Governments".
  • act — numeric code identifying the statute under which the filing is made (for example "98" for the foreign-government carve-out series); these codes correspond to the four Acts under which Form SE is adopted.
  • filmNo — the EDGAR film number assigned at acceptance, e.g. "211281472".
• id — internal opaque 32-hex-character identifier uniquely keying the record within the dataset.

The exhibit document

The substantive content of a Form SE filing lives in the exhibit document, which is in practice a single PDF placed alongside metadata.json. The PDF holds:

• A facsimile of the Form SE cover sheet, which identifies the electronic filer, references the related electronic filing to which the paper exhibit pertains (by file number, form type, and filing date), states the SEC rule under which the paper submission is being made (Rule 201, 202, or 311 of Regulation S-T or one of the underlying-statute hardship provisions), and bears signatures and date.
• The paper-format exhibit itself, scanned or rendered into the PDF. Because Rule 311 specifically contemplates exhibits whose physical form resists electronic conversion, these exhibits are typically image-heavy or large multi-page documents — for example, foreign-government cooperation agreements, indenture supplements, technical specifications, certified copies, or notarized instruments.

Filenames are preserved verbatim from the original EDGAR submission with no normalization. They are typically short and lowercased, frequently built from an issuer abbreviation plus the se mnemonic (for example japanse.pdf). The structural invariant is that any documentFormatFiles[] entry whose type is not the single-space placeholder resolves to a sibling file in the same folder.

A record may, in principle, carry multiple exhibit files if the original submission listed more than one document, in which case each appears as a sibling alongside metadata.json. Single-PDF records dominate.

What the record includes

• The structured metadata.json capturing the filing header, document manifest, and entities.
• The original-format paper-exhibit document(s), preserved with their EDGAR filenames (PDF in current practice).
• All document URLs needed to reach the canonical EDGAR copies of the filing index, the primary exhibit, and the SGML submission text.

What is not included in the record

• Image attachments from the original submission (e.g. .gif, .jpg) — excluded by dataset policy; the dataset ships only PDF and JSON.
• The aggregate SGML .txt submission envelope — referenced by URL via linkToTxt and as a documentFormatFiles[] entry, but the file itself is not bundled.
• The physical paper original held by the Commission — by definition not part of any electronic record. The dataset contains only EDGAR's electronic representation, which for Form SE is typically a PDF rendering of the cover sheet and exhibit.
• The related electronic filing to which the paper exhibit pertains — referenced on the cover sheet by file number, form type, and date, but stored separately on EDGAR as its own accession and not bundled into the Form SE record.
• XBRL artifacts — Form SE has never carried XBRL; linkToXbrl is empty and dataFiles[] is empty.

Changes in required content and structure over time

Form SE has been remarkably stable across the dataset's February 2001 to present window. Its statutory authority (the four Acts named on the form) and its operating rules within Regulation S-T (Rules 201, 202, 311) have not undergone substantive structural change. The cover-sheet content set — electronic filer identification, reference to the related electronic filing, identification of the paper exhibit, statement of the rule relied on, and signature — has been required throughout.

What has shifted materially is the scope of paper-eligible exhibits. As Regulation S-T's electronic-filing mandate has tightened over successive amendments, the universe of exhibits eligible for paper submission under Rule 311 has narrowed, and hardship-exemption use under Rules 201 and 202 has been progressively constrained, with the Commission encouraging electronic re-submission once technical difficulties are resolved. The empirical consequence is the extreme sparsity of Form SE filings across the dataset window: the form is increasingly used only for the residual categories where paper remains appropriate, such as foreign-sovereign-style filings and certain certified or oversized exhibits.

The EDGAR pseudo-CIK 9999999997 convention for paper/hardship accession numbering has been in continuous use across the dataset window and is not a recent innovation; it is the mechanism by which EDGAR issues an accession number to a submission whose filer-side identification flows through the paper-hardship channel rather than through the registrant's own CIK.

Changes in data format over time

Form SE exists specifically to register paper exhibits, and the form has never carried XBRL or structured financial data; the dataset reflects that uniformly. The relevant format evolution concerns how the paper exhibit is represented electronically inside the accession:

• In the earliest portion of the dataset window, Form SE accessions on EDGAR were sometimes captured purely as the SGML submission envelope plus a minimal cover document, with the substantive paper exhibit existing only in physical form at the Commission.
• Through the 2000s and consistently in modern practice, the paper cover sheet and the exhibit are scanned and attached to the EDGAR accession as a PDF, which is what the dataset packages.
• The dataset's policy of including only PDF and JSON — and excluding images — reflects this convergence on the PDF-as-scanned-paper convention. Older accessions that originally used GIF or other image attachments would have those images filtered out, leaving the metadata and any PDF that was attached.

The metadata schema itself is consistent across the dataset: every record carries the same metadata.json field set regardless of filing year, so downstream consumers can parse all records uniformly.

Interpretation notes

• Pseudo-CIK in accession vs. real CIK in entities. When extracting registrant identity, do not parse the accession number — its filer segment will resolve to 9999999997, which is not a real company. The substantive registrant CIK lives inside entities[].cik, and the same CIK appears in the /edgar/data/<cik>/ path component of linkToFilingDetails, linkToTxt, and linkToHtml.
• Document manifest semantics. documentFormatFiles[] mixes two kinds of entries: actual sibling files in the folder (with type codes such as "SE" and a numeric sequence like "1") and the synthetic complete-submission text file entry (with both type and sequence set to a single space " " and a description of "Complete submission text file"). Only the former resolve to files inside the ZIP; the latter is a reference to an EDGAR-hosted artifact that the dataset deliberately does not bundle.
• Entity role suffixes. A party's role is encoded as a parenthetical inside companyName (e.g. "... (Filer)", "... (Subject)"), not as a separate field. Multi-party Form SE filings list each party as a separate object in entities[] with the appropriate suffix.
• Statutory act codes. The numeric act field on each entity identifies the statute under which the filing is being made; these codes correspond to the four Acts under which Form SE is adopted (Securities Act of 1933, Exchange Act of 1934, Trust Indenture Act of 1939, Investment Company Act of 1940), with additional codes such as "98" used for specialized programs (foreign-government issuers, asset-backed and similar carve-outs).
• Filename non-uniformity. Because exhibit filenames are preserved as submitted, there is no reliable lexical pattern for locating the exhibit inside the folder. The robust extraction strategy is to read the sequence: "1" entry of documentFormatFiles[] and resolve its documentUrl to the corresponding sibling file by basename.
• Sparsity. The dataset is best treated as an enumerable corpus rather than a statistical sample. Many monthly containers hold zero or one record; gaps of multiple months between filings are normal and do not indicate missing data.
• Relationship to the related electronic filing. A Form SE record describes a paper-exhibit transmission; it does not contain the related electronic filing whose exhibit it carries. Linking a Form SE record to that companion filing requires reading the cover-sheet text inside the PDF, where the related form type, file number, and filing date are stated, since these references are not lifted into structured metadata.json fields. The entities[].fileNo value (e.g. "333-213968") often coincides with the file number of the related registration and is the most reliable structured hook for cross-linking.

Who Files or Publishes This Dataset, and When

Form SE is filed by an electronic filer on EDGAR that needs to transmit a paper-format exhibit in connection with an otherwise electronic submission. It is a transmittal cover, not a substantive disclosure form. The legally responsible filer is the same registrant, reporting person, or third-party filer responsible for the related electronic filing; counsel, financial printers, or filing agents typically prepare and submit the paper package on the filer's behalf, but the obligation runs to the electronic filer of record.

The Form SE population spans every filer class operating under the four statutes the form is adopted under:

• Securities Act of 1933 registrants — issuers filing registration statements (S-1, S-3, S-4, S-8, S-11, F-series).
• Securities Exchange Act of 1934 reporting companies and third-party filers — domestic issuers and foreign private issuers filing 10-K, 10-Q, 8-K, 20-F, 40-F, 6-K, and proxy or tender materials (DEF 14A, 14C, Schedule 14D-9, Schedule TO, Schedule 13D/13G, Schedule 13E-3).
• Trust Indenture Act of 1939 filers — issuers and indenture trustees filing T-1, T-3, T-4, or T-6.
• Investment Company Act of 1940 registrants — open- and closed-end funds, UITs, and BDCs filing N-series forms (N-1A, N-2, N-CSR, N-PX).

Form SE is filer-class agnostic within this universe. A "filer" subject to a paper exhibit obligation may be the issuer itself or a third party (bidder, beneficial owner, acquirer) whose underlying filing carries an exhibit not transmissible electronically.

When the record is triggered

Form SE is transactional and event-driven, not periodic. It arises only when one of three Regulation S-T (17 CFR Part 232) provisions permits or compels paper submission of a document or exhibit:

• Rule 201 — Temporary Hardship Exemption (17 CFR 232.201). When unanticipated technical difficulties prevent a timely electronic submission, the filer may file the document in paper under cover of Form SE on the date the filing was originally due. A confirming electronic copy must be submitted within six business days. Form SE itself is the cover for the paper document; Form TH (Notification of Reliance on Temporary Hardship Exemption) is the separate notification the filer submits electronically to invoke Rule 201. The two forms are complementary but distinct.
• Rule 202 — Continuing Hardship Exemption (17 CFR 232.202). When electronic submission of one or more documents or portions of a document would impose undue burden or expense, the filer applies to the Commission for a continuing exemption. If granted, the affected document or exhibit is filed on paper under Form SE on the schedule of the underlying form, subject to the terms of the Commission's order.
• Rule 311 — Documents Submitted in Paper Under Cover of Form SE (17 CFR 232.311). Rule 311 enumerates exhibits required or permitted to be filed in paper alongside an electronic filing — most commonly exhibits that pre-date the filer's EDGAR mandate and are incorporated by reference, certain graphic, image, audio, or video material, physical specimens, and oversized exhibits not amenable to electronic submission. The Form SE travels with, or shortly after, the related electronic filing.

In practice, Rule 311 incorporations-by-reference of pre-EDGAR paper exhibits are the most common operative trigger; Rule 201 emergency filings are rare; Rule 202 filings exist only on Commission grant.

Timing logic

Form SE has no independent calendar. Its timing is anchored to the related electronic filing:

• Rule 311 filings are submitted on or about the filing date of the related electronic filing.
• Rule 201 filings are submitted on the original due date of the underlying filing, with the electronic confirming copy due within six business days.
• Rule 202 filings follow the underlying form's schedule, as conditioned by the Commission's exemption order.

The procedural requirement under Regulation S-T is the submission of the prescribed paper copies of both the Form SE cover and the accompanying paper exhibit; the Commission assigns the submission an EDGAR accession number and exposes the metadata electronically.

Important distinctions

• Form SE versus Form TH. Form SE is the cover for a paper document or exhibit; Form TH is the electronic notification invoking Rule 201 temporary hardship. A Rule 201 episode commonly produces both: a Form TH notification and a Form SE paper transmittal.
• Cover, not disclosure. The substantive disclosure event remains the underlying electronic filing (10-K, S-1, Schedule TO, N-2, T-3). Form SE records should be tied back to the related electronic accession to recover filing context.
• Filer versus exhibit subject. The Form SE filer is the registrant or third-party filer of the related electronic submission. Persons named within the paper exhibit (target companies, counterparties, appraisers) are not Form SE filers.
• Outside the SE path. Filings exempted from EDGAR entirely under Rule 101(c) (paper-only filer categories) do not use Form SE, because they have no related electronic submission. Confidential treatment requests under Rule 24b-2 / Rule 83 ride through Form SE only when the substrate exhibit must itself be paper.
• Amendments. Corrections or supplements are filed as Form SE/A under the same accession lineage as the original.

How This Dataset Differs From Similar Datasets or Filings

Form SE occupies a narrow corner of EDGAR: it is a transmittal cover for paper-format exhibits attached to filings that are otherwise required to be electronic. Because it is neither a standalone disclosure nor an ordinary exhibit, it is easily confused with several adjacent record types — Form TH, Form CB, regular electronic exhibits, other paper-only filings under Rule 311, and confidential treatment requests.

Form TH — Temporary Hardship Exemption (Rule 201)

Form TH is the closest neighbor by regulatory framework but addresses a different scenario.

• Trigger. Form TH covers an unanticipated technical failure that prevents timely electronic submission of an entire filing under Rule 201; the document goes in on paper and must be re-submitted electronically within six business days. Form SE covers planned paper exhibits filed under a Rule 202 continuing hardship exemption or under Rule 311 (bulky exhibits, glossy annual reports, items impractical to convert).
• Scope. Form TH typically substitutes paper for an entire filing on a one-off basis. Form SE transmits one or more discrete paper exhibits while the parent filing remains electronic.
• Follow-up. Form TH triggers a downstream electronic re-filing obligation; Form SE does not — the paper exhibit stays paper and is referenced from the electronic filing.
• EDGAR signal. Form types "TH" and "SE" are distinct. A TH package contains a hardship notice plus a paper substitute for a whole filing; an SE package contains a cover sheet pointing to a specific electronic accession plus the paper exhibit.

Form CB — Cross-Border Tender Offer / Rights Offering Notification

Form CB is sometimes filed in paper, but the rationale is unrelated to hardship.

• Regulatory basis. Form CB is filed under the Tier I cross-border exemptions (Rules 13e-4(h)(8), 14d-1(c), and 802) for foreign tender offers, rights offerings, business combinations, and exchange offers. Form SE has no transactional function; it exists solely to transmit paper exhibits permitted under Reg S-T.
• Filer population. Form CB is filed by foreign private issuers, bidders, or affiliates in qualifying cross-border transactions. Form SE may be filed by any electronic filer — domestic or foreign — needing to lodge a paper exhibit under Rule 201, 202, or 311.
• Content. Form CB carries substantive transactional disclosure (target, terms, home-country documents). Form SE carries only a cover identifying the related electronic filing plus the paper exhibit itself.

Regular Electronic Exhibits Inside EDGAR Filings

The closest content comparison is to ordinary electronic exhibits (Exhibits 2, 99, etc.) attached to 10-K, 10-Q, 8-K, S-1, N-1A, and similar filings.

• Substitution relationship. Form SE exhibits are exactly the kinds of attachments that would normally appear inline electronically — glossy annual reports, oversized engineering reports, multimedia components, documents EDGAR cannot faithfully reproduce — but which Reg S-T allows or requires on paper.
• Location. A regular exhibit lives in the parent accession and is searchable via EDGAR exhibit indexes and full-text search. A Form SE exhibit lives in its own SE accession; the parent's exhibit list merely notes that the item is "filed in paper pursuant to Form SE."
• Format. Regular exhibits are typically HTML, XML, or text; Form SE deliveries are paper originals scanned to PDF, which is why this dataset is PDF-dominated.
• Research consequence. Electronic exhibit indexes alone are incomplete whenever a Form SE exists for the same period. The SE accession must be pulled separately to reconstruct a complete exhibit set.

Other Paper-Only Filings Permitted Under Rule 311

A handful of filings have historically been permitted or required on paper under Rule 311 — for example, Form 144 prior to its mandatory electronic filing in 2023, Form 6, certain earlier-era Regulation A items, and miscellaneous exempt-issuer filings.

• Standalone vs. cover. These are substantive filings in their own right. A paper Form 144 is itself the Rule 144 notice; a Form 6 is its own report. Form SE is purely a transmittal cover with no disclosure value alone.
• Independence from an electronic filing. Paper-only Rule 311 forms typically have no associated electronic accession. Form SE is defined by its linkage to one — that linkage is its entire purpose.
• Dataset implication. Researchers studying paper-era Form 144 activity should consult the Form 144 dataset directly. Form SE only captures Form 144 material in the rare case where it was an exhibit to another filing rather than a primary submission.

Confidential Treatment Requests (CTRs)

Confidential Treatment Requests are often confused with hardship-paper exhibits because both historically involved paper submissions and material not freely available in electronic EDGAR.

• Purpose. A CTR (Rule 24b-2 of the Exchange Act or Rule 406 of the Securities Act) seeks to redact commercially sensitive terms from an exhibit while still placing a redacted version on the public record. Form SE makes no confidentiality claim — the paper exhibit it transmits is intended to be fully public, just not electronic.
• Public record. A CTR yields a publicly filed redacted exhibit plus a non-public unredacted copy held by staff. Form SE yields a publicly filed paper exhibit with full content, simply not in electronic form.
• Regulatory family. CTRs flow from confidentiality rules (Rule 24b-2, Rule 406, FOIA Exemption 4); Form SE flows from electronic-filing mechanics (Reg S-T Rules 201, 202, 311). The regimes can co-exist — a CTR can in principle be transmitted via Form SE — but the legal questions are independent.
• EDGAR signal. CTR material typically appears as form types such as CT ORDER or as a redacted exhibit within an otherwise electronic filing; Form SE carries the "SE" form type and a paper-exhibit cover sheet.

Boundary Summary

Form SE is distinctive because it is a transmittal mechanism, not a disclosure form. It exists at the seam between the electronic-filing regime and the residual category of documents that must or may be lodged on paper. Form TH handles temporary, whole-filing technical hardship; Form CB handles a specific cross-border exemption; regular electronic exhibits cover the inline default; other Rule 311 paper forms are themselves substantive submissions; CTRs handle confidentiality rather than format. None of them answers the question "what paper exhibits accompany an otherwise electronic filing, and what do they contain?" For that question — and for reconstructing an issuer's complete exhibit record — Form SE Files is the only source that captures both the cover-sheet linkage to the related electronic accession and the scanned paper exhibit itself.

Who Uses This Dataset

Each Form SE record points to a paper exhibit invisible inside EDGAR's inline document tree, so the user base is narrow and specific: people who must reconstruct a complete filing, audit their own paper-exhibit history, or study how the paper-to-electronic transition played out.

Securities lawyers and paralegals

Disclosure counsel and supporting paralegals use the dataset to reconstruct complete exhibit sets for registration statements, prospectuses, indentures, or Investment Company Act filings whose exhibit list points to a paper-only attachment. The entities[].fileNo, the related-form references on the cover sheet, and the description field in metadata.json map the SE record back to the line in the parent filing's exhibit index; the PDF documents carry the operative legal text — typically an indenture, trust agreement, long-form contract, or voluminous schedule. Workflow: closing binders, legal opinions, precedent review, and litigation discovery where inline EDGAR documents leave a placeholder.

Compliance and disclosure teams at registrants

In-house disclosure staff and outside compliance counsel use the dataset to audit a registrant's own historical submissions whenever Rule 201, 202, or 311 was invoked. The entities[].cik, filedAt timestamp, and the cover-sheet text inside the PDF confirm each paper exhibit was correctly cross-referenced and properly cited; the cover sheet verifies the logged exhibit number. Workflow: disclosure-controls testing, exhibit-inventory reconciliation, and responding to regulator inquiries about historical filings.

Financial-data engineering teams

Engineers building filing-reconstruction pipelines and EDGAR-mirror systems use the dataset to patch a known gap: SE exhibits are not inline and are silently dropped by scrapers that walk only the primary document tree. The entities[].fileNo and the cover-sheet's stated parent form type provide the join keys that attach each SE record to its parent filing in a unified document graph; the PDFs feed OCR and text-extraction stages that normalize the content for search. Workflow: ensuring "complete filing" retrieval surfaces actually contain every exhibit, not a truncated subset.

M&A and capital-markets diligence teams

Diligence teams reviewing a target's historical indentures, shelf takedowns, or fund-complex documentation use the dataset when the underlying contract — a long-form indenture, master trust agreement, or collateral schedule — was filed on paper under hardship. The entities[].cik, entities[].fileNo, and the cover-sheet description locate the right SE record; the PDF is the diligence material itself. Workflow: pulling the operative paper exhibit into the data room, comparing against later amendments, and confirming the terms of instruments that may still be live.

Regulators and academic researchers

Regulator staff and disclosure-practice researchers use the dataset as a complete population — not a sample — for studying how Regulation S-T's paper-permitted provisions have been exercised. The filedAt date, the rule cited on the cover sheet (201, 202, or 311), the parent form type, and entities[] identifiers support frequency analysis by filer category, exhibit type, and year; the PDFs supply the substantive context for why paper was used. Workflow: descriptive studies of a vanishing filing practice and evidence for rulemaking on whether paper-permitted provisions remain necessary.

Archivists and historical-research professionals

Archivists and librarians working with pre-EDGAR documents incorporated by reference into later electronic filings use the dataset as a bridge between the paper and electronic eras. The filedAt date, entities[] identifiers, and linkToFilingDetails locate the digital surrogate; the PDF is the archival object. Workflow: cataloguing and preserving electronic surrogates of paper exhibits so researchers do not have to chase physical copies.

Across all six groups, value comes from the same pairing — metadata.json fields that link the SE record to its parent electronic filing, plus the PDF carrying the substantive paper exhibit. Lawyers and diligence teams reconstruct exhibit sets; registrant compliance staff audit their paper-exhibit history; data engineers prevent silent gaps in filing pipelines; regulators and researchers treat the corpus as a closed population; archivists preserve the digital surrogates. In each case, programmatic retrieval is the only practical way to surface these records inside EDGAR.

Specific Use Cases

The use cases below tie directly to the cover-sheet PDF and the metadata.json linkage fields that connect each SE accession to its related electronic filing.

Reconstructing a complete exhibit set for a registration statement or indenture

Disclosure counsel pulls the SE record whose entities[].fileNo matches the file number on a parent S-1, S-3, or 424 prospectus and reads the cover sheet inside the PDF to identify the exhibit number and form type referenced. The scanned exhibit (typically a long-form indenture, trust agreement, or collateral schedule) is then dropped into the closing binder or litigation production alongside the inline electronic exhibits, eliminating the placeholder that EDGAR's inline document tree leaves in the parent filing.

Patching paper-exhibit gaps in EDGAR mirror pipelines

Data-engineering teams that walk /edgar/data/<cik>/ document trees miss SE exhibits because the parent accession's exhibit index merely notes "filed in paper pursuant to Form SE." Using entities[].cik and entities[].fileNo from metadata.json as join keys, the pipeline attaches each SE PDF to its parent accession in a unified document graph, then feeds the PDFs through OCR so full-text search returns hits inside the paper exhibit rather than a truncated subset.

Identifying foreign-sovereign and Rule 311 carve-out filers

Researchers studying the residual paper-eligible filing population query entities[].sic (e.g. 8888 Foreign Governments), entities[].stateOfIncorporation (foreign codes such as M0 for Japan), and entities[].act (e.g. 98 for the foreign-government series) across the corpus to enumerate exactly which issuer categories still rely on Form SE. The cover sheet's stated rule (201, 202, or 311) is read from the PDF to classify each filing as temporary hardship, continuing hardship, or a Rule 311 format-impractical exhibit.

Auditing a registrant's own paper-exhibit history

In-house disclosure staff filter the dataset by entities[].cik to surface every Form SE the registrant has ever filed, then cross-check each PDF cover sheet's stated file number, related form type, and exhibit reference against the registrant's internal exhibit log. The filedAt timestamp and filmNo from metadata.json confirm EDGAR acceptance details, supporting disclosure-controls testing and responses to staff comment letters about historical exhibits.

M&A diligence on operative paper-filed instruments

When a target's debt stack or fund complex includes an indenture, master trust agreement, or supplemental collateral schedule that was lodged on paper under Rule 311, diligence teams locate the SE accession via the target's CIK and the related fileNo, then extract the PDF as the operative contract text. The exhibit is compared against later electronic amendments and supplements pulled from the parent registration to confirm currently effective terms.

Longitudinal study of the paper-to-electronic transition

Disclosure-practice researchers treat the corpus as a complete population and chart filedAt year against the rule cited on each cover sheet, the entities[].sic industry code, and the parent form type referenced inside the PDF. The resulting frequency tables support descriptive studies of how Rule 201, 202, and 311 use has narrowed across successive Regulation S-T amendments and provide evidence for rulemaking on whether the paper-permitted provisions remain necessary.

Dataset Access

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

This endpoint returns dataset-level metadata along with the list of available container files. The metadata includes the dataset name, description, last updated timestamp, earliest sample date, total record count and total size, the form types covered, the container format, and the content file types. For each container, the response includes its key, size, record count, last updated timestamp, and a direct download URL. The endpoint can be polled regularly to detect which containers were modified in the most recent refresh, so only changed monthly archives need to be re-downloaded. This endpoint does not require an API key.

Example response:

          1
          {
        

          2
            "datasetId": "1f13365b-9ae0-696a-8804-c2e4dd43cd97",
        

          3
            "datasetDownloadUrl": "https://api.sec-api.io/datasets/form-se-files.zip",
        

          4
            "name": "Form SE Files Dataset",
        

          5
            "updatedAt": "2026-04-15T07:58:12.211Z",
        

          6
            "earliestSampleDate": "2001-02-01",
        

          7
            "totalRecords": 53,
        

          8
            "totalSize": 1871716917,
        

          9
            "formTypes": ["SE"],
        

          10
            "containerFormat": "ZIP",
        

          11
            "fileTypes": ["PDF", "JSON"],
        

          12
            "containers": [
        

          13
              {
        

          14
                "downloadUrl": "https://api.sec-api.io/datasets/form-se-files/2026/2026-03.zip",
        

          15
                "key": "2026/2026-03.zip",
        

          16
                "size": 13818783,
        

          17
                "records": 2,
        

          18
                "updatedAt": "2026-04-15T07:58:12.211Z"
        

          19
              }
        

          20
            ]
        

          21
          }
        

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

Downloads the complete Form SE Files dataset as a single ZIP archive containing every monthly container from February 2001 to the latest refresh. This endpoint requires an API key.

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

Downloads one monthly container ZIP, useful when only a specific period is needed or when synchronizing recently updated months identified through the dataset index API. This endpoint requires an API key.

Frequently Asked Questions

What form does this dataset cover?

The dataset covers SEC Form SE, the cover form prescribed by the Commission for the submission of paper-format exhibits relating to filings that are otherwise made electronically through EDGAR. It is adopted under the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, and the Investment Company Act of 1940, and operates in conjunction with Rules 201, 202, and 311 of Regulation S-T.

What does one record in this dataset represent?

One record corresponds to a single Form SE submission to EDGAR, identified by its 18-digit accession number and stored as an accession folder beneath a YYYY-MM/ directory inside a year-month ZIP container. Each folder contains a metadata.json filing header and one or more original EDGAR documents — almost always a single scanned PDF carrying both the Form SE cover sheet and the paper exhibit it transmits.

Who is required to file Form SE?

Form SE is filed by any electronic filer on EDGAR — including Securities Act registrants, Exchange Act reporting companies and third-party filers, Trust Indenture Act filers, and Investment Company Act registrants — that needs to transmit a paper-format exhibit in connection with an otherwise electronic submission. The legal obligation runs to the electronic filer of record for the related filing, even when counsel, financial printers, or filing agents prepare and submit the paper package.

When is a Form SE filing triggered?

Form SE is event-driven, not periodic. It is triggered by one of three Regulation S-T provisions: Rule 201 (temporary hardship exemption when unanticipated technical difficulties block timely electronic submission), Rule 202 (a continuing hardship exemption granted by the Commission), or Rule 311 (paper exhibits permitted because their physical form resists electronic conversion or because they pre-date the filer's EDGAR mandate and are incorporated by reference).

What time period does the dataset cover?

The dataset begins on February 1, 2001 and extends to the present, with new monthly containers added as additional Form SE filings are accepted by EDGAR. Because Form SE is rare, many monthly containers hold zero or one record; multi-month gaps between filings are normal and do not indicate missing data.

What file format is the dataset distributed in?

The dataset is distributed as monthly ZIP containers organized by YYYY-MM/ directory. Each accession folder ships only PDF and JSON files: the metadata.json filing header and the original-format paper-exhibit PDF preserved with its EDGAR filename. Image attachments and the aggregate SGML submission envelope are excluded by dataset policy, though the envelope remains reachable via the linkToTxt URL inside metadata.json.

How does this dataset differ from the Form TH dataset?

Form TH is the electronic notification a filer submits to invoke Rule 201's temporary hardship exemption when an unanticipated technical failure prevents timely electronic submission of an entire filing; the underlying document goes in on paper and must be re-submitted electronically within six business days. Form SE, by contrast, is a transmittal cover for one or more discrete paper exhibits while the parent filing remains electronic, with no downstream electronic re-filing obligation for the paper exhibit itself. A single Rule 201 episode can produce both a Form TH notification and a Form SE paper transmittal.