The SEC's proxy voting disclosure requirement at a glance
All SEC-registered investment companies and Form 13-F filers are required to file Form N-PX annually, publicly disclosing how they voted on every shareholder proposal during the reporting period. The filing deadline is 31 August each year. Download our materials to understand your obligations, key challenges in gathering data, and how Proxymity's Form N-PX Filing Solution can support your firm.
Regulatory Guidelines
Understanding Form N-PX: A guide for investment managers for Form 13-F filers
A comprehensive guide to the SEC's annual proxy voting disclosure requirement, with everything your firm needs to know ahead of the 31 August filing deadline.
- What Form N-PX is and why the SEC introduced it
- Key dates and the annual reporting timetable
- Who is required to file and what obligations apply
- Required SEC-mandated filing specifications
- Key challenges identified from the last two filings
- How Proxymity supports accurate, on-time compliance
Product Overview
Proxymity’s Form N-PX Filing Solution
Learn how Proxymity handles the entire N-PX filing process, from vote data consolidation to direct electronic submission to the SEC's EDGAR system.
- Overview of the end-to-end filing process
- Frequently asked questions around filing Form N-PX
- Key product features, variants and benefits of our solution
Frequently asked questions (FAQs) about Form N-PX
What is Form N-PX?
Form N-PX is the SEC's annual proxy voting disclosure form. Registered funds have filed it since 2003. What changed materially in 2022 was scope, structure, and who exactly has to file, with first filings made August 31, 2024.
Who is required to file Form N-PX?
Two groups are required to file. Registered management investment companies, including mutual funds and ETFs, have been required to file annually since 2003. Following the 2022 amendments, institutional investment managers that file Form 13F (those exercising investment discretion over $100 million or more in Section 13(f) securities) are now also required to file, disclosing their say-on-pay, say-on-frequency, and golden parachute votes. First filings for the new requirement were due August 31, 2024.
What is the Form N-PX filing deadline?
Form N-PX must be filed with the SEC no later than August 31 each year, covering the 12-month period from July 1 to June 30. Specific transition rules apply for managers making initial or final Form 13F filings during the relevant period.
Does the requirement apply even if we did not vote any say-on-pay proxies?
Yes. Form 13F filers must file Form N-PX regardless of whether they exercised voting discretion on say-on-pay matters during the reporting period. If no votes were cast, the filing must still be made indicating that fact. Failure to file because no votes were exercised is not a recognized exemption.
Is Form N-PX public?
Yes. All Form N-PX filings are publicly available through the SEC's EDGAR database.
How do you file Form N-PX?
Form N-PX is filed electronically with the SEC through EDGAR, the agency's online filing system. Since the 2022 amendments, filings must be submitted in structured XML format, either via the SEC's web-based filing tool or as a valid XML file conforming to the prescribed schema. The filing covers the 12-month period from July 1 to June 30 and must be submitted no later than August 31 each year.
How does an N-PX Amendment form work?
An N-PX/A or amendment is used for a correction or supplement to a previously filed report. Form N-PX amendments are a routine practice, and filers frequently submit them to ensure their public record remains accurate and compliant. Each amendment includes a complete cover page and, if necessary, a summary page.
Amendments do not need to be filed within a certain time frame or window. The SEC expects filers to act promptly, and amendments to be filed as soon as practicable after discovering an error or omission for the period.
What does the XML requirement mean operationally?
Filers must submit N-PX in structured XML format, either via the SEC's web-based filing tool or as a valid XML file conforming to the prescribed schema. Vote data must be accurately organized and field-mapped before submission.
Let's make sure you are ready before the August 31st deadline.
Get your copy of our guide and our solution brief to understand the filing requirements and how Proxymity can help ensure accurate compliance.