PDFs are not an acceptable format for images. Deduplication and AI-assisted review must be approved by Enforcement before you do it. Google Drive and Microsoft 365 links are not accepted. All three are in the SEC’s own specification, and almost nobody reads it before producing.
The Securities and Exchange Commission publishes exactly what a production to it has to look like. The current edition is marked Rev 08/2026, and it is more prescriptive than most court protocols.
Producing to the SEC without reading it is how a volume gets rejected and a deadline gets missed.
The image specification
Black and white images must be 300 DPI Group IV single-page TIFF files. Color images must be produced in JPEG format. And flatly: PDFs are not an acceptable format for images.
AutoCAD and photograph files should be produced as a single page JPEG. Excel files get a placeholder image named by Bates number rather than being imaged. No folder may exceed 2,000 image files.
The load files
The data file is a .DAT. The image cross-reference file is a .LOG or .OPT. The standards specify Concordance default delimiters — a comma as ASCII character 020 and a quote as þ, ASCII character 254.
The cross-reference file carries seven comma-delimited fields: ImageID, VolumeLabel, ImageFilePath, DocumentBreak, FolderBreak, BoxBreak, PageCount. A Unicode .DAT must contain the byte order marker. Dates are mm/dd/yyyy, and date, time and time zone go in separate fields. Each load-ready collection should include only one data load file and one image pointer file.
Text is not optional and not in the load file
Text must be produced as separate document-level text files, not as fields within the .DAT file, named per the FIRSTBATES or image key. Files may be ANSI or Unicode, but all text files must be in the same format within the same production, and foreign characters require Unicode.
For redacted documents the standards direct you to provide the full text for the redacted version — which is the same trap that catches litigants in court productions, written into the SEC’s specification explicitly.
Two requirements that change how you work, not just what you ship
First: all electronic files must be produced in their native format, with natives named by FIRSTBATES and linked through the LINK field. Email containers must be separated by custodian. PDFs produced natively need prior approval and must be unitized, flattened and contain embedded text.
Second, and this is the one people miss: deduplication and AI-assisted or technology-assisted review must be discussed with and approved by the Division of Enforcement. You do not get to choose your culling methodology unilaterally. And where deduplication is approved, the CUSTODIAN field must list every custodian who possessed a specific document.
If your review plan assumes global deduplication and TAR, that plan needs Enforcement’s agreement before it is a plan.
The metadata list is long
Addendum A runs to more than forty fields, including SHA256 hashes, TEXTPATH, the internal message ID, email importance, Office flags and the full header. Chat data requires a unique thread ID field. Translated material requires a translation field.
One internal inconsistency worth knowing: Section I.3 requires an OCRPATH field that the Addendum A list does not include. Build for both.
Delivery, which has its own rules
Media must be labeled with case number, production date, producing party and Bates range, and encrypted with industry standard self-extracting encryption software, with passwords sent separately. Email transmission is accepted only for productions of 10MB or less. File-sharing sites such as Google Drive or Microsoft Office 365 are not accepted. Material carrying Bank Secrecy Act or suspicious activity report content must be encrypted, segregated and marked.
Physical productions go to the Enforcement CPU in Vienna, Virginia — about twenty minutes from our office, which occasionally matters more than it should.
What we do
Pro-Legal Services, Inc. builds productions to the SEC Data Delivery Standards from Arlington, Virginia — images, load files and document-level text to specification, natives linked, metadata to Addendum A, text regenerated for redacted documents, and the culling methodology raised with Enforcement before it is relied on.
Small business, minority-owned, SAM registered. We also test-load every volume before it ships.
Pro-Legal Services, Inc. produces to the Commission from Arlington, Virginia, minutes from the District and a short drive from the Enforcement CPU in Vienna, for counsel nationwide.
Producing to Enforcement on a deadline? Send us the request and your intended culling plan. The approval question is the one to settle first. Pro-Legal Services, Inc. · 1550 Wilson Blvd, Suite 250, Arlington, VA 22209 · 202-955-9400 · info@pro-legal.com