SEC Form 4, 2026 Q2: issuer-as-owner filings, flag spellings and filing timing

The questions

Issuer as reporting owner. A company's EDGAR filing list can include Form 4s on which the company is itself a reporting owner for a different issuer. For how many companies does filtering their own list to form type 4 return Form 4s whose issuer is another company, and on how many filings?

Flag spelling. Form 4 XML records each reporting owner's relationship to the issuer in four flags, isDirector, isOfficer, isTenPercentOwner and isOther, and marks Rule 10b5-1 plan trades in aff10b5One. Filers write them as 1/0 or as true/false. How often is each spelling used, and does any document mix them? Also: how many Form 4s name more than one reporting owner, and how many Form 4/A amendments were filed?

Filing timing. How many business days after the transaction is a Form 4 filed, overall and by transaction code? And for the filings that took longer than two business days, what do the form's own timing fields, the transactionTimeliness value, the deemed execution date and the transaction form type, say about them?

Results

Issuer as reporting owner: every Form 4 in the quarter

In 2026 Q2, 35 of the 4,497 companies that were the issuer on at least one Form 4 also appeared as a reporting owner on a Form 4 for a different issuer: 80 filings in all, out of 49,832 Form 4s. For those companies, filtering their own EDGAR filing list to form type 4 returns Form 4s whose issuer is another company. For 20 of them, such filings were at least 10% of the quarter's Form 4s listed under their CIK; for 2, they outnumbered the company's own.

Flag spelling: a random sample of 600 Form 4 XML documents

In a random sample of 600 of the 49,832 Form 4s filed in 2026 Q2, 414 (69%) wrote the relationship flags isDirector, isOfficer, isTenPercentOwner and isOther as 1/0, and 186 (31%) as true/false.

Of the 360 sampled Form 4s that marked a reporting owner as a director, 246 wrote it as 1 rather than true. A check for the string "true" misses those.

No sampled document mixed 1/0 and true/false within its relationship flags, but 59 of 600 (about 10%) wrote those flags as true/false and the Rule 10b5-1 checkbox, aff10b5One, as 0/1.

In 31 of the 600 sampled documents (5%), isDirector was left out entirely rather than written as false or 0.

Sample shares are whole percentages: at this sample size the worst-case margin of error is ±4.0 percentage points at 95% confidence.

Whole-quarter counts from the data set

Across all 49,832 Form 4s in 2026 Q2, aff10b5One was written 0/1 in 38,637 (77.5%) and true/false in 11,195 (22.5%); 296 of the 3,982 issuers with two or more Form 4s that quarter had filings using both.

1,022 of the 49,832 Form 4s in 2026 Q2 (2.1%) named more than one reporting owner, and 713 Form 4/A amendments were filed (1.4% of Form 4 and 4/A filings combined).

The data set keeps aff10b5One as filed (it matched the XML in 600 of 600 sampled documents), so that figure covers the whole quarter. It stores the relationship flags in normalized form, so their spelling can only be estimated from the sample.

Filing timing

A Form 4 cannot mark itself late

In 2026 Q2, 0 of the 107,119 Form 4 transaction rows carried the timeliness value L (late), and 524 carried E (early). A Form 4 has no way to say late: SEC's EDGAR Ownership XML Technical Specification Version 5.5, March 2026, section 4.3.8.2, says “The <transactionTimeliness.value> element is optional and should be left empty.” and “By definition, a “4” transaction is on time. Provide no value for this case.”

So on a Form 4, an empty transactionTimeliness is the specification's default, not the filer's statement that the filing was on time. E marks a transaction reported early, normally one reportable on Form 5; the same section says “By definition, a “5” transaction is early.” Code that looks for late Form 4s in this element finds none.

The form's own timing fields explain little of the tail

Of the 107,116 Form 4 transaction rows measured in 2026 Q2, 6,204 were filed more than two business days after their transaction date. 5,810 of them (93.6%) carry no deemed execution date, no transaction form type 5 and no timeliness value.

A row can carry more than one of these. Across all 107,119 rows, a deemed execution date appears on 950 (0.9%), and 718 are coded as Form 5 transactions reported on a Form 4. Per filing, 2,678 of the 2,961 filings with such rows (90.4%) carry none of them. Those rows are not a count of late filings; the reasons are below.

How long after the transaction a Form 4 is filed

Of the 49,636 Form 4s filed in 2026 Q2 with a dated transaction, 46,675 (94.0%) were filed within two business days of the earliest transaction they report. The median was 2 business days, and the p99 was 63. By row, 94.5% of Table I rows and 93.5% of Table II rows were within two business days of their own transaction date.

By transaction code

Form 4 transaction rows in both tables, for codes with at least 1,000 rows, sorted by the share filed within two business days. Each range is business days from the row's transaction date to the filing date, as a share of measured rows.

Thin tails. Some tails rest on a handful of filings. A code is listed below when its rows more than two business days after the transaction number at least 20 but come from fewer than 50 filings; its tail figures describe those filings, not a pattern across filers. Every code, including those with fewer rows, is in the by-code download.

More than two business days is not, by itself, a late filing

The data set carries dates, and the rules turn on more than dates. Rule text below is eCFR's as of 2026-06-30, inside the quarter, and SEC's Form 4 instructions (Last-Modified 2026-08-25), quoted rather than paraphrased.

• The deadline. 17 CFR 240.16a-3(g)(1): “Form 4 must be filed before the end of the second business day following the day on which the subject transaction has been executed.”
• Deemed execution dates. For a transaction under a Rule 10b5-1(c) plan, or a discretionary transaction, whose execution date the reporting person does not select, the date of execution is deemed to be the date the reporting person is notified of it (17 CFR 240.16a-3(g)(2) and (g)(3)), with a limit in 17 CFR 240.16a-3(g)(4): “if the notification date is later than the third business day following the trade date of the transaction, the date of execution is deemed to be the third business day following the trade date of the transaction.” Form 4, General Instruction 4(a)(ii): “A deemed execution date must be reported in Column 2A of Table I or Column 3A of Table II only if the execution date for the transaction is calculated pursuant to §240.16a-3(g)(2) or §240.16a-3(g)(3).” Measured from the transaction date alone, such a filing can look late and be within the rule.
• Form 5 transactions reported early. 17 CFR 240.16a-3(g)(5): “At the option of the reporting person, transactions that are reportable on Form 5 may be reported on Form 4, so long as the Form 4 is filed no later than the due date of the Form 5 on which the transaction is otherwise required to be reported.” Such a row can carry a transaction date long before its filing date.
• The filing date is EDGAR's. 17 CFR 232.13(a)(4): “a Form 3, 4, or 5 … submitted by direct transmission commencing on or before 10 p.m. Eastern Standard Time or Eastern Daylight Time, whichever is currently in effect, shall be deemed filed on the same business day.” A filing that starts later is deemed filed the next business day. The data set carries a date, not a time, so an interval of three business days can be a submission made after that cutoff on the second business day.
• The columns cannot carry every reason. A Form 5 transaction reported early without transaction form type 5, a plan transaction with no deemed date entered, a footnote explaining the timing and a late-evening submission all look, in these fields, like a filing made late.

Checked two ways, and against the filings

Two independent programs, one reading SEC's extracted tables and one reading the zip directly with its own holiday parse and business-day count, agreed on all 17,523 compared values (0 disagreements). Then 30 Form 4 filings, chosen deterministically (20 whose earliest transaction was more than 45 calendar days before filing, and 10 within 3 calendar days), were compared with their own submission text on EDGAR: 30 of 30 matched on the filing date, every transaction date, deemed execution date, transactionTimeliness value and transactionFormType.

Prior work

Two published studies measure Form 4 filing delay. How late is Form 4 'real-time' data? Measuring filing delay on 11,241 insider filings, on dev.to (2026-08-24), covers July 2026 filings via a commercial API, measured from the earliest transaction date on the form, with a split by transaction code. Form 4 Insider Trading in Python: A Filing-Date Event Study, by QuantInsti (2026-08-25), covers C-suite code-P purchases, 2022 to 2026 Q2, trading sessions. Their populations and clocks differ from this one, so their figures and these are not directly comparable.

Sources

Every request declared a User-Agent with a company name and contact address, as SEC's fair-access policy asks. 1,260 requests in all, 1,260 of them answered HTTP 200, with 0 retries and no more than 5 started in any one second. The filing-timing figures took 58 more requests and the spot-check 30, each declaring the same User-Agent.

Method

Issuer as reporting owner

Companies are the distinct issuer CIKs over the data set's Form 4 filings (4,497). A cross-issuer filing is a Form 4 with at least one reporting-owner CIK that is one of those companies and is not the filing's own issuer. CIKs are compared as integers; a Form 4 that lists its own issuer as a reporting owner is not counted.

Computed three independent ways, which returned the same companies and the same (filing, company) pairs, compared element by element: an in-memory join of the data set's SUBMISSION and REPORTINGOWNER tables; a SQL join of the same tables; and a join of SUBMISSION against EDGAR's quarterly full index in place of REPORTINGOWNER.

Coverage. EDGAR's full index for the quarter lists 49,832 Form 4 and 713 Form 4/A accessions: the same accession sets as the data set, with 0 missing in either direction.

Live check. On 2026-09-14, 80 of the 80 cross-issuer filings were present, with form 4, in the companies' filing lists on data.sec.gov. For 10 of them, chosen by seed, the raw XML was read: in 10 of 10, the issuer is a different company and the company is a reporting owner.

Share of a company's list is its cross-issuer Form 4s divided by the quarter's Form 4s listed under its CIK (its own Form 4s as issuer plus its cross-issuer Form 4s).

Flag spelling

Population: the data set's 49,832 Form 4 accessions. Form 4/A was not sampled.

Draw: for each accession number, the key is the lowercase hex SHA-256 of <seed>|<accession number> with the seed aervik-sec-form4-2026q2-20260914. Keys are sorted ascending and the first 600 are the sample. That is reproducible in any language without a random-number library. A filing that failed to resolve would have been recorded and replaced by the next rank; none failed (0 excluded).

Document: the filing's index.json in EDGAR Archives, and the top-level XML document it lists with an ownershipDocument root.

Classification: each element's text is trimmed; true or false is one spelling, 1 or 0 the other. No other value occurred. An element that is not in the document is counted as absent, not as a spelling. Figures are per document.

Two independent parsers, one using regular expressions over the raw text and one an XML tree parser walking the schema positions, agreed on all 18 compared fields for all 600 documents (0 disagreements). For 600 of 600 documents, the XML's issuer CIK, document type, reporting-owner count and raw aff10b5One value equal the data set's.

Uncertainty. The worst-case margin of error for a proportion at this sample size is ±4.0 percentage points at 95% confidence. The upper bound quoted under Limitations is a Wilson score interval.

Filing timing

Source: the same data set file, https://www.sec.gov/files/datastandardsinnovation/data/insider-transactions-data-sets/2026q2_form345.zip, Last-Modified 2026-07-09, read again on 2026-09-15.

Population: the quarter's 49,832 Form 4s, of which 49,636 are measured; 195 with no transaction row and 1 whose earliest transaction date is after its filing date are counted and not measured. Of 107,119 transaction rows, 3 dated after their filing are left out of the distributions. Form 4/A amendments are measured separately and are in no Form 4 figure: 672 were measured, with a median of 13 business days from the earliest transaction date and 16.2% within two.

Business days: not a Saturday, not a Sunday, and not a date in OPM's federal holiday schedule (read 2026-09-15 02:39 UTC). OPM's 2026 holidays equal the 11 dates on SEC's EDGAR Calendar. The interval is the number of business days after the transaction date up to and including the filing date: a Form 4 filed on the second business day after the transaction has an interval of two, and a Saturday transaction filed on Monday an interval of one. The Form 4 rules we read do not define “business day”; this calendar is our measure.

Filing date: the date EDGAR assigns. Under 17 CFR 232.13(a)(4), quoted above, a submission that starts after the evening cutoff is deemed filed the next business day; the data set has no submission time.

Per filing: from the earliest transaction date across both tables of the filing to its filing date, the longest interval in the filing. Per row: from that row's transaction date. Percentiles: nearest rank. Codes: the by-code download gives a code its own line with at least 100 measured rows in a table and pools the rest.

Calendar sensitivity: EDGAR published no daily index on 3 weekdays between 2025-01-01 and 2026-06-30 that OPM counts as business days. Treating them as closed changes 0 bucket counts and moves no median, p90 or p99 by more than 3 business days.

Limitations

• One quarter. Filing dates 2026-04-01 to 2026-06-30. Nothing here says other quarters look the same.
• The issuer-as-owner count is a floor. It counts only companies that were a Form 4 issuer in the quarter. Entities that report as owners but had no Form 4 as issuer that quarter, such as funds, holding vehicles and non-registrants, are not counted, because the data set does not distinguish entity owners from natural persons and we did not try to. Widening the universe to any Form 3, 4 or 5 issuer gives 38 of 5,065. The count is a floor for companies whose EDGAR list contains other issuers' Form 4s, not a ceiling.
• A quarter is not a lookup. A company's recent filing list on data.sec.gov usually spans far more than one quarter, so a real lookup sees several quarters of cross-issuer filings at once. We did not measure that; do not read the quarter figure as a per-lookup rate.
• SEC-derived data set. SEC disclaims the accuracy of the data set's extraction. That is mitigated by the full-index coverage match and the XML cross-check of the sampled documents, and not eliminated for fields we did not check.
• Sampling error. A sample of 600: worst case ±4.0 points at 95% confidence. Counts of individual element occurrences are not quoted, because joint filings repeat values. With 0 of 600 documents mixing spellings within the relationship flags, the 95% upper bound on that rate is 0.64%; it does not prove mixing never happens.
• Form 4/A. Excluded from the issuer-as-owner count and from the sample. Including 4/A on both sides of the count gives 35 of 4,508 companies and 81 filings. The 4/A share above is exact.
• Non-XML filings. The data set holds XML submissions only. Its Form 4 accession set equals EDGAR's full index for the quarter, so no Form 4 in the quarter was left out on that account.
• Filing timing is a filing-date cohort. Every Form 4 filed in the quarter, whatever its transaction date: transactions from the quarter filed later are absent, and older transactions filed in the quarter are present.
• Dates, not times. The data set has no submission time, so EDGAR's evening cutoff cannot be applied, and some intervals of three business days may be late-evening submissions.
• Calendar. EDGAR's daily indexes were checked against the calendar from 2025-01-01; closures before that were not checked, and before 2011-01-01 only weekends are excluded. SEC business days are not exchange trading sessions.
• The rows with no visible marker are not classified. Footnotes and remarks were not read. The count says only that the form's timing fields are empty for those rows.
• Rows versus filings. Row figures weight filings with many rows; tails that rest on few filings are named above.
• Element placement. One parser counted the flag elements anywhere in the document, the other only in their schema positions. Their agreement on every sampled document means no stray occurrences affected the counts.

What this data does not support

• That the issuer-as-owner problem is common across companies. In 2026 Q2 it affected under 1% of Form 4 issuers; its weight falls on the companies it affects, not across the market.
• That most Form 4s mix spellings. Within the relationship flags, no sampled document did.
• Any rate for other quarters, for Forms 3 or 5, or for a company's multi-quarter recent filing list.
• That any filing, filer, issuer or transaction code was late or out of compliance. A filing-timing figure is a measured interval between two dates, and the rows with no visible timing marker are not a count of late filings.
• That the flag spelling is always set by the filing agent. The first part of an accession number identifies the submitter, often a filing agent; of the 38 submitters with two or more sampled documents, 37 used one relationship-flag spelling throughout.
• Any statement about a particular company or filer beyond the counts. The company file is published so the count can be checked; appearing in it reflects how EDGAR indexes a filing, not anything about the company.
• Anything about what an insider trade means. This is about reading the data correctly, not investment advice.

Downloads

• companies-issuer-as-reporting-owner.csv One row per company: CIK, company name as issuer, cross-issuer Form 4s, the company's own Form 4s, and the cross-issuer share of the Form 4s listed under its CIK.
• sample-flag-spellings.csv One row per sampled document, keyed by accession number: draw key, issuer CIK, each flag's raw values and spelling tallies, and the document's SHA-256. No owner names, no filenames.
• summary.json Every issuer-as-owner and flag-spelling figure on this page, the sources with read times, the sample parameters, license and citation.
• lag-summary.json Every filing-timing figure on this page, its sources with read times, the method, the specification and rule text quoted, and the verification. Aggregates only.
• lag-by-code.csv Filing timing per table and transaction code: rows, business-day ranges, median, p90 and p99, and what the form's timing fields show for rows more than two business days after the transaction. Counts only.
• README.txt Column definitions, method summary, rounding, limitations, license and citation.

Free to use and redistribute, including commercially, with attribution under CC BY 4.0. If you publish something built on it, a link to this page gives readers the method and any later correction alongside the files.

Suggested citation

Aervik Labs. "SEC Form 4, 2026 Q2: issuer-as-owner filings, flag spellings and filing timing." Measurement of the SEC Insider Transactions Data Set 2026q2 and 600 EDGAR Form 4 XML documents, read 2026-09-14. https://aerviklabs.com/research/sec-form4-2026q2/ (CC BY 4.0)

@misc{aervik_sec_form4_2026q2,
  author       = {{Aervik Labs}},
  title        = {SEC Form 4, 2026 Q2: issuer-as-owner filings, flag spellings and filing timing},
  year         = {2026},
  howpublished = {Data set, CC BY 4.0},
  note         = {Measurement of the SEC Insider Transactions Data Set 2026q2 and 600 EDGAR Form 4 XML documents, read 2026-09-14},
  url          = {https://aerviklabs.com/research/sec-form4-2026q2/}
}

About this research

Published by Aervik Labs, operated by EAC Ventures, LLC. We sell an API that reads SEC Form 4 filings, so all three matter to us; that is why the method and the data are published in full. For handling them in code, see Parsing SEC Form 4 XML.

Corrections: if a figure here is wrong, we fix it and say so, with the date. See About for how to report an error and who is accountable.