Pink Current Information ended on July 1, 2025, when OTC Markets Group launched OTCID. The new market is for companies that keep their public information current and meet a basic set of disclosure requirements. For a company that previously held Pink Current status, the question now is whether it meets the OTCID requirements and has a process for maintaining them.
That review needs to go beyond the latest financial statements. OTCID also involves management certifications, a verified company profile and, for U.S. and Canadian companies, share information provided through the required arrangements. These tasks may sit with different people, but they all affect the company’s position.
Imagine a finance team completing its annual report while everyone assumes someone else has handled the company profile. The report is published, the deadline is marked as met, and the separate verification is left unfinished. A useful OTCID review is designed to catch that sort of gap before it becomes an urgent problem.
What Replaced Pink Current Information?
OTCID is OTC Markets Group’s basic reporting market. It sits below OTCQB and OTCQX, which have higher qualification standards. Pink Limited remains a separate market, so references to the end of Pink Current should not be read as the disappearance of every Pink designation.
The distinction is the company’s involvement in its U.S. market disclosures. OTCID identifies companies that provide the required information, certifications and profile verification. Pink Limited can include companies that do not meet those requirements or do not maintain an active relationship with OTC Markets Group.
For a board considering a later move to OTCQB or OTCQX, OTCID should be treated as its own set of obligations. Meeting the basic requirements does not establish eligibility for a higher market. Any proposed upgrade needs a separate review of that market’s standards.
Shareholder announcements should reflect that distinction. Explain the designation the company has obtained and what it involves. Avoid suggesting that basic reporting status is a recommendation to buy the shares or a promise of more active trading. Where a later move to OTCQB is still a plan, describe it as a plan rather than implying that the company has already qualified.
Start with the Company’s Reporting Obligations
Not every OTCID company reports in the same way. An SEC-reporting company must remain current with its SEC filings. An eligible company using the Alternative Reporting Standard publishes under OTC Markets’ disclosure framework. There are also routes for qualifying international companies and banks. OTCID does not require every issuer to become an SEC filer, nor does it cancel existing SEC reporting duties.
For alternative-reporting companies, the usual deadlines are 45 days after quarter-end for quarterly reports and 90 days after fiscal year-end for annual reports. Those dates should not be copied into every issuer’s calendar. SEC-reporting companies, international issuers and banks need schedules that reflect their own reporting obligations.
Before preparing the next report, confirm which standard the company follows and what that standard requires. Then compare the requirements with the published record. A completed annual report does not answer whether an earlier reporting period is missing or whether information elsewhere needs updating.
This is particularly worth doing when a new finance officer, outside accountant or legal adviser takes over. Give the incoming person the filing history, upcoming deadlines and unresolved questions. A folder of old reports is useful, but it does not explain which work is complete and which assumptions still need checking.
The OTCID Requirements Beyond Financial Reports
Companies generally submit a Management Certification before joining or requalifying for OTCID and again with annual reporting. Qualifying international reporting companies use a Rule 12g3-2(b) certification instead. The rules link the annual certification to the annual report filing, with an outside deadline of 45 calendar days after the report’s due date. That certification deadline does not extend the deadline for the report itself.
The company profile must also be verified through OTCIQ initially and at least every six months. A profile may contain information that still looks accurate while its verification is overdue. Put verification on the calendar as a separate task, and check the details rather than simply repeating the previous confirmation.
U.S. and Canadian companies must retain a transfer agent participating in the Transfer Agent Verified Shares Program, or provide data directly if acting as their own transfer agent. They must also authorize the agent to supply the required securities information to OTC Markets. Confirm both the agent’s participation and the authorization; merely having a transfer agent does not settle those questions.
The required OTCID Disclosure & News Service subscription and applicable fees need attention too. Paying for the service supports the disclosure process but does not satisfy the reporting requirements. Include renewals and billing contacts in the same internal review so an administrative task is not overlooked while everyone concentrates on the accounts.
Preparing an OTCIQ Disclosure Package
OTCIQ is the portal used to manage company information and publish applicable disclosures. OTCID is the market designation. The names are similar, but opening an OTCIQ account is not the same as qualifying for OTCID. The portal is where part of the work is submitted, not evidence that all the requirements have been met.
Begin with the underlying records. Collect the financial statements, ownership information, management details and share records for the relevant dates. Compare the report with those records before publication, rather than asking each contributor to check only their own section. This is also the stage to establish whether an attorney letter is required and arrange the legal review.
Where an attorney letter is needed, ask counsel early which records they will need and who should answer any follow-up questions. Build that review into the timetable agreed with finance. Sending an incomplete package just before the filing deadline leaves little room to resolve discrepancies, obtain missing records or make changes that affect more than one part of the report.
For example, suppose an annual report gives the number of outstanding shares at year-end, while the transfer agent’s latest statement reflects a later share issuance. The two figures may properly differ. The reviewer should check the dates and confirm that the intervening issuance explains the difference. Changing one figure simply to make the documents match would not solve the problem.
Read the business description as carefully as the figures. Does it describe what the company does now? Have the people named in the report changed roles? Are earlier statements about ownership or operations being carried forward without being checked? Working through these questions is more useful than treating last year’s document as a form that only needs new dates.
Allow time for corrections before the filing deadline. After publication, open the public version and check that the intended document is visible, complete and readable. Keep the final approved copy and submission record together so the next person reviewing the file can see exactly what was published.
OTCID, Pink Limited and the Expert Market
A company that falls short of OTCID’s requirements can lose that designation. The next market depends on its reporting position and quotation eligibility. Pink Limited can include companies that no longer meet OTCID’s requirements but still meet the conditions for Pink Limited. A company with more serious information gaps may move to the Expert Market.
The Expert Market has tighter quotation restrictions. Quotes are unsolicited only, meaning they represent qualifying customer orders rather than a dealer’s own trading interest. Quote information is not available to the general public in the same way. These restrictions matter, but they should not be described as an automatic ban on every transaction in the shares.
A quotation is a price at which someone is willing to buy or sell; a trade is the completed transaction. Limits on quotations and limits on trading are related, but they are not identical. Investors also need to check their broker’s restrictions, since the market designation alone does not tell them what their brokerage account will permit.
A move to Pink Limited need not be permanent. The company must meet OTCID’s eligibility requirements and follow the applicable admission or requalification process. The rules allow some former OTCID companies to requalify automatically after restoring compliance, provided they have not undergone a change in control. That route is not available on the same terms to every company.
Restoring Disclosures and Restoring Quotations are Different Jobs
Publishing missing information may address a disclosure problem without completing everything needed to start or restore quotations. SEC Rule 15c2-11 and FINRA Rule 6432 govern information reviews and related procedures for initiating or resuming quotations, subject to their exceptions. Depending on the circumstances, the process may involve a broker-dealer or a qualified interdealer quotation system.
That distinction should be settled early in a recovery plan. Ask whether the problem concerns OTCID qualification, quotation eligibility, or both. Then identify the information and review required for each. An issuer should not announce that normal quotations will resume on a particular date solely because it expects to upload its reports by then.
Before giving shareholders a timing update, separate what the company has completed from what still depends on a third party’s review. That is a more useful explanation than saying everything has been submitted and leaving the remaining steps unclear.
Keeping Management and the Board Informed
One person should coordinate the process, even where several people prepare the information. Finance can own the accounts, counsel can review legal disclosures, and management can handle certifications. The coordinator’s job is to establish what remains open and make sure it is assigned to someone.
A shared calendar should cover reports, certifications, profile verification and service renewals. Add internal review dates, not just final deadlines. Where information is needed from the transfer agent or an outside adviser, agree when it must arrive. Otherwise, a deadline on the calendar may hide the fact that nobody has requested the material needed to meet it.
Keep a short handover note as well. It should identify the people authorized to submit documents, where approved copies are stored and who receives messages about the account. Review that note when staff or advisers change. The aim is to avoid a filing process that works only because one employee remembers every step, and becomes difficult to reconstruct when that person is unavailable.
For the board, keep the update practical: the company’s current market designation, work completed, outstanding items and the next deadlines. Begin with what has actually been published, compare it with the requirements, and assign an owner to every gap. A report marked ‘filed’ should not be the end of the review.
Ishimbayev Law Firm, P.C. helps OTC issuers review quotation readiness, prepare and update OTCIQ disclosures, and address attorney-letter requirements where needed. Contact our team to review your company’s current position, identify missing information and plan the work required to meet or maintain OTCID’s requirements.