The SEC has already or may yet update its periodic reporting requirements on a number of fronts. Most of these relate to ESG, KPI and non-GAAP disclosures. Meanwhile, COVID-19 continues to require dynamic responses.
Public companies have been monitoring and rapidly adapting to a wide array of developments impacting periodic reporting disclosure practices over the last year. Several new SEC rules went into effect during this time. These include various amendments to Regulation S-K, such as the addition of a new human capital disclosure requirement that became effective in November 2020, as well as revisions to MD&A disclosure requirements that public companies may now apply on a voluntary basis ahead of an August 2021 effective date.[1] In light of the fact that calendar year-end companies gave consideration to these amendments in connection with recent Form 10-K filings, this article will highlight the following four key areas impacting periodic reporting for public companies for the remainder of 2021:
- Evolving disclosure considerations arising from the COVID-19 pandemic.
- The renewed focus of the SEC on climate-related considerations and other issues related to environmental, social and governance (ESG) matters under the Biden administration.
- The SEC’s key performance…
