The New SEC Semiannual Reporting Proposal

A new proposal that would ease financial reporting requirements is stirring emotion among investors.

The proposal from the US Securities and Exchange Commission’s (SEC) in May 2026 would allow public companies to file semiannual results on Form 10-S in lieu of quarterly results on Form 10-Q. This has generated overwhelming opposition, primarily from individual investors who worry that less frequent mandatory reporting would reduce transparency and increase information asymmetry, making valuation more difficult.

The CFA Institute and our members share those concerns. In a survey of more than 2,500 CFA Institute members, approximately 70% opposed allowing companies flexibility to determine or change reporting frequency, and nearly 85% expressed concern about comparability under a flexible reporting regime. Investors also view earnings releases and Form 10-Qs as complementary, not interchangeable, and were highly skeptical that a voluntary, quarterly earnings release system would provide investors with nearly the same level of information as today.

If the SEC adopts the new proposal as law, semiannual reporting could begin as soon as 2027.

Professor Tzachi Zach of The Ohio State University has built a public tracker of the SEC comment letters on the proposal. The tracker separately identifies form letters and individually classified letters, and sorts them as support, oppose, or conditional. As of the latest snapshot (July 18), total submissions exceed 108,000, with 107,800 opposing the SEC’s proposal and 255 in favor.— a fraction of one percent.

Though the overwhelming majority opposes the new proposal, the majority is not the final score on the proposal.

In the comment letter process, all votes are not counted equally. One comment from a major issuer or association can have more influence than scores of other votes. Further, the supporters of the proposal are companies that CFA Institute members may own or analyze. To the extent the company names are public, CFA Institute member investors should open a dialogue with them about their support for semiannual reporting.

Many large companies support the proposal including business associations, oil & gas, and pharmaceuticals. Eli Lilly, for example, stated that, if the rule is adopted substantially as proposed, it anticipates electing to file semiannual reports on Form 10-S while continuing voluntary quarterly earnings releases. A joint letter from Bristol Myers Squibb, Eli Lilly, Gilead, Johnson & Johnson, Merck, Pfizer, Roivant, Viatris, and Zoetis similarly supports optional semiannual reporting and says some of the companies currently anticipate electing Form 10-S while continuing voluntary quarterly earnings releases.

ExxonMobil also supports the proposal. Its letter argues that investors increasingly rely on earnings releases, presentations, and Form 8-K filings rather than the Form 10-Q itself. ExxonMobil also proposes an optional new Form 8-K item through which companies could file first- and third-quarter financial statements and related information without preparing a full Form 10-Q.

Industry associations including the U.S. Chamber of Commerce, the National Association of Manufacturers, the American Petroleum Institute, MassBio, The National Association of Real Estate Investment Trusts (Nareit), the Aerospace Industries Association, and the Retail Industry Leaders Association all publicly expressed support for the proposal. 

One of the most important supportive letters comes from Financial Executives International’s Committee on Corporate Reporting. FEI CCR says its members include “approximately 50 chief accounting officers and corporate controllers from Fortune 100 and other large public companies, representing more than $19 trillion in market capitalization.” In a survey of CCR members, 58% said they would most likely elect semiannual reporting, while 42% said they would most likely continue filing quarterly. Among those leaning toward semiannual reporting, all said they would continue issuing voluntary quarterly earnings releases.

That is a critical data point: could almost 60% of large (Fortune 100) companies elect semiannual reporting, moving their quarterly reports to purely earnings release processes? While better than nothing, the content, legal liability, assurance and comparability across issuers for earnings releases are markedly lower than those of a Form 10-Q.

Companies and issuer associations generally support the proposal because they see the Form 10-Q as costly, rigid and duplicative. Their common argument is that investors already receive material information through earnings releases, investor presentations, and Form 8-Ks, often before the Form 10-Q is filed, and that Form 10-Q imposes significant incremental burden without commensurate benefit.

The second argument is flexibility: Supporters say a mandatory quarterly cadence does not fit all companies. Pharma and biotech commenters argue that drug development is measured in years, not quarters, and that investors focus more on clinical milestones and regulatory events than quarterly results. Nareit makes a similar industry-specific argument for REITs, noting that real estate business cycles and capital structures may not align with 90-day reporting windows. 

At the same time, many supporters of the new proposal acknowledge common benefits of quarterly reporting such as debt covenants, investor expectations, and insider trading windows to name a few.

Investors, shareholders, analysts, and stewardship teams should ask companies in favor of the new SEC proposal:

• Is your company considering semiannual reporting on Form 10-S?
• Would the board make the decision, or would the company seek investor input first?
• Will you continue publishing quarterly earnings releases?
• Will quarterly earnings releases include GAAP financial statements, notes, and MD&A information comparable to what investors receive today?
• Will auditors review the optional earnings release?
• Would the company commit to maintaining quarterly disclosure quality over time?
• What circumstances would cause it to return to quarterly reporting?

The SEC may ultimately decide what companies are permitted to do. Investors, however, should decide what they expect their portfolio companies to do with that permission.