Human Capital Disclosures

In August 2020, the SEC adopted final amendments to Item 101 of Regulation S-K including adding a requirement for disclosures related to “human capital” (see HERE).  The new rule applies to Form 10-Ks and registration statements filed after November 8, 2020.  This blog will not only discuss how companies are navigating their human capital disclosures, but also the push to add more prescriptive disclosure requirements to the rules, which the SEC is considering.  Amendments to the rule are currently included on the SEC’s regulatory agenda although as of now, the SEC has not published a proposal.

Drill Down on Human Capital Disclosure

Item 101(c)(2) of Regulation S-K now requires that a company discuss, in its Form 10-K and in registration statements, the following information to the extent material to an understanding of the business: “[A] description of the registrant’s human capital resources, including the number of persons employed by the registrant, and any human capital measures or objectives that