SEC Opens Public Comment On Regulation S-K
On January 13, 2026, SEC Chair Paul S. Atkins issued a high-profile request for public comment on modernizing Regulation S-K, the SEC’s central framework for narrative disclosures in public company filings. This move signals one of the most consequential disclosure reform efforts in years and comes as part of a broader recalibration of SEC priorities under his leadership. For more on Chair Atkins priorities, including disclosure reform, see HERE.
Background – Regulation S-K
Regulation S-K has governed the qualitative disclosure requirements in U.S. securities filings since it was first adopted in the early 1980s. Regulation S-K governs the disclosures made in periodic reports under the Exchange Act (for example Forms 10-Q, 10-K, 8-K, 20-F, proxy statements…) and registration statements filed under the Securities Act (for example, S-1, S-3, S-4, F-1, F-3, F-4, etc..). Regulation S-K encompasses items ranging from a company’s business description and risk factors to management’s discussion and analysis (MD&A) and executive compensation disclosures.
Over time, Regulation
