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November 21, 2025 | 8:30 AM – 9:30 AM ET
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Articles + Publications October 8, 2025
The Securities and Exchange Commission (SEC) is actively evaluating whether to transition from the current quarterly reporting regime for domestic public companies to a semiannual reporting framework. Although no formal proposal or timeline has been released, recent public statements by President Donald Trump and SEC Chair Paul Atkins indicate strong support for such a shift. However, significant hurdles and practical considerations remain before any such implementation can take effect.
Key Takeaways
Background
Semiannual reporting is not new to the U.S. capital markets, and this is not the first time the SEC has considered a change in reporting frequency. Before 1970, the U.S. was on a semiannual reporting schedule. The SEC adopted the Quarterly Report on Form 10-Q in 1970, after years of semiannual Form 9-K practice in the 1950s and 1960s, moving the U.S. from semiannual to quarterly periodic disclosure. Between 2018 and 2019, during President Trump’s first term, the SEC actively considered semiannual reporting after support for the change was also voiced by the president. The SEC initially requested data in a request for comment (RFC) at the end of 2018 covering: (i) overlaps between 10-Qs and earnings releases; (ii) whether earnings releases and Current Reports on Form 8-Ks could satisfy core 10-Q requirements; and (iii) whether rules should allow flexibility in frequency (issuer-wide or by class). Commentators were largely split between companies and their industry groups pushing for less frequent reporting against some investors (including banks, fund managers, etc.) pushing to maintain quarterly reporting. However, the SEC dropped the potential policy change by delaying the issuance of any official rulemaking proposal during the final year of President Trump’s first term. In 2021, however, shortly after President Joseph Biden took office and appointed then-SEC Chair Gary Gensler, the SEC officially withdrew the proposal from consideration and further development.
What’s New in September 2025 and Why This Time May Be Different
On September 15, 2025, President Trump called on the SEC to consider a regulatory shift to semiannual reporting over quarterly reporting by domestic public companies. President Trump’s support for less frequent reporting stems from two areas of concern: (i) reducing “short-termism concerns,” where investors and companies only focus on short-term improvements rather than long-term growth, and (ii) reducing compliance and reporting burdens for public companies to incentivize more companies to go — and stay — public. Shifting to semiannual reporting would also align the U.S. capital markets reporting scheme with other international reporting schemes (including Australia, the UK, and Europe) which already maintain a semiannual reporting frequency.
Atkins has also publicly signaled support for the reporting change. He briefly addressed the concept of semiannual reporting during an open SEC meeting on September 17, which was held to vote on mandatory arbitration clauses in initial public offerings (IPOs). Atkins described these measures as “among the first steps of my goal” to reinvigorate IPO activity. He has repeatedly stated that one of his main policy goals as SEC chair is to make becoming a public company more attractive by eliminating compliance requirements that do not provide meaningful investor protections, minimizing regulatory uncertainty, and reducing legal complexities in the SEC’s rules.
On September 30, the SEC received a formal petition from the Long-Term Stock Exchange, a San Francisco-based securities exchange, to permit public companies to report on a semiannual basis, although the SEC has yet to comment.
Proponents argue that semiannual reporting would reduce costs and duplicative efforts, while freeing management’s attention for strategic moves that may negatively impact a company’s earnings in the short term but result in better long-term outcomes. A shift to semiannual reporting would also ensure the U.S. is consistent with international markets and result in parity with foreign private issuers (public companies which are domiciled outside the U.S. but are required to, or voluntarily, report with the SEC), as many such international issuers operate without mandated quarterly filings.
Opponents raise concerns that transparency and market efficiency will suffer, as bad news may be delayed, volatility may increase, and analyst coverage could diminish. Such a change could also lead to detrimental impacts for insiders and controlling shareholders, as quarterly filings help manage the release of material nonpublic information and available trading windows, allowing potentially larger windows of time in which such insiders may freely trade in company securities. Less frequent mandated public reporting can complicate trading compliance unless companies supplement with robust current reports or make voluntary updates. Empirically, critics of semiannual reporting argue, a reporting change would not cure short-termism, as companies may still face quarterly expectations from markets, institutional investors, and creditors even without a legal mandate.
There May Be Considerable Regulatory Changes to Implement Semiannual Reporting
Rules 13a-13 and 15d-13 under the Securities Exchange Act of 1934, along with Form 10-Q instructions, establish quarterly periodic reports and their requirements. A move to semiannual reporting would require amending those rules and forms with coordinated updates to Regulation S-K, Regulation S-X interim presentations, review expectations by auditors (and the rules of the Public Company Accounting Oversight Board (PCAOB)), Financial Accounting Standards Board (FASB) and securities exchange rules (such as the New York Stock Exchange and Nasdaq). As a result, even if the SEC implements a rule change, a rolling implementation process would be necessary before the capital markets are fully aligned on semiannual reporting. This process could take several months if not years.
There may be some clues to the SEC’s potential course of action from the 2018 RFC. The SEC provided several potential options for shifting to a semiannual reporting scheme, while understanding and maintaining the market’s expectations for quarterly information. The SEC, at least in 2018, did not expect a hard or immediate shift to semiannual reporting but rather carveouts and/or exceptions to support the market’s expectations. Instead, the SEC asked for public opinions on options related to:
Another potential option briefly discussed by Atkins was to allow issuers the choice to provide quarterly reports and remove the mandated reporting requirements for the first and third quarters.
Practical Implications
From a practical perspective, reporting companies would need to consider the impact of the following if semiannual reporting is implemented:
Where Things Stand Today; Looking Ahead
No proposed rule or new RFC has been published yet, but the SEC’s recent regulatory agenda suggests active consideration of disclosure reforms. Recent Supreme Court decisions have heightened scrutiny of administrative rulemaking, so any substantial change will likely involve extensive public comment and participation and could take more than a year to finalize. The effective date of any new rule could be months or years after adoption, depending on implementation details.
Speaking Engagements
Georgetown Law 2025 Advanced eDiscovery Institute
November 21, 2025 | 8:30 AM – 9:30 AM ET
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New York, NY
Leading the energy evolution.
Learn more
From compliance to the courtroom, we have you covered.
Learn more
Helping you focus on what matters – improving human health.
Learn more
Trusted advisors to leading insurers for 100+ years.
Learn more
Unlocking value in the middle market and beyond.
Learn more
Full-service legal advice from coast to coast.
Learn more
Applying radical applications of common sense
Explore More
Our standard-setting client experience program.
Explore more
Delivering life-changing help to those most in need.
Explore More
Our firm’s greatest asset is our people.
Explore More
Market-leading eDiscovery and data management services.
Explore more
The Pepper Center for Public Services
Explore more
Strategies helps businesses and individuals solve the complexities of dealing with the government at every level. Our team of specialists concentrate exclusively on government affairs, representing clients nationwide who need assistance with public policy, advocacy, and government relations strategies.
This unique program provides innovative and affordable opportunities to startups and early-stage emerging companies with a solid technology or scientific foundation. We help companies that have a quality management team in place and do not have other significant legal representation.
eMerge’s lawyers and technologists work together to deliver strategic end-to-end eDiscovery and data management solutions for litigation, investigations, due diligence, and compliance matters. We help clients discover the information necessary to resolve disputes, respond to investigations, conduct due diligence, and comply with legal requirements.
Stay ahead of the curve and in touch with our latest thinking on the issues that are top of mind across our practices and industry sectors.
Change happens fast in today’s turbulent world. Stay on top of the latest with our industry-specific channels.
Take a closer look at how we partner with clients to help them realize their goals.