March 13, 2023
Pandemic Disclosure: What’s Next?
During the preparation and review of Form 10-K filings this annual reporting season, the question invariably arose as to what still needed to be said about the COVID-19 pandemic. The surprising answer was that, in many cases, the COVID-19 pandemic continues to impact the operations of public companies in a wide variety of ways and therefore disclosure about the pandemic, principally in MD&A and risk factors, continues to be necessary.
While I am certain that we will not be talking about the COVID-19 pandemic forever, it is important to keep providing the disclosure that addresses the trends, risks and uncertainties arising from the pandemic that continue to this day. One thing to keep in mind is that now that we have experienced the COVID-19 pandemic, we have a much greater appreciation for the risks associated with any global pandemic, and that recognition should be reflected in risk factor disclosure going forward, thereby avoiding the “hypothetical” risk factor situation in future filings.
– Dave Lynn