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As we shift into back-to-school mode and the summer winds to a close, I anticipate more discussion of what we can expect next from the SEC as it pursues its regulatory agenda focused on public companies and capital raising. At the risk of undoubtedly being wrong in my prognostications, here is what I am anticipating over the next few months.

As we approach the final stages in anticipation of the mid-term elections in November, there will no doubt be an effort to demonstrate progress across the regulatory spectrum, and the SEC will certainly be a part of that. To that end, we could expect to see the SEC move to adoption of the semiannual reporting, filer status and registered offering reform proposals. Moving these proposals to final rule amendments in such a short period of time is a monumental task, but it appears that the Staff has dedicated significant resources to these projects to move them forward quickly. It is difficult to predict exactly when these proposals will be adopted and what sort of transition periods may be contemplated, but it is conceivable that some or all of these rule changes will be in effect going into calendar-year 2027.

The Spring 2026 Reg Flex Agenda also contemplates a slew of proposals by October of this year, which would likely include the executive compensation disclosure rulemaking that the SEC signaled could be coming back in June 2025. Based on everything that the Staff and Commissioners have said and the comments received to date, this proposal could involve a significant paring back of the executive compensation disclosure requirements. Given the timing here, we are not likely to see the relief in time for the 2027 proxy season.

Also slated for October is the “Rationalization of Disclosure Practices” rulemaking, which I read to be the Regulation S-K project. I tend to think that proposing amendments to Regulation S-K in October is a very ambitious goal given the scope of this project, but I know that the Staff is working very hard on this effort, so it is certainly possible. As with the executive compensation disclosure project, a proposal in the Fall of this year means that we likely would not see actual changes on the disclosure requirements until the middle of 2027 at the earliest.

Finally, perhaps the most mysterious of the SEC proposals slated for this Fall are the “Shareholder Proposal Modernization” and “Amendments to Certain Proxy Rules” proposals listed in the Spring Reg Flex Agenda. I do not think that it is too dramatic to say that the fate of Rule 14a-8 hangs in the balance with the shareholder proposal rulemaking, and we still do not have a clear picture of whether the SEC will go in the direction of amendments to Rule 14a-8 or a repeal of the rule. We can also expect proxy rule changes targeting proxy advisory firms, based on the Executive Order issued at the end of last year. Given that we are now on the eve of potential proposals, we will not see changes taking effect before the 2027 proxy season.

For the latest discussion of all of these events as they are happening, go back to school and sign up for our 2026 Proxy Disclosure Conference and 23rd Annual Executive Compensation Conference. These Conferences are taking place in Orlando on October 12-13 and via live webcast.

– Dave Lynn