If the SEC lets you stop filing every quarter, will you? That’s the debate many IR teams are having.
In May 2026, the SEC proposed letting companies swap three quarterly 10-Qs for one semiannual report on a new Form 10-S. Companies would make the choice each year by checking a box on their Form 10-K. It sounds like a small administrative tweak. It could reshape how investors hear from you.
With 2027 planning underway, it's a good time to consider what a change like this could mean for your IR strategy.
The comment period closed on July 6, and the volume was striking. Skadden reports more than 200,000 letters, the most ever on an SEC proposal. Skadden reports more than 200,000 letters, the most ever on an SEC proposal. Retail investors wrote the bulk of them. SIFMA, the Investment Company Institute, NASAA and the CFA Institute opposed the change.
Support came from the Business Roundtable and about ten pharma and energy companies. One mega-cap pharmaceutical company said it would elect semiannual reporting if the rule is adopted, and eight other pharma companies jointly voiced support. A mega-cap energy company backed the proposal too. Most companies haven’t said what they would do.
The SEC hasn't announced a timetable. Staff are reviewing comments and a final rule needs a commission vote. Skadden expects the agency to move forward in some form, and calendar-year companies could start as early as fiscal 2027. So the rule might change before it lands. The planning still belongs on your desk today.
Here's the part that won’t change. A semiannual filing doesn't mean investors stop wanting a quarterly view of your business. They'll still look for it, and they'll look to you.
That puts your earnings release and your guidance in a different spot. Today they sit alongside a 10-Q that anchors the numbers. If the 10-Q goes away for two of the four quarters, those voluntary disclosures become the main event. Analysts will build their models from what you choose to say.
That raises the bar on completeness. A voluntary update that highlights the good news and skips the rest will get noticed. Companies need to make sure interim releases are complete and balanced.
Think about how an analyst works when a quarter has no filing behind it. The next best source is your own words. Your outlook and the assumptions behind it carry far more weight than they do now.
Guidance can feel like a chore, but it's also the clearest way to show you're being straight with the market. Strong guidance gives people a reason to trust the months between reports. Thin guidance invites speculation, and speculation moves share prices.
Here are two practical questions to work through now.
If you can't answer those two cleanly, that's your starting point.
Longer stretches between formal filings also stretch the time when you hold information that others don't.
Consider a simple scenario. Your CFO is on a conference panel in month five and gets a sharp question about demand. Under a quarterly rhythm, you have a recent filing to point to. Under a semiannual rhythm, the last formal data point could be months old. The pull to say a little more than you should gets stronger.
IR teams will need tighter talking points and a faster path to publish material updates broadly.
Two outside forces will also influence the decision. The first is activists. If you drop to two reports a year, an activist can argue that investors lack the interim data they need and push for more metrics. A company that elects semiannual reporting could find itself defending the choice in a proxy fight.
The second is your peer group. If the companies you're compared against keep reporting every quarter, going semiannual could leave you harder to compare. Investors who run screens across a sector tend to favor the names with the freshest data.
None of these mean semiannual reporting is a bad idea for every company. The case for it is real, especially for businesses whose results swing little from one quarter to the next. It simply means the choice carries trade-offs that IR should help the board see clearly.
The SEC hasn’t set a timetable, so you have time to prepare. The work is useful whichever way the rule lands, and IR has a lot to contribute to the board’s thinking.
Start with what you already know. Your call transcripts, meeting notes and CRM logs show which quarterly details investors ask about most. Analyst notes and models show which line items they track and which numbers they quote back to you. The pages and filings that draw the most traffic on your IR site point the same way. Put together, that picture shows how much a change in reporting rhythm could affect your coverage and your cost of capital.
Next, it can help to review what you share today. Look at what your earnings release and call already include, and see where investors tend to lean on the 10-Q for detail. Those spots show where you might want to add more voluntarily if the filing schedule ever changed.
You might also sketch your approach to interim updates. Consider which metrics you’d share between formal reports and who would review each message. A plan built ahead of time tends to hold up better than one written in a hurry.
Finally, it often helps to keep your board in the loop early. A shared framework gives directors a way to weigh the savings in time and cost against the signals investors may read into any change.
The real shift is in how you communicate
Whatever the SEC decides, this debate raises a question every IR team should ask regularly. How much of investor trust rests on a filing, and how much rests on how you talk to the market in between?
Teams that invest in clear guidance and a reliable disclosure rhythm will be ready for any outcome. Their guidance becomes a source investors trust, because they built it well before anyone leaned on it.
Stay tuned to our IR resources blog for more industry news and insights.