Statement by Commissioner Peirce on Proposed Rescission of Climate-Related Disclosure Rules

Hester M. Peirce is a Commissioner at the U.S. Securities and Exchange Commission. This post is based on her recent statement. The views expressed in this post are those of Commissioner Peirce and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

The Commission has struggled with the climate disclosure proposal for years. Today we are proposing to rescind the rule that the Commission adopted in 2024. I support the rescission proposal and look forward to hearing feedback from the public.

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Statement by Chair Atkins on Proposing Release for Rescission of Climate-Related Disclosure Rules

Paul S. Atkins is the Chairman of the U.S. Securities and Exchange Commission. This post is based on his recent statement. The views expressed in the post are those of Chairman Atkins and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Today, the Commission proposed to rescind[1] in their entirety the rules on The Enhancement and Standardization of Climate-Related Disclosures for Investors, which the Commission adopted on March 6, 2024 (the “2024 Climate Rules”).[2]

The 2024 Climate Rules generated national controversy since they were first proposed.  Some commenters supported the proposal, but many commenters argued that the 2024 Climate Rules, as proposed, were outside the scope of the Commission’s authority and were flawed for policy reasons.

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From Scorched Earth to Mars: Corporate Governance Goes Rogue in 2026

Michael Garland is Assistant Comptroller for Corporate Governance and Responsible Investment in the Office of New York City Comptroller Mark Levine.

Something fundamental shifted during the 2026 proxy season. Reacting to the SEC’s “hands-off” approach, boards deployed increasingly aggressive procedural strategies to evade accountability. That several of the New York City Pension Funds had to sue AT&T simply to secure a vote on a shareholder proposal illustrates how far the process has shifted.

The SEC’s retreat from the traditional no-action process stands at the heart of this storm—inequitably favoring management and impairing shareholders’ ability to advance shareholder proposals. Indeed, while shareholders have thus far been forced to litigate just to have their proposals voted on, the SEC staff granted Exxon Mobil Corporation (“Exxon”) no-action relief on its unprecedented (and potentially industry-defining) retail voting program with seemingly minimal scrutiny. As the public record shows, Exxon’s retail voting program, which is now facing legal challenges in federal court, received no-action relief from the SEC on the very day it was requested.[1]

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Weekly Roundup: May 22-28, 2026


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This roundup contains a collection of the posts published on the Forum during the week of May 22-28, 2026

2026 Policy Updates from Key Investors


District Courts Weigh in on Shareholder Proposal Exclusions


What Corporate Boards Need to Know and Do About Anthropic’s Mythos and Project Glasswing



Chancery Rules Stockholder, through its Board Designee, May Have Conspired with Company Fiduciaries to Commit Fraud




The Impact of SEC Punting



The SEC’s Proposal on Semiannual Reporting is Easier Said than Done


Corporate National Identity: Contestation and Reconfiguration in an Age of Weaponized Interdependence



Remarks by Chair Atkins on Revitalizing Public Markets Through Regulatory Simplification and Capital Formation

Paul S. Atkins is the Chairman of the U.S. Securities and Exchange Commission. This post is based on his recent remarks. The views expressed in the post are those of Chairman Atkins and do not necessarily reflect those of the Securities and Exchange Commission or its staff.

Good afternoon, ladies and gentlemen. It is a pleasure to join you here today. And thank you, Bobby [Bartlett], for your generous introduction. Of course, I should also like to extend my thanks to the Stanford Rock Center for Corporate Governance for the opportunity to discuss our ongoing work at the SEC—work that I know touches the professional lives of many in this room.

To the business leaders and market participants who have joined us, thank you. I am grateful for your presence, and I trust that the reflections that I intend to share today will prove both insightful and meaningful to your work. READ MORE »

Corporate National Identity: Contestation and Reconfiguration in an Age of Weaponized Interdependence

Curtis J. Milhaupt is the William F. Baxter – Visa International Professor of Law at Stanford Law School, Mariana Pargendler is the Beneficial Professor of Law at Harvard Law School, and Dan W. Puchniak is the Yung Pung How Professor of Law at the Yong Pung How School of Law, Singapore Management University. This post is based on their recent paper.

What makes a corporation American, Italian, Chinese, or any other nationality – and who gets to decide?

In a new paper, we examine how the national identity of corporations is increasingly contested in the contemporary global economy. Corporate national identity (CNI) can no longer be understood as a fixed legal attribute determined solely by jurisdiction of incorporation, location of administrative headquarters, or corporate control through equity ownership. Rather, CNI emerges from the interaction of four interrelated facets – legal, economic, (geo)political, and symbolic – whose relative salience varies across contexts and over time. The central implication is that corporate nationality is not a unitary status, but a contingent and contested construct.

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The SEC’s Proposal on Semiannual Reporting is Easier Said than Done

Julie Laskin is Senior Vice President and Felipe Ucrós is a Partner at Gladstone Place Partners. This post is based on their Gladstone Place memorandum.

The SEC wants to “make IPOs great again,” and it believes that one path to doing so is easing reporting requirements for publicly listed companies. Last week, the SEC made official its much-anticipated proposal to permit public companies to report earnings semiannually. If adopted, companies will effectively have the option to trade three Form 10-Qs for a single semiannual Form 10-S.

For companies, this isn’t only about filing fewer earnings reports. It’s also about the impact on the proactive investor relations strategy, and what happens between filings: managing market expectations and establishing equity story narratives, maintaining analyst credibility and sustaining investor engagement, handling material nonpublic information (MNPI), and navigating insider trading windows.

The proposal, if approved, could create more volatility in an issuer’s share price, force investors to find alternative sources of information, and may not be the panacea some policymakers and corporate chieftains hope.

We game out three likely paths and their implications below.

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Companies Disclose Executive Pay Impacts of Trump Tariffs

Joyce Chen is an Associate Editor at Equilar, Inc. This post is based on an Equilar memorandum by Ms. Chen and Andrew Gordon.

Tariffs imposed by the Trump administration in 2025 introduced a new layer of uncertainty for U.S. companies already navigating a fragile macroeconomic environment. The measures apply to imports from most global trading partners across a wide range of tariff rates, shifting constantly in response to negotiations, policy changes and foreign retaliation. During the 2026 proxy season, this uncertainty influenced how companies evaluated executive compensation programs, with many organizations addressing tariff-related impacts in their proxy statements, particularly when determining performance goals and pay outcomes.

This Equilar analysis examines U.S. public companies that disclosed tariff-related impacts during the 2026 proxy season.

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The Impact of SEC Punting

Anna Toniolo is a Fellow at the Harvard Law School Program on Corporate Governance and an S.J.D. candidate at Harvard Law School. This post is based on her recent paper.

For decades, the Securities and Exchange Commission (“SEC”) acted as the de facto arbiter of Rule 14a-8 of the Securities Exchange Act of 1934, the federal securities rule governing shareholder proposals. The rule gives shareholders a procedure for proposing ballot items for corporate elections and outlines specific procedural and substantive grounds on which management can lawfully exclude a proposal. The SEC used to referee this process by allowing companies to apply for “no-action” letters that effectively blessed their decisions to exclude proposals from their ballots. But in November 2025, the Commission announced that it would no longer issue such letters, leaving companies to interpret the rules for themselves.

My new paper, The Impact of SEC Punting, compares proposal activity at S&P 1500 companies during the 2025 and 2026 proxy seasons to analyze how companies and shareholders have responded to the SEC’s decision to stop refereeing shareholder proposal disputes.

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How Investors Are Adapting to the SEC’s Deregulatory Agenda, and What to Do About It

Ferrell Keel, Joel May, and Kim Pustulka are Partners at Jones Day. This post is based on a Jones Day memorandum by Ms. Keel, Mr. May, Ms. Pustulka, David Peavler, and Randi Lesnick.

In Short

The Situation: The SEC, under Chairman Paul Atkins, is pursuing a sweeping deregulatory agenda aimed at simplifying public company disclosure obligations, promoting capital formation, scaling requirements to company size, and refocusing the regulatory framework on financial materiality and investor protection. Several rulemaking initiatives—including the proposed rules to permit semiannual reporting—are underway, and other wholesale reforms, including revisions to the broader Regulation S-K disclosure architecture, have been announced.

The Result: As the SEC advances rule proposals and signals further amendments to come, institutional and activist investors are deploying an expanding toolkit of alternative pressure mechanisms—from board-level accountability campaigns and shareholder litigation and proposals to strategies that bypass traditional regulatory channels—to preserve the transparency and engagement frameworks they view as essential.

Looking Ahead: Investor engagement may become even more critical in an environment that reduces required disclosures to shareholders. Boards and management teams must anticipate the evolving investor response and build proactive strategies that balance regulatory relief with transparency and shareholder expectations. READ MORE »

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