The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Thu, 07 May 2026 11:32:12 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Defending the Disclosure Ecosystem: The Essential Role of Shareholder Proposals and Regulation S-K – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Defending the Disclosure Ecosystem: The Essential Role of Shareholder Proposals and Regulation S-K https://corpgov.law.harvard.edu/2026/05/05/defending-the-disclosure-ecosystem-the-essential-role-of-shareholder-proposals-and-regulation-s-k/?utm_source=rss&utm_medium=rss&utm_campaign=defending-the-disclosure-ecosystem-the-essential-role-of-shareholder-proposals-and-regulation-s-k https://corpgov.law.harvard.edu/2026/05/05/defending-the-disclosure-ecosystem-the-essential-role-of-shareholder-proposals-and-regulation-s-k/#respond Tue, 05 May 2026 11:32:08 +0000 https://corpgov.law.harvard.edu/?p=180527?d=20260504162145EDT Posted by Sanford Lewis, Khadija Foda, and Tanya Agarwal, Shareholder Rights Group, on Tuesday, May 5, 2026
Editor's Note:

Sanford Lewis is General Counsel, Khadija Foda is an Associate Counsel, and Tanya Agarwal is a Research Associate at the Shareholder Rights Group. This post is based on an SEC comment letter submitted by the Shareholder Rights Group.

The SEC Division of Corporation Finance is conducting a comprehensive review of Regulation S-K, and Chairman Paul Atkins has indicated that the current disclosure regime elicits significant volumes of immaterial information. As such, it appears the agency will seriously consider revisions to reduce disclosure requirements.

However, paring back Regulation S-K disclosures would harm a critically valuable disclosure ecosystem that provides investors with information on emerging risks and helps investors assess their portfolio companies and engage in stewardship in alignment with their fiduciary duties. Shareholder proposals and Regulation S-K disclosures work together in this ecosystem of disclosures. Shareholder engagement often leads to voluntary reporting, which, in turn, informs and ultimately expands Regulation S-K disclosures.

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