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. Wed, 23 Sep 2026 11:32:16 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.11 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Compensation Clawbacks – Surveying the Disclosures to Date – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Compensation Clawbacks – Surveying the Disclosures to Date https://corpgov.law.harvard.edu/2026/09/22/compensation-clawbacks-surveying-the-disclosures-to-date/?utm_source=rss&utm_medium=rss&utm_campaign=compensation-clawbacks-surveying-the-disclosures-to-date https://corpgov.law.harvard.edu/2026/09/22/compensation-clawbacks-surveying-the-disclosures-to-date/#respond Tue, 22 Sep 2026 11:32:51 +0000 https://corpgov.law.harvard.edu/?p=183800?d=20260921124035EDT Posted by Mark Borges, Hannah Orowitz, and Brigid Rosati, Compensia, on Tuesday, September 22, 2026
Editor's Note:

Mark Borges and Hannah Orowitz are Principals and Brigid Rosati is a Senior Consultant at Compensia. This post is based on their Compensia memorandum.

As we approach the third anniversary of the date when incentive compensation “received” is subject to clawback, we have taken a closer look at the disclosures companies have made since implementation.

This Thoughtful Pay Alert summarizes our findings from reviewing publicly available disclosures of “recovery analyses” conducted between January 1, 2024 and June 30, 2026.

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