SEC Issues Extension For Compliance With Section 16(a)

As discussed in our Dec. 23, 2025, GT Alert and our March 9, 2026, GT Alert, Congress enacted the Holding Foreign Insiders Accountable Act (HFIAA), which extended Section 16(a) beneficial ownership reporting obligations under the Securities Exchange Act of 1934, as amended (Exchange Act) to directors and officers of foreign private issuers (FPIs), effective March 18, 2026.

The U.S. Securities and Exchange Commission (SEC) recognized that processing delays associated with the unusually large number of Form ID applications being submitted due to the HFIAA may contribute to FPIs failing to meet the March 18, 2026, deadline to comply with such Section 16(a) reporting requirements. Accordingly, the staff of the SEC's Division of Corporate Finance (staff) released the below two FAQs on March 12, 2026, providing clarity and relief subject to certain conditions.