On May 19, 2026, the SEC proposed amendments (Release No. 33-11419) that would significantly revise the public company filer status framework and related disclosure obligations. While the proposal is not limited to executive compensation, one of its most notable effects would be to expand the availability of scaled disclosure requirements that could substantially reduce disclosure of executive and director compensation for many U.S. public companies. If adopted as proposed, the amendments could become effective as early as the 2027 proxy season.
Proposed changes to the filer status framework
The proposed amendments would consolidate the SEC’s current five overlapping filer status categories into two principal categories, large accelerated filers (LAFs) and non-accelerated filers (NAFs), eliminating the accelerated filer and smaller reporting company (SRC) categories entirely. LAF status would be limited to companies with a public float of at least USD2B, measured using the average
