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ARTICLE · 02 JANUARY 2026

Investor Advisory Committee Recommends SEC Disclosure Guidelines For Artificial Intelligence

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On December 4, 2025, an advisory committee of the U.S. Securities and Exchange Commission (SEC or Commission) voted to advance a recommendation that the agency issue guidance requiring issuers to disclose information about the impact of artificial intelligence (AI) on their companies.

United StatesTechnology
Justin Weiss
Justin Weiss
Matthew F. Ferraro
Matthew F. Ferraro
William J. Bruno
William J. Bruno
Carlton Greene
Carlton Greene
Caitlyn Weeks
Caitlyn Weeks

On December 4, 2025, an advisory committee of the U.S. Securities and Exchange Commission (SEC or Commission) voted to advance a recommendation that the agency issue guidance requiring issuers to disclose information about the impact of artificial intelligence (AI) on their companies.

In its recommendation, the Investor Advisory Committee (IAC) cited a "lack of consistency" in contemporary AI disclosures, which "can be problematic for investors seeking clear and comparable information," and called for a rule that would require issuers to define AI, disclose board oversight mechanisms, and report on material AI deployments internally and for consumer-facing deployments.

The IAC recommendations are neither formal guidance nor a rule, and the SEC—which earlier this year withdrew Biden-era proposed rules related to AI (including on conflicts of interest in predictive data analytics)—has responded tepidly. But, as firms of all types rush to develop and deploy AI

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