INSIGHT

SEC Proposes to Give Public Companies the Option of Semiannual Reporting

Will Tanem, Martina Gadgeff • July 17, 2026

Services: SEC Reporting

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Public companies have been filing quarterly reports since the SEC adopted the current Form 10-Q framework in 1970. The SEC is now proposing to make that a choice rather than a requirement.

On May 5, 2026, the Securities and Exchange Commission (SEC) proposed rule and form amendments that would allow domestic reporting companies that currently file Form 10-Q, as well as certain IPO registrants, to elect semiannual reporting to meet their interim SEC reporting obligations under federal securities laws.

It’s a meaningful shift in how the Commission is thinking about the relationship between regulatory structure, transparency and business flexibility, and it’s worth understanding what is being proposed by the SEC.

What the SEC Is Proposing

Currently, public companies subject to Exchange Act Section 13(a) or 15(d) are generally required to file quarterly reports on Form 10-Q. Under the proposed amendments, those companies could elect to file semiannual reports on a new form, Form 10-S, instead. The practical effect: companies that choose semiannual reporting would file one semiannual report and one annual report per fiscal year, rather than three quarterly reports and one annual report.

This is an opt-in proposal. Companies would choose the interim reporting frequency that best serves their business and their investors. Nothing in the proposal would require any company to change its current reporting cadence; however, once a company opts in, it cannot change its election. Under the proposal, the filing deadline for Form 10-S would be 40 or 45 days after the end of the first semiannual period of the fiscal year, depending on the company’s filer status. The proposal would also amend Regulation S-X, which governs financial statement requirements for periodic reports, registration statements, and proxy statements, to reflect the new semiannual option and simplify existing financial statement requirements.

What This Could Mean for Your Company

Quarterly reporting would remain available. This proposal doesn’t eliminate Form 10-Q or require any company to change how it currently reports. Companies that prefer the quarterly cadence, or whose investors expect it, can continue filing as they always have. The election could meaningfully change how your finance and accounting teams allocate their time. Quarterly filings carry significant preparation demands. For eligible companies, moving to a semiannual schedule could free up internal resources that are currently consumed by the quarterly reporting cycle. However, companies could still voluntarily provide quarterly updates, including through earnings releases furnished on Form 8-K.

“The quarterly reporting cycle is a resource-intensive obligation that public companies carry,”  says Will Tanem, Partner and Technical Accounting Practice Leader at BPM. “The ability to elect semiannual reporting, if adopted, gives companies and their investors more say in what a sustainable and informative reporting rhythm looks like for their specific situation. The proposal appears aimed, in part, at reducing the cost and burden of being public, which could encourage more companies to enter or remain in the public markets.”

Regulation S-X changes are part of the package. The proposal includes amendments to simplify existing financial statement requirements alongside the new semiannual option. For companies building an IPO timeline, this could be a meaningful change because current staleness rules generally require updated interim financial statements once the existing 130- or 135-day thresholds are reached.

Under the proposal, interim financial statement requirements would instead be tied to the timing of the issuer’s next required Form 10-Q or Form 10-S filing, aligning registration statement updating requirements with periodic reporting deadlines rather than a separate day-count test. For IPO registrants, the proposed election made in the registration statement would determine whether the registration statement follows the quarterly or semiannual interim financial statement framework. For companies electing semiannual reporting, this could allow registration statements to remain current longer before an interim update is required.

What’s Still Uncertain

Like the SEC IPO rules 2026 released later in May, this remains a proposal rather than a final rule. The public comment period closed on July 6, 2026, and the SEC is now reviewing feedback before determining whether and how to proceed. One notable development is the level of public response the proposal generated. Comment letters submitted during the comment period reflect a wide range of perspectives, with many investors, finance professionals, and market participants expressing concerns that a move to semiannual reporting could reduce transparency and limit the availability of information relied upon by investors.

Public reporting on the comment process has indicated that opposition significantly outweighed support, although the SEC has not yet announced what impact, if any, the feedback will have on its ultimate decision. The reaction highlights one of the central policy debates behind the proposal. Supporters view semiannual reporting as a way to reduce compliance costs, ease administrative burden, and potentially encourage more companies to enter or remain in the public markets. Opponents argue that quarterly reporting remains an important component of investor protection and market transparency. The SEC will ultimately need to balance those competing considerations as it evaluates the comments received.

“Proposals like this one signal where the regulatory environment is heading, even before rules are finalized,” Tanem notes. “Whether or not this proposal is ultimately adopted in its current form, companies should pay attention to the broader themes behind it, including continued efforts to reduce reporting burdens and encourage capital formation. The time to evaluate what these types of changes could mean for your reporting infrastructure, investor communications, and IPO planning is before the rules are finalized, not after.”

How BPM Can Help

BPM’s SEC reporting services help public and pre-IPO companies navigate SEC reporting requirements, financial statement preparation, and the operational demands of being, or becoming, a public company. As the SEC’s regulatory framework continues to evolve, BPM’s SEC reporting services we can help you assess how proposed changes apply to your specific situation and what steps make sense to take now.

Ready to talk through what the proposed semiannual reporting option could mean for your company? Contact BPM’s Technical Accounting and IPO Readiness teams to start the conversation.