Preparation for 2025 Fiscal Year-End SEC Filings and 2026 Annual Shareholder Meetings

As public companies prepare for 2026 annual reporting and proxy season, Mintz highlights key developments from 2025 and considerations for year-end SEC filings. While the SEC did not adopt major new disclosure rules in 2025, the year marked a significant shift in regulatory priorities under the new administration. Numerous proposals were withdrawn, and attention turned to emerging financial technology, executive compensation, and principles-based disclosure standards. At the same time, state-level initiatives advanced independently, creating a patchwork of requirements that companies must navigate.

Looking ahead, issuers should anticipate continued policy volatility and uneven compliance obligations across jurisdictions. Diverging state and federal mandates, evolving guidance on AI and data practices, and sector-specific oversight in areas such as life sciences and fintech will heighten disclosure and governance risks. Boards and management teams should ensure that risk factors and MD&A sections are updated to address these developments, including cybersecurity, tariffs, geopolitical uncertainty, and the growing use of AI.

Other areas of focus include proxy advisory policy changes, digital asset regulation, and employment considerations. Life sciences companies face additional complexity as FDA operations adjust to leadership changes and new initiatives. Finally, recent litigation and Delaware corporate law reforms underscore the need for robust governance practices and careful disclosure planning.

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