NCACPA has formed a task force to evaluate the U.S. Securities and Exchange Commission’s proposal, implementing optional semiannual reporting framework for public companies and develop the association’s formal comment letter to the SEC.
The proposal would allow public companies to elect semiannual reporting instead of filing Form 10-Q reports each quarter. Quarterly reporting would remain the default, but companies choosing the new framework would file a new Form 10-S covering the first six months of the fiscal year. Form 10-S would generally require the same narrative disclosures and financial information currently included in Form 10-Q, but for a six-month period rather than a fiscal quarter. The financial statements would be reviewed by an auditor and tagged using Inline XBRL.
On May 27, NCACPA hosted an Advocacy Roundtable to gather practical feedback from professionals involved in SEC reporting, assurance, public-company finance, and capital markets. The discussion made clear that this proposal is not simply about filing frequency. It could affect how public companies communicate with investors, how audit committees oversee interim disclosure, how auditors review interim financial information, how underwriters evaluate securities offerings, and how investors compare companies across sectors.
One of the clearest takeaways from the roundtable was that the semiannual reporting proposal should not be evaluated in isolation. Participants discussed the proposal in connection with related SEC initiatives involving filer-status simplification, emerging growth company accommodations, shelf-offering reform, and broader efforts to reduce the cost of being public. Taken together, these proposals could reshape the public-company reporting environment.
The roundtable also highlighted the choices companies could face if the rule is finalized. Some companies may keep the current approach, and continue filing quarterly Form 10-Q reports. Others may elect semiannual reporting and provide only required Form 8-K disclosures between Form 10-S and Form 10-K. Many may consider hybrid approaches, such as filing Form 10-S while continuing quarterly earnings releases- providing summarized financial information, full interim financial statements, or operational metrics on Form 8-K.
Those choices involve trade-offs. A company may gain flexibility by moving away from quarterly Form 10-Q reporting, but investors, lenders, underwriters, and analysts may still expect timely interim information. A company may continue quarterly earnings releases, but furnished earnings information is not the same as a filed Form 10-Q. Participants raised questions about disclosure completeness, liability, Regulation FD, trading windows, insider-trading risk, and the potential for material nonpublic information could remain inside the company for longer periods.
The assurance implications are also notable. Form 10-S would require auditor review, but if companies stop preparing reviewed quarterly interim financial statements, that could affect comfort letters and capital markets transactions. Participants noted that coordination with the PCAOB may be necessary to determine whether current assurance and negative-assurance frameworks remain workable under a semiannual reporting model.
The roundtable also addressed the SEC’s related filer-status proposal, which could move the large accelerated filer threshold from $700 million to $2 billion and remove auditor attestation over internal control over financial reporting for a larger population of companies. This proposal adds another layer to the broader policy discussion about burden reduction, investor protection, and market confidence.
NCACPA’s role is to ensure the SEC hears considered feedback from the accounting profession. The association’s comment letter should reflect the practical implications of changing how public-company information is prepared, reviewed, communicated, and used.
Members with experience in public-company reporting, assurance, corporate finance, banking, investor relations, academia, governance, or capital markets are encouraged to share their questions, concerns, and recommendations with NCACPA’s task force.
Share your feedback with the task force here.
If you have questions about this topic or other policy matters, please contact NCACPA Coordinator of Advocacy & Outreach Will Edmondson.