What to Expect in 2026: Anticipated Changes to Executive Compensation Disclosure After the SEC Chairman’s NYSE Speech

For the first time in nearly two decades, the SEC is preparing to modernize Item 402 of Regulation S-K, the backbone of public-company executive compensation disclosure. Although the timing remains uncertain, we expect proposed reforms to emerge in 2026, setting the stage for the most significant shift in pay disclosure since 2006.

Recent public remarks—including Chairman Paul Atkins’s December 2025 address at the New York Stock Exchange[1]—indicate a strong shift toward re-centering the SEC’s executive compensation disclosure regime on financial materiality, scalable requirements for smaller and newly public issuers, and avoidance of what Chairman Atkins described as an “avalanche of trivial information.”[2] These remarks reinforce that any modernization of Item 402 is likely to emphasize clarity, decision-useful disclosures, and proportional compliance burdens. READ MORE