“Five Years of Evolving Form 10-K Human Capital Disclosures” from Gibson Dunn presents the results of the firm’s analysis of human capital disclosures among S&P 100 companies based on five annual Form 10-K filings since the effective date of the SEC’s Regulation S-K requirements adopted in 2020. The report reveals the number of such companies that include disclosure across 28 topics as compared to the firm’s December 2024 report (following disclosure year #4) and prior years, the content and scope of which are then described in much greater detail throughout the report:
Among the noteworthy takeaways:
- The vast majority of companies (85%) reduced the length of their disclosure year-over-year.
- The most commonly addressed topics remained generally consistent with the preceding three years, with Talent Development, Talent Attraction and Retention, Employee Compensation and Benefits, Diversity and Inclusion, and Monitoring Culture, remaining the five most prevalent disclosure topics.
- Nearly three-quarters of companies (72%) reduced the number of topics covered in their disclosures from 2024 to 2025, with the most significant year-over-year decreases observed in diversity-related disclosures (including pay equity and quantitative pay gap disclosures).
The following depicts the changes in the most prevalent disclosures over the five-year period:
Changes in traditional diversity disclosure categories (excluding diversity-related categories such as pay equity and quantitative pay gap) are shown here:
The report also discusses industry-specific disclosure trends and big picture disclosure format observations, and suggests sound considerations for companies in preparing their upcoming Form 10-K disclosures.