“Your 2024 Form 10-K roadmap” from Davis Polk identifies recently adopted SEC rules that impact the Form 10-K with reference to prior firm memos for additional detail and highlights numerous disclosure topics of heightened scrutiny, including AI, commercial real estate, non-GAAP measures, and geopolitical-related exposures. Companies are also reminded to actively review and refresh their forward-looking statements, MD&A, and risk factors.
Debevoise & Plimpton’s “Key Considerations for the 2024 Annual Reporting Season” provides an overview of recent SEC rule changes that impact the Form 10-K and disclosure “hot topics” (including AI, non-GAAP, board diversity, climate, and geopolitical conflict disclosures) that will likely impact risk factor disclosures and/or other sections of the Form 10-K for most companies. The Annex addresses these topics in a checklist format that includes links to additional relevant resources.
Sullivan & Cromwell’s "Key Considerations for Upcoming 2024 Form 10-K and 20-F Filings" highlights SEC rulemaking and enforcement developments companies should consider relative to forthcoming Form 10-K / Form 20-F disclosures. The Appendix includes a tabular summary of the timing and scope of applicability of the recently adopted rule amendments requiring insider trading policy and equity award disclosures.
Wilson Sonsini’s “Preparing for the 2025 Reporting Season: Form 10-K Reminders” summarizes new disclosure requirements for Form 10-Ks; provides guidance on other key disclosures and filing-related requirements; and suggests potential D&O questionnaire updates.