Blogs

“Four 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 four 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 November 2023 report (following disclosure year #3) and prior years, the content and scope of which are then described in much greater detail throughout the report:

Among the noteworthy takeaways:

• Most companies reduced the length of their disclosure year-over-year.
• While a plurality of companies (46%) covered the same number of topics in their disclosures in 2023 and 2024, nearly as many (41%) reduced the number of topics addressed in 2024.

• The most commonly addressed topics remained generally consistent with the preceding two years, with Talent Development, Diversity and Inclusion, Talent Attraction and Retention, Employee Compensation and Benefits, and Monitoring Culture, remaining the five most prevalent disclosure topics.

The report also discusses industry-specific disclosure trends and big picture disclosure format observations, and suggests a sound list of considerations for companies in preparing their upcoming Form 10-K disclosures.