SEC Semi-Annual Reporting Proposal Tracker (S7-2026-15)

In May 2026 the SEC issued a proposal that would allow public companies to switch from quarterly (Form 10-Q) to semi-annual financial reporting (a new Form 10-S). From the date of publication, the public has 60 days to comment on the proposal.

This site was produced by Professor Tzachi Zach at The Ohio State University Fisher College of Business as a public service to track the comment letters as they arrive, classify their positions, and surface patterns in the docket. A number of methodological decisions had to be made along the way — how to classify stance, how to bucket commenters by entity type, how to handle hedged or conditional letters — those decisions are explained below.

Beyond the tracker itself, the project has two other goals. First, I hope it will encourage discussion among accounting academics about the proposal. The economic-analysis questions the proposal raises (short-termism, fraud risk, compliance burden, retail-investor protection) are central to what we study, and the comment period is a good moment to bring our expertise to bear. Second, it is quite interesting to test how well language-model classifiers handle regulatory text. With a few hundred letters and fast iteration, can we converge on classifier design choices that scale to future research? The site will be most relevant to accounting academics, auditors, preparers, financial analysts, IR professionals, and anyone who follows the SEC docket professionally.

This is not the first time the SEC has revisited reporting frequency. In 2018 the Commission issued a request for comment on the same question — earnings releases and the frequency of quarterly reporting (Release 33-10588, File No. S7-26-18). That one solicited public input without proposing a specific rule, unlike the current formal proposal. I built a companion tracker of the 2018 comment letters, available here.

The semi-annual proposal was not the SEC's only rulemaking that month. Two weeks later, on May 19, the Commission issued a companion Filer Status proposal (File No. S7-2026-18) easing the rules for smaller and newly public companies — raising the threshold for the largest filer category, opening a longer reporting on-ramp for recent IPOs, and, at its center, dropping the requirement that these companies have an outside auditor attest to their internal controls. I track that docket too, on a companion filer-status tracker built the same way — except that a filer-status letter gets a stance on each of the eleven proposal elements it touches, since a commenter can back the longer IPO on-ramp while fighting the audit-attestation rollback in the same paragraph.

The two dockets could not look less alike. This one drew a flood of letters that point almost all the same way; the filer-status docket has drawn only dozens, and those do not agree. That relative silence is itself worth noting — the filer-status changes are arguably no less consequential, yet they have drawn a small fraction of the attention, which raises a question the extension requests on this docket quietly echo: did the crowded May 2026 proposal schedule leave the public too little room to engage with each one?

Comments, suggestions, or corrections welcome — send feedback here or email zach.7@osu.edu.