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On Aug. 26, 2026, the White House’s Office of Information and Regulatory Affairs (OIRA) updated its regulatory dashboard to reflect that the SEC has submitted a rule proposal titled “Executive Compensation Disclosure Reform.” This development signals that the Commission is poised to consider this rulemaking in the near term and that a formal proposal could be released shortly after completing the OIRA review process.
Why this matters
As a result of a 2025 Executive Order requiring all independent regulatory agencies, including the SEC, to submit rulemaking projects to OIRA before publication in the Federal Register, the appearance of this proposal on the OIRA dashboard is a strong indicator that the SEC is moving forward with executive compensation disclosure reform. The specific contours of the proposal have not yet been made public, but this rulemaking appears to be the next step in the broader reform agenda signaled by SEC Chairman Paul Atkins when the Commission proposed amendments to the filer-status framework earlier this year, which we discussed in a prior alert. In that rulemaking, the Chairman characterized the filer-status proposal as among the first steps toward broader reform, with anticipated future changes potentially including simplification of pay-versus-performance disclosure, revisions to perquisite disclosure (including executive security), and other modifications to Item 402 of Regulation S-K. The submission of a stand-alone proposal to reform executive compensation to OIRA suggests that the Commission is now advancing that agenda. OIRA reviews typically have a 90-day review period, though reviews are frequently completed on a shorter timeline.
Looking ahead
Compensation committees and their advisors should be aware that this rulemaking is on the horizon and may move quickly once OIRA completes its review. When the proposal is published in the Federal Register, there will be a public-comment period, and companies and trade groups that want to help shape the final rule should be prepared to evaluate the proposal and participate in that process.
We will continue to monitor these developments. For questions about how these changes may affect your company’s executive compensation disclosure obligations, please reach out to the Executive Compensation & Employee Benefits or Capital Markets teams at Winston Taylor.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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