Quarterly Versus Semi-Annual Reporting

Calls to consider the frequency of corporate reporting have resurfaced, driven by a rulemaking petition from the Long-Term Stock Exchange, the President's social media posts, and remarks by SEC Chair Atkins.

On September 30, 2025, the Long-Term Stock Exchange (the "LTSE") filed a rulemaking petition with the Securities and Exchange Commission (the "SEC" or the "Commission") requesting that the SEC amend Rules 13a-13 and 15d-13 under the Securities Exchange Act of 1934, as amended (the "Exchange Act") as well as the general instructions to Form 10-Q. The proposal would permit public companies to file comprehensive interim reports on a semi-annual basis, rather than quarterly, while maintaining current Form 10-K requirements and Form 8-K reporting for material events. Companies would have the option to report on a quarterly basis.

In its petition, the LTSE argues that the quarterly reporting regime incentivizes companies to focus on short-term results at the expense of long-term strategy and innovation. By allowing companies the option to report on a semi-annual basis, the LTSE believes that public companies will be better positioned to prioritize sustainable growth, reduce unnecessary compliance costs, and align their reporting practices with those in other major markets such as the European Union and the United Kingdom. The LTSE also notes that this change would be optional, preserving flexibility for companies that wish to continue quarterly reporting.

Debate over the frequency of interim reporting for U.S. public companies has resurfaced periodically. In recent years, some policymakers have questioned whether quarterly reporting promotes excessive short-termism. The President suggested that companies should move to six-month reporting cycles. Shortly thereafter, SEC Chair Atkins indicated that the Commission was evaluating whether to propose rule changes that would permit semi-annual reporting. As with any rulemaking, the SEC would need to conduct a formal notice-and-comment process before amending its regulations. Speaking at Georgetown's Financial Markets Quality Conference, Chair Atkins noted that the SEC may seek public feedback on whether a "one-size-fits-all" reporting model remains appropriate, observing that smaller issuers might benefit from reduced compliance costs while others may prefer to continue quarterly disclosures. Read the full petition.

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