Donald Kalfen
SEC Commissioner Hester Peirce has signaled that the Commission is unlikely to issue revised executive pay disclosure rules in time for the 2026 proxy season.
According to Commissioner Peirce, the SEC has not yet begun substantive analysis of the current disclosure framework or the cost benefit of potential reforms.
Unless there is an unexpected shift, public companies should plan to prepare their 2026 proxy statements under the current disclosure requirements.
On September 18, 2025, in informal remarks before attendees at the Corporate Board Member Summit and Roundtable, SEC Commissioner Hester Peirce indicated that the Commission has yet to begin work on potential revisions to the executive compensation disclosure rules, including the cost implications of any disclosure reforms. Commissioner Peirce told attendees that they “should all adjust … expectations since nothing will be released any time soon.”
Given Commissioner Peirce’s remarks and the SEC’s current pace, companies should assume that no new pay disclosure rules will apply for the 2026 proxy season. Boards and management teams are advised to proceed with proxy preparation based on the existing regulatory framework.
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The Client Alert is prepared by Meridian Compensation Partners’ Governance and Regulatory Team led by Donald Kalfen. Questions regarding this Client Update or executive compensation technical issues may be directed to Donald Kalfen at 847-347-2524 or dkalfen@meridiancp.com.
This report is a publication of Meridian Compensation Partners, LLC, which provides general information for reference purposes only, and should not be construed as legal or accounting advice or a legal or accounting opinion on any specific facts or circumstances. The information provided herein should be reviewed with appropriate advisors concerning your own situation and issues.