Will the SEC's optional semiannual reporting save companies money?

On May 5, 2026, the Securities and Exchange Commission proposed amendments that would let public companies file a semiannual report on a new Form 10-S in place of quarterly reports on Form 10-Q.³ The proposal appeared in the Federal Register on May 7, 2026, with comments due July 6, 2026.² The SEC's case is that a company electing the new form would prepare interim reports once a year instead of three times, and so "may see a reduction in compliance costs of time and money."¹ Chairman Paul S. Atkins presented the proposal as part of what he called a "Make IPOs Great Again agenda."⁷

The savings are a projection, and the SEC's own sentence is conditional. Commenters reading the release put the gain at about $198,000 a year for each company that switches.⁹ They say the aggregate figure assumes that 20% of eligible filers would make the switch.¹⁰ The chairman also says the proposal leaves earnings releases and calls to each company. Skadden reads that to mean much of the quarterly work could remain.⁷ No public document examined here measures what a switching company would actually save.

What would a semiannual filer still file?

The baseline is three reports a year. Form 10-Q is due after each of the first three fiscal quarters, and no report is filed for the fourth.⁸ The form carries an OMB-estimated average burden of 135.13 hours per response.⁸ That figure is a government average. It is not a company's cost.

Form 10-S would replace those three filings with one report. The semiannual financial statements would follow U.S. generally accepted accounting principles and would be reviewed by an auditor, but not audited.⁶ The proposing release carries over the content of Form 10-Q, applies a six-month auditor review and keeps the same 40- or 45-day filing deadline.¹ The form changes how often a company files. It does not lighten what each filing contains.

What does the SEC say it saves?

The release says electing companies "may see a reduction in compliance costs," because they would incur interim reporting costs "only one time in connection with each fiscal year instead of three times."¹ That sentence describes a possibility. It does not report a measured result.

The dollar estimates sit in the release's Economic Analysis section. That section was not examined directly for this piece, so the figures below are commenters' descriptions of it. Ron Alquist and Craig Lewis describe the SEC's analysis as projecting about $394 million in aggregate annual monetized benefits against about $159 million in costs. They put the ten-year present value of net benefits at roughly $1.7 billion to $2.0 billion.¹⁰ An opposing comment letter filed July 6, 2026 says the SEC justifies the change "based on projected savings of approximately $198,000 annually for companies that switch."⁹

The same letter describes the inputs as about $110,000 per Form 10-Q and a Form 10-S costing 20% more.⁹ Three avoided 10-Qs at $110,000 come to $330,000. One 10-S at 1.2 times $110,000 comes to $132,000. The difference is $198,000, which matches the letter's figure. That arithmetic is ours. The inputs are the commenter's reading of the release and have not been checked against it here.

How many companies would switch?

The aggregate benefit depends on adoption. Commenters say the SEC's figures assume 20% of eligible filers elect semiannual reporting.¹⁰ The opposing letter and Alquist and Lewis argue that the assumption is thinly supported. Alquist and Lewis point to the United Kingdom, where they say about 9% of firms stopped quarterly reporting once permitted. The release cites a study finding fewer than 10% stopped issuing quarterly reports, and says it reads that as voluntary earnings releases, since UK firms no longer file quarterly reports.⁹,¹⁰ If fewer companies switch, the $394 million total shrinks with them. The per-company figure does not.

Alquist and Lewis also offer a cost estimate of their own. Assuming a 5 basis-point rise in the cost of equity, their model produces a loss of $94.2 billion to $176.9 billion.¹⁰ The authors present that figure as an illustration. It is not a forecast, and it is not an SEC estimate. Their paper is dated July 7, 2026, one day after the comment deadline, and it was not found in the SEC comment file.¹⁰

Would the quarterly work stop?

The SEC says the proposal does not touch earnings announcements. Atkins: "Today's proposal would not affect the frequency of a company's earnings call and earnings release. That frequency has been, and will continue to be, determined solely by the company."⁷ The release acknowledges that Item 2.02 Form 8-K disclosures would be lost only if a company "stops reporting quarterly earnings or having quarterly earnings release conference calls."²

Skadden, Arps, Slate, Meagher & Flom says many companies may keep the quarterly cycle:

Many companies may continue issuing earnings releases, holding earnings calls and providing guidance, meaning that much of the existing quarterly process would persist regardless of a semiannual election.¹¹

Commenters add that fixed costs would remain. The opposing letter also expects companies to keep preparing quarterly information for lenders, boards and rating agencies.⁹,¹⁰ A company that files one 10-S but still closes its books, briefs its board and holds an earnings call each quarter may avoid less than three 10-Qs' worth of cost. No document examined here measures how much less.

What does the comment file show?

The record comment count comes from Skadden. Its client memo, dated September 24, 2026, reports more than 200,000 comments, with the vast majority opposed.¹¹ The SEC's own comment page gives no total and no tally of support or opposition. Its letter-type counts sum to about 52,600, but its listing runs to 7,255 pages, which by rough arithmetic is on the order of 180,000 to 200,000 entries. Its letter-type counts total about 52,600, and the largest category, Type F, holds 41,110.⁵ The page says "we are working on posting them," and it gives no tally of support or opposition.⁵ The 200,000 figure may prove correct once posting is complete. For now it is Skadden's number, not the agency's.

Is there a final rule?

No. The SEC's rulemaking index, with entries through October 9, 2026, still lists S7-2026-15 as a proposed rule.⁴ The rulemaking page, last reviewed July 31, 2026, shows the comment period closed July 6 and reports no adoption.³ Skadden expects final rules could arrive in time for fiscal 2027. The SEC has announced no timetable.¹¹