SEC’s New Form 10-S Could Change Public Reporting Forever

For decades, public companies have operated on a strict quarterly reporting cycle: file the Form 10-Q, release earnings, answer analyst questions, and repeat every three months. Now, the SEC wants to give companies another option. On May 5, 2026, the SEC proposed allowing public companies to file semiannual reports instead of quarterly reports through a new filing called Form 10-S. SEC Chairman Paul Atkins said the goal is flexibility, allowing companies and investors to decide what reporting frequency works best for them. The proposal would not eliminate quarterly reporting. Instead, companies could choose between continuing with Form 10-Q filings or switching to the new semiannual reporting framework. That decision could reshape how companies communicate with investors, manage disclosure controls, and approach public-market reporting in the future.

How 10-Q Became the Market’s Playbook

Quarterly reporting became the heartbeat of U.S. capital markets because investors wanted regular, standardized, comparable financial information. Over time, Form 10-Q evolved into far more than a compliance document. It became a trust mechanism.

Today, public companies generally file:

• Three quarterly reports on Form 10-Q
• One annual report on Form 10-K

Those 10-Q filings include interim financial statements, MD&A disclosures, litigation updates, liquidity discussions, risk-factor changes, and management certifications. Large accelerated filers typically file within 40 days after quarter-end, while other issuers generally get 45 days. That rhythm shaped everything around it. Analyst models, trading windows, debt covenant testing, shelf registrations, investor calls, blackout periods, stock buybacks, and even executive compensation cycles all became synchronized with quarterly reporting.

But critics have spent years arguing that the system creates “quarterly capitalism,” where management teams obsess over hitting near-term earnings targets instead of long-term strategy. President Trump pushed that debate back into the spotlight in 2025 when he publicly urged the SEC to reconsider mandatory quarterly reporting, arguing that U.S. companies were trapped in short-term thinking while global competitors planned decades ahead.

The SEC’s New Kid on the Block

The proposal does not eliminate quarterly reporting. Instead, it creates an option. Companies could continue filing Form 10-Q exactly as they do today, or they could elect a semiannual reporting framework built around a brand-new filing called Form 10-S.

Under the proposal:

• Quarterly filers would continue filing three Forms 10-Q and one Form 10-K annually.
• Semiannual filers would submit one Form 10-S covering the first six months of the fiscal year and one Form 10-K covering the full year.

The SEC proposal applies to companies subject to Exchange Act Sections 13(a) or 15(d). Companies would elect the semiannual option through a checkbox on Form 10-K or certain registration statements, including Forms S-1, S-3, S-4, S-11, and Form 10. Here is the important technical detail many people are missing: Form 10-S is not expected to be some stripped-down “lite” filing. The proposed form would still require:

• Interim financial statements prepared under U.S. GAAP
• Auditor review, though not a full audit
• Inline XBRL tagging
• Disclosure controls and procedures
• Certifications and exhibits
• Narrative disclosures similar to Form 10-Q

In other words, the SEC is reducing frequency, not eliminating rigor.

Why Investors Are Split Down the Middle

Supporters argue that quarterly reporting has become expensive, repetitive, and overly focused on short-term earnings management. Smaller public companies, biotech firms, and emerging-growth issuers may especially welcome breathing room from the nonstop reporting treadmill. Ro Sokhi, partner at UHY, pointed out that companies could focus more on “long-term strategic growth, rather than this quarterly cadence.” The SEC and some market participants also believe lower compliance costs could make public markets more attractive again, especially as private markets continue stealing potential IPO candidates.

But critics see serious risks.

Kristina Wyatt, former SEC senior counsel, warned that less frequent reporting could create:

• Greater informational asymmetry
• Higher cost of capital
• Reduced pricing efficiency
• Increased reliance on third-party data

That last point matters more than ever in the AI era. If fewer company-certified reports exist, markets may lean more heavily on AI-generated summaries, analyst estimates, alternative datasets, and unofficial information streams. That raises accuracy and accountability concerns fast.

Columbia Business School professor Shivaram Rajgopal also questioned whether the proposal actually solves short-termism. “Myopia over three months,” he argued, “will simply be myopia over six months.” And then comes the comparability problem. If one company reports quarterly while a competitor reports semiannually, analysts could struggle to compare:

• Margins
• Liquidity trends
• Cash flow timing
• Revenue seasonality
• Backlog movement
• Expense patterns

Sandra Peters from CFA Institute called that possibility a “comparability nightmare.”

Why Many Companies May Still Report Quarterly Anyway

Here is the twist that makes this whole proposal more complicated than the headlines suggest: many companies may continue releasing quarterly earnings even if they stop filing quarterly Forms 10-Q. That creates a possible two-track reporting system:

• Formal SEC filings twice a year through Form 10-S
• Voluntary quarterly earnings releases, KPI updates, and analyst calls

Why? Because Wall Street still expects constant information flow.

Companies considering the switch will need to evaluate:

• Analyst expectations
• Debt covenants
• Shelf-registration timing
• Trading-window restrictions
• Regulation FD exposure
• Investor-relations strategy
• ATM offering activity
• Auditor comfort-letter availability

The SEC’s proposal even acknowledges the complications involving Public Company Accounting Oversight Board standards, especially the 135-day negative assurance window tied to comfort letters in securities offerings.

Regulation S-X Is Quietly Doing Heavy Lifting Here

One of the biggest technical shifts in the proposal involves Regulation S-X, the SEC’s financial-statement rulebook. The SEC is proposing changes to:

• Financial statement “staleness” rules
• Interim-period definitions
• Comparative-period presentation requirements
• Registration-statement financial requirements

That may sound deep in the accounting weeds, but it matters enormously for transactional reporting, IPO readiness, and securities offerings. For semiannual filers, “interim” would now refer to a six-month period rather than a quarter. That changes how companies think about:

• Comparative financial statements
• Proxy statement requirements
• Registration statements
• Capital-raising timelines

Accounting teams will need to rethink not just filing cadence, but entire disclosure-control frameworks.

What Finance Pros Should Be Learning Right Now

First, finance professionals need to separate reporting frequency from disclosure quality. Filing less often does not automatically reduce accountability.

Second, Moving from Form 10-Q to Form 10-S is not just a compliance choice. It could affect analyst coverage, investor trust, liquidity, and cost of capital.

Third, professionals should closely monitor FASB’s evolving role. SEC officials and FASB leadership already signaled that interim reporting standards, materiality expectations, and disclosure frameworks could eventually evolve alongside the proposal.

And fourth, AI is now entering the reporting conversation in a major way. SEC Chief Accountant Kurt Hohl said the agency is actively evaluating how companies and auditors are using AI in financial reporting, disclosure preparation, and audit procedures.

Is Quarterly Reporting Cooked?

Despite all the noise, quarterly reporting is probably not disappearing anytime soon. Large-cap companies with heavy analyst coverage will likely stick with quarterly reporting because markets expect it. Investors rely on it. Trading infrastructure depends on it. Capital markets move around it. But smaller issuers, development-stage biotech firms, and companies with long operational cycles may seriously consider Form 10-S if the final rule becomes effective. The future may not be quarterly versus semiannual. It may be a hybrid system where companies choose the cadence that best matches their business model, investor base, and strategic priorities.