The U.S. Securities and Exchange Commission (SEC) has proposed giving public companies the option to file semiannual reports instead of quarterly reports. Announced on May 5, 2026 (Release Nos. 33-11414; 34-105368; File No. S7-2026-15), the proposal would represent the most significant proposed change to SEC interim reporting requirements since quarterly reporting replaced semiannual reporting in 1970, if adopted. Here’s a straightforward look at what’s being proposed, how it would work, and what companies should be tracking.
At a Glance
| Today (Form 10-Q) | Proposed (Form 10-S, if elected) | |
|---|---|---|
| Interim filings per year | 3 (quarterly) | 1 (semiannual) |
| Total periodic filings per year | 4 (3x 10-Q + 1x 10-K) | 2 (1x 10-S + 1x 10-K) |
| Filing deadline | 40/45 days after quarter-end | 40/45 days after first half-year |
| Financial statement basis | U.S. GAAP, reviewed (not audited) | U.S. GAAP, reviewed (not audited) — unchanged |
| Inline XBRL tagging | Required | Still required |
| Disclosure content required | Full narrative + financials | Substantially the same disclosures, covering a six-month period |
| Can frequency change mid-year? | N/A | No — locked in for the fiscal year once elected |
| Mandatory or optional? | Mandatory | Optional; election made annually |
What’s Changing
Most domestic public companies subject to Exchange Act Section 13(a) or 15(d) reporting requirements files quarterly reports on Form 10-Q. Under the proposed amendments, companies would be able to elect, on an annual basis, to file a semiannual report on a new Form 10-S instead of two of their three quarterly Form 10-Q filings.
A company that elects semiannual reporting would file:
• One semiannual report on Form 10-S, covering the first six months of the fiscal year, in place of the Q1 and Q2 Form 10-Q filings
• One annual report on Form 10-K covering the full fiscal year, eliminating the need for a separate third-quarter Form 10-Q.
Companies that don’t elect semiannual reporting would continue filing quarterly as they do today. The option is not mandatory.
How Form 10-S Would Work
1.Same content, different period. Form 10-S would generally require substantially the same narrative disclosures and financial information currently required in Form 10-Q, adapted for a six-month reporting period.
2.Filing deadline. Form 10-S would be due 40 or 45 days after the end of the first semiannual period, depending on the company’s filer status — the same deadline structure currently used for Form 10-Q.
3.Review, not audit. Semiannual financial statements would need to be prepared under U.S. GAAP and reviewed (but not audited) by an independent auditor, consistent with the current treatment of quarterly financials.
4.Inline XBRL tagging is still required. Financial statements filed on Form 10-S would still need to be data-tagged using Inline XBRL.
5.A cover-page checkbox. Companies would indicate their elected reporting frequency by checking a box on Form 10-K (for existing filers) or on registration statements such as Form S-1, S-3, S-4, S-11, or Form 10 (for companies going public). Existing companies choosing to remain quarterly would simply leave the box unchecked.
6.One choice per fiscal year. Once a company elects a reporting frequency for a fiscal year, it must stick with it for the remainder of that year — it cannot switch from semiannual back to quarterly, or vice versa, mid-year. The election is made annually, so a company could change its choice the following year.
7.Conforming changes elsewhere. The proposal also includes amendments to Regulation S-X governing financial statement requirements, and updates to the rules on when financial statements become “stale” in registration statements and other filings, to align with the new Form 10-S deadlines.
Why the SEC Is Proposing This
The proposal is framed as part of a broader effort to ease compliance costs and encourage companies to go and remain public. Among other factors, SEC Chairman Paul Atkins has pointed to the decline in the number of U.S. public companies over the past several decades as part of the rationale for revisiting reporting requirements. The SEC estimates average net annual direct compliance cost savings of approximately $198,000 for issuers that elect semiannual reporting, with the proposal noting that reduced reporting frequency could also lessen “short-termism” by allowing management to focus more on long-term strategy rather than the quarterly earnings cycle.
Notably, the proposal would not prevent companies from keeping investors updated more often than the new minimum. Companies electing semiannual reporting could still choose to provide quarterly financial information voluntarily, such as through earnings releases furnished on Form 8-K — although those voluntary updates would not automatically be subject to the same reporting framework as a required Form 10-Q.
This semiannual reporting proposal is one of several related rulemakings the SEC has introduced as part of a broader push to streamline the IPO process and modernize disclosure requirements.
What Happens Next
The proposal was subject to a public comment period, with comments due on or before July 6, 2026. After reviewing comments, the SEC will determine whether and how to finalize the rule; no effective date has been set, and adoption of a final rule is not guaranteed.
Key dates so far:
• May 5, 2026 — SEC publishes the proposed rule (File No. S7-2026-15)
• July 6, 2026 — Public comment deadline
• The SEC has not announced when, or whether, a final rule will be adopted
One possible implementation timeline, if the rule is adopted and becomes effective later in 2026: a calendar-year-end company electing semiannual reporting could file its 10-K in February/March 2027 and its first Form 10-S in mid-2027, covering the first half of fiscal 2027
What This Means for Disclosure Teams, Whichever Way You Go
Whether your company ultimately stays on a quarterly cadence or elects semiannual reporting, a few things are already clear from the proposal as written:
• The required disclosure content remains substantially the same — Form 10-S generally requires substantially the same narrative and financial disclosures as Form 10-Q, adapted for a six-month reporting period. The volume of required disclosure remains broadly similar, although it is prepared and reported on a six-month rather than quarterly cadence.
• The election is locked in for the year, so the choice of cadence needs to be made deliberately, with downstream processes (audit/review scheduling, investor communications, internal reporting cycles) built around whichever frequency is chosen.
• If adopted, the proposal could result in a mixed reporting environment in which some issuers report quarterly while others elect semiannual reporting, which could mean more variation in how peer companies report going forward.
• Inline XBRL tagging isn’t being removed — it stays a requirement for Form 10-S financial statements, the same as it is today for Form 10-Q.
How EcoActive Can Help, Regardless of Reporting Cadence
EcoActive is an AI-native financial and ESG disclosure management platform, with Inline XBRL tagging and financial data management built into the reporting workflow rather than added on at the end. That structure is designed to work whether a company continues filing Form 10-Q or, if the proposal is adopted, elects to file Form 10-S.
The same underlying reporting data and disclosure framework can support either a quarterly or semiannual filing cycle without requiring organizations to redesign their core reporting workflows.
A single governed environment for financial and ESG disclosure can help organizations switch reporting frequency—or manage a transition between reporting cadences—without maintaining separate reporting processes.
Because Inline XBRL tagging is integrated into EcoActive’s reporting workflow, companies that elect Form 10-S could continue using the same tagging process rather than introducing a separate tagging step.
As the SEC reviews comments and considers whether to adopt a final rule, disclosure teams have time to think through what reporting frequency makes sense for their company and how their underlying reporting infrastructure can support that choice efficiently.
This article is based on the SEC’s proposed rule (Release Nos. 33-11414; 34-105368; 39-2563; IC-36140; File No. S7-2026-15), published May 5, 2026.
