As discussed in this prior blog, on December 18, 2025, the Holding Foreign Insiders Accountable Act (HFIAA) removed the exemption from reporting under Section 16(a) of the Securities Exchange Act of 1934 (Exchange Act), as amended, for foreign private issuers (FPIs). 

On March 5, 2026, the United States Securities

Continue Reading SEC provides exemptive relief and issues final rules codifying Holding Foreign Insiders Accountable Act Section 16 reporting for directors and officers of foreign private issuers

Foreign private issuers (FPIs) have recently faced scrutiny from regulators in the United States. As discussed in a previous Market Edge blog, US Securities and Exchange Commission (SEC) Chairman Paul Atkins has questioned some of the accommodations currently provided to FPIs and whether the “FPI” definition under federal securities

Continue Reading Executive compensation for foreign private issuers: Key reporting and tax issues to consider

On January 13, 2026, the United States Securities and Exchange Commission (SEC) announced plans to conduct a comprehensive review of Regulation S-K, the central framework governing non-financial statement disclosure requirements for public companies. In a statement, SEC Chairman Paul S. Atkins emphasized that the current breadth of Regulation S-K

Continue Reading SEC proposes comprehensive reform of Regulation S-K

Now that 2026 has begun, US public companies with a December 31 fiscal year-end will be working to prepare their annual reports on Form 10-K for filing with the United States Securities and Exchange Commission. 

Companies are encouraged not only to meet relevant SEC requirements, but also to understand disclosure

Continue Reading Updating Form 10-K for fiscal year 2025 and other annual reporting

For more than five decades, a significant advantage of “Foreign Private Issuer” (FPI) status was the exemption from the beneficial ownership reporting requirements and short-swing profit rules of Section 16 of the Securities Exchange Act of 1934 (Exchange Act). That era has now ended.

On December 18, 2025, the Holding

Continue Reading End of an era: FPIs now subject to Section 16 reporting, new requirements

We are pleased to announce the availability of our calendar showing Securities and Exchange Commission (SEC) filing deadlines and financial statement staleness dates for 2026.

Public companies are encouraged to keep in mind these important deadlines and dates for meeting their SEC reporting obligations for the forthcoming year.

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Continue Reading 2026 SEC filing deadlines and financial statement staleness dates calendar

On September 4, 2025, the US Securities and Exchange Commission (SEC) announced the publication of its Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions, which sets forth its rulemaking priorities for the next several months.

In a statement, SEC Chairman Paul Atkins noted that the agenda represents the

Continue Reading SEC rulemaking agenda focuses on crypto regulation, facilitating capital formation and easing public company reporting burdens

As discussed in our prior blog posts, on June 4, 2025, the US Securities and Exchange Commission (Commission) published a concept release (Release) soliciting comments on whether to revise the definition of “foreign private issuer” (FPI) under Commission rules in light of considerable changes to the FPI population over the

Continue Reading The Commission’s analysis of recent developments in the FPI population

As discussed in our prior blog post, the US Securities and Exchange Commission (Commission) recently issued a concept release (Release) aiming to gather input on whether the criteria for designation as a foreign private issuer (FPI) should be reevaluated in light of changes to the FPI population in recent

Continue Reading Current state of play for foreign private issuers