Not Much Data Disclosed on SEC Human Capital Reporting Requirements | JD Supra & Intelligize

HR Effectiveness

Last week, I made a post that included various resources I have shared on the SEC human capital (HC) reporting requirements. Given the high number of shares and interest in this post, I am sharing an additional resource from JDSupra based on a new report from IntelligizeHuman Capital Disclosure Report: Learning on the Job. The report analyzed 427 Annual Reports on Form 10-K filed by companies in the S&P 500 between November 9, 2020, and March 5, 2021. As noted by JDSupra in its summary of the report, most companies made a sincere effort to fulfill the scantly defined disclosure obligation; nevertheless, companies capitalized on the fact that the new rule does not call for specific metrics, as relatively few issuers provided meaningful numbers about their human capital, even when they had those numbers at hand. The report notes that HC disclosures in the 427 10-Ks analyzed significantly varied in both form and content. Further, content length did not correlate with company size (e.g., Amazon has more than 1M employees and included less content than Extra Space Storage, which has fewer than 5,000). Other insights are provided.

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