The Current State of Human Capital Disclosure in Corporate America: What Data Large U.S. Employers Share | Just capital

HR Effectiveness

I have shared over 10 resources and posts regarding the Security Exchange Commission (SEC) Regulation S-K human capital (HC) disclosure requirement during the past year. The rule, which went into effect on November 9, 2020, gives public firms governed by the SEC 60-90 days after their fiscal year to include HC information in their annual report. This new report by Just capital analyzed how the 100 largest U.S. employers disclose 28 metrics across six critical HC themes: Employment and Labor Type, Job Stability, Wages, Compensation and Benefits, Workforce Diversity, Equity, and Inclusion, Occupational Health, and Safety, and Training and Education. Consistent with other analyses, there is much variation in what firms are reporting, given the SEC leaves it up to companies to determine what measures to disclose. The analysis found that disclosure is “low across the board, with the disclosure rate below 20% for most metrics,” Also, “most metrics are currently disclosed in Corporate Social Responsibility or Sustainability Reports, which do not require auditing or have standardization requirements.” I expect the SEC to establish more rigor on what HC measures firms should use to show the connection between human capital practices and business performance. While the SEC figures this out, it is a good time for firms to leverage these materials to develop their approach to HC disclosure. Even for firms not governed by the SEC, the report provides several insights on HC measures, including one chart summarizing 28 HC metrics by theme.

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