On March 5, 2026, the U.S. Securities and Exchange Commission (the “SEC”) issued an order[1] providing conditional relief from the insider reporting requirements of Section 16(a) of the U.S. Securities Exchange Act of 1934 (the “Exchange Act”) for directors …
Sullivan & Cromwell Discusses SEC Exemption of Officers, Directors of Certain Foreign Private Issuers from Section 16(a) Reporting
On March 5, 2026, the SEC issued an order exempting officers and directors of certain foreign private issuers from Section 16(a) insider reporting requirements, reducing transparency on securities transactions. This affects foreign private issuers subject to SEC reporting with potential compliance gaps for stakeholders relying on insider trading disclosures. The exemption introduces risks of undisclosed insider transactions impacting investor confidence and market fairness.