Would Companies Still Report Quarterly Earnings Under Form 10-S?

Form 10-S is still a proposal: the SEC proposed it in May 2026, and as of October 7, 2026 it has not been adopted. If it were adopted, it would let a company replace its three quarterly Form 10-Q reports with one semiannual report, but it would neither require nor ban quarterly earnings releases and earnings calls. Those are voluntary today, and the SEC says the proposal would not change that, so whether a company kept announcing quarterly results would be its own decision.

Would the SEC's Form 10-S proposal end quarterly earnings releases?

The proposal would change a required filing, not the earnings announcements traders usually react to. The SEC's page for file S7-2026-15 lists the semiannual reporting plan, Release 33-11414, as a proposed rule issued on May 5, 2026, with public comments due on July 6, 2026, and as of October 7, 2026 the page shows no final rule and no vote to adopt it. hi2morrow's overview of the SEC's Form 10-S proposal and where it stands covers the election mechanics and the timeline in more detail.

On earnings specifically, the proposing release says the proposal does not include any general changes to the rules governing earnings releases or earnings guidance, apart from technical amendments to Item 2.02 of Form 8-K so that it also refers to semiannual periods. It adds that federal securities laws impose no general duty on companies to announce earnings, hold earnings calls, or issue guidance. SEC Chairman Atkins put it more directly in his statement on the proposal: "Today's proposal would not affect the frequency of a company's earnings call and earnings release."

That does not mean nothing would change for a stock whose issuer opted in. The same release acknowledges that if a company elected semiannual reporting and stopped reporting quarterly earnings and holding quarterly calls, the disclosures that Item 2.02 produces would not be available for those quarters. The SEC expects each company's individual characteristics, facts, and circumstances to decide which way it goes.

What is the difference between a 10-Q and an earnings release?

A Form 10-Q is a mandatory report filed with the SEC, while an earnings release is a company announcement that becomes an SEC document only because Form 8-K Item 2.02 requires it to be furnished. The 10-Q contains interim financial statements prepared under the SEC's interim reporting rules and subject to an independent public accountant's review, tagged in XBRL, and accompanied by management's discussion and certifications. A large accelerated or accelerated filer has 40 days after the quarter ends to file it, and other companies have 45 days.

The earnings release works under different rules. Since 2003, Item 2.02 has required a company that publicly announces results for a completed period to furnish the release as an exhibit to a Form 8-K. According to the SEC's proposing release 33-11414, information furnished under Item 2.02 does not require an independent public accountant's review, is not required to follow GAAP (although the non-GAAP rules of Regulation G still apply), and is not required to be data tagged. The antifraud provisions apply to earnings releases and guidance in any case.

The earnings call sits alongside the release. Item 2.02 lets a company skip furnishing the call itself if certain conditions are met, including that the call takes place within 48 hours of the release, is open to the public, and is announced in advance along with the dial-in details. In practice, the headline numbers, the guidance, and the call all reach traders through this voluntary channel, and the release is usually the first of the two documents they see, while the timing of the 10-Q varies from company to company. The timing side of that, including how releases issued after the 4 p.m. close are traded, is covered in hi2morrow's guide to trading earnings released after the close.

Which companies might keep quarterly earnings, according to the SEC?

The SEC does not predict a single outcome. Its economic analysis says it does not expect issuers to respond homogeneously and sorts them into three possible groups. Semiannual reporters would file Form 10-S without systematically providing voluntary disclosure for the first and third quarters. Quarterly reporters would keep filing 10-Qs because the savings look small or because investors, contracts, or other regulations favor quarterly disclosure. Hybrid reporters would file Form 10-S while continuing to give quarterly information voluntarily through earnings releases, guidance, or calls, and could even include quarterly figures inside the Form 10-S itself.

The release lists the pressures that could keep a company on a quarterly rhythm: expectations of investors and securities analysts, disclosure practices in its industry, contractual obligations, and other regulatory requirements. It also notes a less obvious one. A longer gap between reports means directors and employees hold non-public information for longer under closed trading windows, so some companies may prefer quarterly reporting simply because it opens those windows more often.

For a reference point, the SEC cites a 2017 CFA Institute research study of the United Kingdom, where quarterly reporting stopped being required in 2014. Fewer than 10% of UK companies had stopped issuing quarterly reports by the end of 2015, and the SEC reads that as referring to voluntary earnings releases. The Commission says foreign experience may be broadly illustrative, which is a long way from a forecast for U.S. companies, and it asks commenters how likely semiannual filers would be to keep quarterly releases.

What would a quarterly release from a semiannual filer look like?

It would look much like a release today, but the official report behind it would arrive later. Under the proposed text of Item 2.02, the item would be triggered by results for a "completed quarterly, semiannual, or annual fiscal period," so a semiannual filer that announced first-quarter results would still furnish the release on Form 8-K. What would be missing is the first-quarter 10-Q: the quarter's numbers would next appear in an SEC report only in the Form 10-S covering the full six months.

Take ABC Corp., a hypothetical calendar-year company and large accelerated filer, used here only to illustrate the mechanics and not as a forecast. Under the current rules it releases first-quarter results in late April, holds a call the same day, and files its 10-Q within 40 days of the quarter's end, so its 10-Q for the first quarter of 2027 would be due by May 10, 2027. Following the timeline the SEC itself uses as an example, suppose the rule were adopted in time and ABC ticked the semiannual box on its Form 10-K for fiscal 2026, filed in March 2027. There would be no 10-Q for the first quarter of 2027, and its first Form 10-S, for January through June 2027, would be due in August 2027, 40 days after the six months end on June 30, or 45 days if ABC were not an accelerated filer.

If ABC chose the hybrid path, it could still publish a first-quarter release and hold a call in late April 2027. That release would be furnished under Item 2.02 without an auditor's review, and the same quarter would reach a reviewed SEC report only in August, more than three months later. If ABC chose to be a pure semiannual reporter instead, its next scheduled financial report after the 10-K would be the August Form 10-S, with Form 8-K still covering material events in between.

The SEC flags the trade-off in its analysis of hybrid reporters. Voluntary quarterly disclosures may differ from 10-Q filings in scope, standardization, XBRL tagging, and liability, since earnings releases are typically furnished rather than filed. It also cites research suggesting markets give voluntary disclosures more weight when a later mandatory report confirms them, and with semiannual filing that confirmation would come less often.

What is the SEC still asking about earnings releases?

Several possible changes appear only as questions in the release, not as proposed rules. The SEC asks how likely semiannual filers are to keep issuing quarterly earnings releases, and whether a first-quarter release from a December year-end company, with the Form 10-S not due until August, would raise new investor protection concerns. It asks whether Item 2.02 submissions from semiannual filers should be "filed" rather than "furnished," which would expose them to additional liability under Exchange Act Section 18, and whether such a requirement might discourage those companies from issuing releases at all.

It also asks whether first- and third-quarter earnings releases from semiannual filers should require a review by an independent public accountant, and whether auditing standards would need to change to allow that. Separately, the release recognizes that stock exchange rules may need changes to fit semiannual reporting if the proposal is adopted, and says it expects SEC staff would coordinate with exchanges and accounting and auditing standard-setters. None of these points is part of the proposal as written, and any of them could appear in, or stay out of, a final rule.

What does this mean for an earnings calendar?

Nothing changes for any company's earnings calendar today, because the proposal has not been adopted and no company can elect semiannual reporting yet. If a final rule were adopted, a stock's earnings dates would stop being a by-product of the 10-Q cycle for companies that switched. For a hybrid reporter the familiar quarterly releases and calls could continue on a voluntary basis, while for a pure semiannual reporter the scheduled financial updates for a calendar-year company would shrink to the annual report and an August Form 10-S.

The practical signals would be the check box on the cover of each company's Form 10-K and the company's own announcement of its next release date. The release does not say how quickly the first elections could happen, because it sets no compliance date.

Alexander Styopin's professional view: traders tend to treat the earnings release and the 10-Q as one event, and this proposal is a good reason to separate them. The number that moves a stock already comes from a voluntary announcement, so the real question for each name would be whether management keeps talking every quarter, not which form it files. A company that dropped its quarterly calls would leave longer stretches in which news reaches the price through 8-Ks, conferences, and guesswork, and the eventual reports could carry more surprise. The risk mechanics would be the familiar ones, such as a stop that fills well below its trigger when the stock gaps, as hi2morrow explains in its guide to why a stop-loss can fill below your stop after a gap. Until a final rule exists, all of this remains a scenario to watch rather than a change to plan around.

Educational material only. Not investment or legal advice. The proposal could change before any final rule, and disclosure practices vary by company.

Author: Alexander Styopin, hi2morrow analyst and economist with 25 years of experience in the US stock market