An Inside Look at Pay vs. Performance Year 2 Disclosure Trends

In August 2022, the U.S. Securities and Exchange Commission (SEC) adopted final rules implementing the pay vs. performance (PVP) requirement in the Dodd-Frank ActOpen in a new tab. These rules require registrants to disclose, in both tabular and narrative format, how their executive compensation is paid in relation to their financial performance.

WTW is among the organizations that have kept a close eye on PVP disclosure trends, providing insight on early trends as well as broad consensus on disclosure practices among first-year filersOpen in a new tab. In addition, WTW tracks the SEC’s Compliance and Disclosure Interpretations (C&DIs) that accompanied the final rules, most recently in November 2023 (see SEC issues November 2023 guidance on pay versus performanceOpen in a new tab). READ MORE