Search within this section
Select a section below and enter your search term, or to search all click PwC SEC volume
Favorited Content
SEC 3185 - Change in fiscal year
Publication date: 30 Jun 2023
us PwC SEC Volume 3185
[Editor’s note: SEC 3185 is principally focused on Exchange Act reporting guidance for a US domestic SEC registrant that changes its fiscal year-end. The guidance in this section does not address Securities Act filings. Those documents may need more current audited financial statements to comply with the relevant form’s instructions and age of financial statement requirements (e.g., S-X 3-12). See SEC 4600.4 and SEC FRM 1365.4. See SEC 3185.8 for information relating to foreign private issuers.]
.1 General
.11 What are the Exchange Act reporting requirements associated with an SEC registrant’s change in fiscal year-end?
The Exchange Act reporting requirements associated with an SEC registrant’s change in its fiscal year-end are principally focused on two areas:
(i) Form 8-K reporting of a registrant’s decision to change its fiscal year-end (see SEC 3185.12) and
[Editor’s note: The principal rules governing changes in fiscal year-end are set forth in Exchange Act Rules 13a-10 and 15d-10. These rules are substantially the same. Throughout SEC 3185 we reference Rule 13a-10. Registrants subject to Rule 15d-10 should refer to that rule for the corresponding guidance.]
.111 What do the terms “transition period” and “transition report” mean?
The “transition period” is the period of time between the last day of the most recent fiscal year and the first day of the new fiscal year. For example, if an SEC registrant with a March 31 fiscal year-end decides on June 30, 2023 to change its fiscal year-end to December 31, 2023, the transition period is the nine-month period from April 1, 2023 through December 31, 2023 (i.e., the period of time between the last day of the most recent fiscal year (March 31, 2023) and the first day of the new fiscal year (January 1, 2024)). As described more fully below, a US domestic SEC registrant generally reports the transition period on a Form 10-K or Form 10-Q. A Form 10-K or Form 10-Q used to report a transition period is commonly referred to as a “transition report.”
.12 What are the Form 8-K reporting requirements associated with an SEC registrant’s decision to change its fiscal year-end?
Note 1 to Exchange Act Rule 13a-10 requires specified issuers to file a Form 8-K to report a decision to change their fiscal year-end. Item 5.03(b) of Form 8-K sets forth the associated disclosure requirements. An Item 5.03(b) Form 8-K must be filed within four business days after the registrant determines to change its fiscal year-end. See also SEC 3185.901.
.13 How does an SEC registrant report the transition period under the Exchange Act?
Separate and apart from the Form 8-K disclosure of the registrant’s decision to change its fiscal year-end, Exchange Act Rule 13a-10 sets forth the SEC’s transition period reporting requirements. As more fully discussed below, the transition period reporting requirements are largely driven by the length of the transition period:
(i) six months or more (see SEC 3185.2);
(ii) less than six months but more than one month (see SEC 3185.3); or
(iii) one month or less (see SEC 3185.4)
See SEC FRM 1360.2.
.2 Transition periods of six months or more
.21 How does an SEC registrant report a transition period of six months or more
A transition period of six months or more must be reported on Form 10-K, including all textual disclosures (e.g., management’s discussion and analysis pursuant to S-K 303) and audited transition period financial statements. See Exchange Act Rule 13a-10(b) and SEC FRM 1365.1.
[Editor’s note: In no event may a transition report for a US domestic registrant cover 12 or more months. See SEC FRM 1365.3.]
.22 What is the due date of a transition report on Form 10-K?
The due date of a transition report on Form 10-K is set forth in Exchange Act Rule 13a-10(b) and depends on the registrant's accelerated filer status:
- Large accelerated filers: the transition report must be filed within 60 days after the later of (i) the election to change the fiscal year or (ii) the close of the transition period.
- Accelerated filers: the transition report must be filed within 75 days after the later of (i) the election to change the fiscal year or (ii) the close of the transition period.
- Non-accelerated filers: the transition report must be filed within 90 days after the later of (i) the election to change the fiscal year or (ii) the close of the transition period.
[Editor’s note: See SEC 3125.803 and SEC FRM 1340.8 for guidance on the impact of a change in fiscal year-end on a registrant’s accelerated filer status.]
Consider the following example:
Facts: Company X is a large accelerated filer with a June 30 fiscal year-end. On July 28, 2023, Company X determined to change its fiscal year-end from June 30 to December 31.
Analysis: Company X will file an Item 5.03(b) Form 8-K reporting its decision to change its fiscal year-end no later than August 3, 2023 (i.e., the fourth business day after the decision to change). The transition period for Company X is six months (July 1, 2023 through December 31, 2023). Accordingly, Company X is required to report its transition period on Form 10-K, including all textual disclosures and audited transition period financial statements. Since Company X is a large accelerated filer, its transition report on Form 10-K is due February 29, 2024 (60 days after the later of (i) the election to change the fiscal year (July 28, 2023) or (ii) the close of the transition period (December 31, 2023)).
[Editor's note: A registrant must file its annual report for any fiscal year that ended before the date it elected to change its fiscal year-end. Accordingly, in the above example, Company X would be required to file its Form 10-K for the year ended June 30, 2023 no later than August 29, 2023.]
.23 What financial statements are required in a transition report on Form 10-K?
Similar to a Form 10-K used as an annual report, a transition report on Form 10-K is required to contain the financial statements required by Regulation S-X as specified by Item 8 of Form 10-K. In addition, a transition report on Form 10-K is required to include audited financial statements for the transition period. A transition report on Form 10-K is also required to include financial statements (or summarized footnote disclosure) for the comparative transition period. The comparative transition period financial statements/note disclosures may be unaudited. See Exchange Act Rule 13a-10(b).
Given the fact pattern shown in the example in SEC 3185.22, Company X would provide the following audited financial statements in its December 31, 2023 transition report on Form 10-K (in accordance with S-X 3-01, S-X 3‑02, and S-X 3-04):
Balance Sheets |
Statements of Comprehensive Income, Cash Flows, and Equity(a) |
Financial Statement Schedules |
||
As of 12/31/23 and the end of each of the two latest fiscal years (fiscal years ended 06/30/23 and 06/30/22). |
For the six-month transition period ended 12/31/23 and for each of the three latest fiscal years (fiscal years ended 06/30/23, 06/30/22 and 06/30/21). |
Required as applicable in support of and for the same periods required for the primary financial statements. |
||
(a) See SEC 3185.5 regarding requirements for providing unaudited transition period comparative information (i.e., for the six months ended December 31, 2022 in the above example). |
||||
Company X must also include management's report on internal control over financial reporting (and the associated auditor attestation report) as of December 31, 2023. This is true even though the transition period does not constitute a fiscal year. See SEC 3185.24.
[Editor’s note: Except with respect to registered investment companies, the SEC will accept the filing of audited financial statements covering a period of nine to twelve months as satisfying a requirement for filing financial statements for a period of one year where the registrant has changed its fiscal year. See S-X 3-06(a)(1). Accordingly, in the above example, if Company X had changed its fiscal year-end to March 31 (rather than December 31), then the transition period would have been nine months and the transition report would not have needed to include the June 30, 2022 audited balance sheet nor the audited statements of comprehensive income, cash flows and equity for the year ended June 30, 2021. This is because the transition period financial statements as of and for the nine-month period ended March 31, 2024 would satisfy a requirement for filing audited financial statements for a fiscal year.]
.24 How are the SEC’s reporting requirements relating to internal control over financial reporting impacted by a change in fiscal year-end?
If a registrant prepares its transition report on Form 10-K (whether voluntarily or by rule), it must also comply with the applicable SEC reporting requirements relating to internal control over financial reporting, including any applicable auditor attestation requirements, as of the end of the transition period. See Question 6 of Management’s Report on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports--Frequently Asked Questions (revised September 24, 2007).
For example, if a US domestic registrant changed its year-end from June 30 to December 31, then the transition report (i.e., on Form 10-K) would be required to include management's report on internal control over financial reporting as of December 31 and the associated auditor attestation (in each case, subject to the SEC's transition provisions relating to newly public companies and the auditor attestation exemption provided to non-accelerated filers and emerging growth companies, each as described in SEC 3125.11).
However, if the registrant is eligible to and does report the transition period on Form 10-Q, then the registrant would not be required to provide a management report on internal control over financial reporting or any related auditor attestation report as of the close of the transition period (either in the transition report or in the Form 10-K that includes the audited transition period financial statements). Consider the following example:
Facts: On March 25, 2023, Company Z, a calendar year-end accelerated filer, decided to change its fiscal year from December 31 to March 31. Company Z elected to file its transition report on Form 10-Q covering the transition period from January 1, 2023 to March 31, 2023.
Analysis: Company Z would be required to include audited financial statements for the transition period in its Form 10-K for the year ending March 31, 2024. Company Z would only be required to include a management report on internal control over financial reporting and related auditor attestation report as of March 31, 2024 in its Form 10-K for the year ending March 31, 2024. This is true even though Company Z never provided a management report on internal control over financial reporting (or associated auditor attestation) as of March 31, 2023.
.3 Transition periods of less than six months but more than one month
.31 How does an SEC registrant report a transition period of less than six months but more than one month?
A transition period of less than six months but more than one month may be reported either on Form 10-Q (with unaudited transition period financial statements) or on Form 10-K (with audited transition period financial statements). If the transition report is filed on Form 10-Q (with unaudited financial statements), then separate audited statements of comprehensive income, cash flows and equity for the transition period must be included in the annual report which covers the first 12 months of the new fiscal year. A separate audited balance sheet as of the end of the transition period would need to be filed in the annual report only if the audited balance sheet as of the end of the fiscal year prior to the transition period is not filed. The notes to the financial statements for the transition period may be integrated with the notes for the full fiscal period(s). See Exchange Act Rule 13a-10(c).
.32 What is the due date of a transition report on Form 10-Q?
The due date for a transition report on Form 10-Q is set forth in Exchange Act Rule 13a-10(c) and depends on the registrant's accelerated filer status:
- Large accelerated filers and accelerated filers: the transition report must be filed within 40 days after the later of (i) the election to change the fiscal year or (ii) the close of the transition period.
- Non-accelerated filers: the transition report must be filed within 45 days after the later of (i) the election to change the fiscal year or (ii) the close of the transition period.
[Editor’s note: See SEC 3125.803 and SEC FRM 1340.8 for guidance on the impact of a change in year-end on the registrant’s accelerated filer status.]
[Editor’s note: If the registrant elects to report a transition period of less than six months on Form 10-K, the filing timetable described in SEC 3185.22 would apply.]
Consider the following example:
Facts: Company Y is a large accelerated filer with a fiscal year-end of August 31. On January 3, 2023, Company Y decided to change its fiscal year end to December 31 (beginning with December 31, 2022).
Analysis: Company Y will file an Item 5.03(b) Form 8-K reporting its decision to change its fiscal year-end no later than January 9, 2023 (i.e., the fourth business day after the decision to change). The transition period for Company X is four months (September 1, 2022 through December 31, 2022). Accordingly, Company Y has the option to file its transition report either on Form 10-K (with audited transition period financial statements and management's assessment of internal control over financial reporting and the associated auditor attestation) or on Form 10-Q (with unaudited transition period financial statements).
If Company Y elects to report its transition period on Form 10-Q, then the transition report would be due February 13, 2023 (i.e., because the 40th day after the later of (i) the election to change the fiscal year-end (January 3, 2023) or (ii) the close of the transition period (December 31, 2022) is February 12, 2023, which is a Sunday).
[Editor's note: Company Y would be required to file its Form 10-Q for the old fiscal year quarter ended November 30, 2022 in the normal course (i.e., by January 9, 2023). See Exchange Act Rule 13a-10(e)(1).]
.33 What financial statements are required in a transition report on Form 10-Q?
Exchange Act Rule 13a-10(c) specifies that the financial statements included in a transition report on Form 10-Q are required to cover the transition period. Additionally, in SEC Release 33-6823, Amendments to Reporting Requirements for Issuer’s Change of Fiscal Year; Financial Reporting Changes; Period to be Covered by First Quarterly Report After Effective Date of Initial Registration Statement (SEC Release 33-6823), the Commission stated that “[c]onsistent with existing requirements for Form 10-Q, a transition report on Form 10-Q also is required to include financial information about the comparable period of the prior year.” (footnote omitted). Financial statement schedules are not required to be included in a transition report on Form 10-Q. See Exchange Act Rule 13a-10(c).
Using the fact pattern described in SEC 3185.32, Company Y’s transition report on Form 10-Q would include a balance sheet as of December 31, 2022 and statements of comprehensive income, cash flows and equity for the period from September 1, 2022 through December 31, 2022 as well as for the period from September 1, 2021 through December 31, 2021. Company Y would also present a balance sheet as of August 31, 2022.
.34 If a registrant reports its transition period on Form 10-Q (with unaudited transition period financial statements), will the transition period financial statements ever need to be audited?
Yes. Exchange Act Rule 13a-10(c) specifies that if the financial statements included in a transition report on Form 10-Q were unaudited, then the company must file separate audited transition period statements of income and cash flows with the first annual report for the newly adopted fiscal year. However, a separate audited balance sheet as of the end of the transition period is only required if the audited balance sheet as of the end of the fiscal year prior to the transition period is not filed. See SEC 3185.24 regarding internal control over financial reporting requirements.
Given the fact pattern described in SEC 3185.32 and .33, Company Y would be required to include audited statements of comprehensive income, cash flows and equity for the transition period (i.e., September 1, 2022 through December 31, 2022) in its Form 10-K for the year ended December 31, 2023. Company Y has the option of providing its audited balance sheet as of December 31, 2022 or August 31, 2022 in that Form 10-K. However, in most cases the transition period balance sheet will be audited (due to the requirement to provide audited statements of comprehensive income, cash flows and equity) and thus could be provided. See the Editor's note at the beginning of SEC 3185 regarding the possibility that a registrant would have to provide audited transition period financial statements in connection with a Securities Act registration statement earlier than the due date of the next Form 10-K.
See SEC 3185.5 regarding requirements for disclosures relating to the comparative transition period of the prior year.
[Editor's note: If Company Y had elected to file its transition report on Form 10-K, the guidance in SEC 3185.2 should be considered.]
.4 Transition periods of one month or less
.41 How does an SEC registrant report a transition period of one month or less?
Information for a transition period of one month or less does not need to be filed in a separate transition report if either:
- The issuer's first periodic report required for the newly adopted fiscal year is an annual report and separate audited financial statements for the transition period are presented; or
The issuer files with the first annual report required for the newly adopted fiscal year separate audited statements of comprehensive income and cash flows covering the transition period; and the first periodic report required to be filed for the newly adopted fiscal year is a Form 10-Q and the information for the transition period is included in such quarterly report (i.e., the financial statements for the transition period are separately presented in the first Form 10-Q). The information covering the transition period required by Form 10-Q, Part II and Form 10-Q, Part I, Item 2, "Management’s Discussion and Analysis of Financial Condition and Results of Operations," may be combined with the information regarding the quarter. However, the financial statements required by Form 10-Q, Part I, which may be unaudited, must be separately presented. See Exchange Act Rule 13a-10(d).
[Editor’s note: The financial statements covering the transition period should consider the requirements of S-X 3-04 and include a statement of changes in stockholder’s equity covering the transition period.]
A change from a fiscal year ending as of the last day of the month to a 52-53 week fiscal year commencing within seven days of the month-end (or vice-versa) is not deemed a change in fiscal year-end for purposes of reporting subject to Exchange Act Rule 13a-10 if the new fiscal year commences with the end of the old fiscal year. See SEC FRM 1365.7. See SEC 3185.901, regarding the requirement to report a decision to change fiscal year-end under Item 5.03(b) of Form 8-K.
See SEC 3185.5 regarding requirements for disclosures relating to the comparative transition period of the prior year.
.5 Comparative period information
.51 How is the comparative transition period financial information presented in a transition report on Form 10-K?
Exchange Act Rule 13a-10(b) requires that the report covering the transition period include statements of comprehensive income, cash flows, and equity, which may be unaudited, for the comparative transition period of the prior year. In lieu of presenting full comparative transition period financial statements, the registrant has the option of presenting specified line items from the statement of comprehensive income in a footnote, which may be unaudited. The following is an example footnote described by Exchange Act Rule 13a-10(b) in the case of a 6-month transition period:
Note 18. Transition Period Comparative Data:
The following table presents certain financial information for the six months ended December 31, 2023 and 2022 respectively (amounts in thousands, except per share amounts):
Six Months Ended December 31, |
|||
2023 |
2022 (unaudited) |
||
Revenues |
$XXX |
$XXX |
|
Gross profits |
XXX |
XXX |
|
Income taxes |
XXX |
XXX |
|
Income from continuing operations |
XXX |
XXX |
|
Net income |
$XXX |
$XXX |
|
Earnings per common share (basic and diluted) |
$XXX |
$XXX |
|
Weighted average common shares outstanding (basic and diluted) |
XXX |
XXX |
|
If applicable, the effects of discontinued operations are also required to be disclosed.
.6 Quarterly reporting subsequent to a change in fiscal year
.61 What are the quarterly reporting requirements subsequent to a change in fiscal year?
The requirement to file quarterly reports on the basis of the new fiscal year begins with the first quarter in the new fiscal year (not the transition period) that ends after the issuer determined to change its fiscal year-end. See Exchange Act Rule 13a-10(e)(3).
Issuers have the option of filing Form 10-Qs for quarters that end in the transition period on the basis of either the old or new fiscal year. See Exchange Act Rule 13a-10(e)(2).
Issuers are required to file a quarterly report for any quarter of the old fiscal year that ended before the date of the issuer's determination to change its year-end on the basis of the old fiscal year, except where the last day of the quarter also is the last day of the transition period. See Exchange Act Rule 13a-10(e)(1).
The change in quarterly reporting from the old to the new fiscal year may result in a period of less than three months that is not covered by a separate report on Form 10-Q. Exchange Act Rule 13a-10(e)(4) specifies that unless such a period of less than three months is or will be covered in the issuer's transition report or in the first annual report for the newly adopted fiscal year, separate financial statements covering such period need to be included in the issuer's initial report on Form 10-Q for the newly adopted fiscal year. Consider the following example:
Facts: Company A is an accelerated filer with a fiscal year-end of December 31. On June 1, 2023, Company A decided to change its fiscal year end to October 31. Accordingly, the transition period will be from January 1, 2023 through October 31, 2023. Company A has the option of filing its Form 10-Qs during the remainder of the transition period based on either (i) the quarters of its old fiscal year (i.e., quarters ended June 30, 2023 and September 30, 2023) or (ii) the quarters of its new fiscal year (i.e., quarter ended July 31, 2023). Assume Company A decided to file during the remainder of the transition period based on the quarters of its new fiscal year. Accordingly, Company A will file its next Form 10-Q for the quarter ended July 31, 2023.
Analysis: As a result of Company A’s decision to use the quarters of its new fiscal year during the remainder of the transition period, the period from April 1, 2023 through April 30, 2023 would not be covered by a separate report on Form 10-Q. The statement of comprehensive income for the one-month period ended April 30, 2023 would be required to be included in Company A’s Form 10-Q for the quarter ended July 31, 2023 in addition to the statements of comprehensive income for the three and the seven-month periods ended July 31, 2023 and 2022, the statement of cash flows for the seven-month periods ended July 31, 2023 and 2022 and the balance sheets as of July 31, 2023 and December 31, 2022. See footnote 53 of SEC Release No. 33-6823.
[Editor’s note: The SEC’s guidance is not clear as to whether a statement of cash flows for the one-month period ended April 30, 2023 or comparative financial statements for the one-month period ended April 30, 2022 would be required.]
The note to paragraphs (c) and (e) of Exchange Act Rule 13a-10 indicates that when it is not practicable or cost-justifiable to include financial statements for comparative periods of the prior year in a transition report on Form 10-Q or in a quarterly report for the new fiscal year, financial statements may be included for the most nearly comparative quarters of the earlier year. In such cases the issuer is required to disclose:
- A discussion of seasonal and other factors that could affect the comparability of information or trends reflected.
- An assessment of the comparability of the data.
- A representation as to the reason recasting has not been undertaken.
.7 Reports following a change in fiscal year-end
.71 Has the SEC provided any examples of how periodic reporting works following a change in fiscal year-end?
Yes. Questions frequently arise about the appropriate manner of reporting following a change in fiscal year-end. Many of these include questions relating to reporting alternatives based on the date management determined it would make a change in year-end, or on the quarterly Form 10-Q reporting obligations and alternatives resulting from a change.
SEC FRP 102.05 includes several examples of typical reporting situations for an issuer that changes its fiscal year end. In all of these examples, it is assumed that the registrant is a domestic issuer and non-accelerated filer with a December 31 year-end date that files periodic reports pursuant to Section 13(a) or 15(d) of the Exchange Act.
[Editor’s note: For accelerated or large accelerated filers, the due dates would be adjusted to those applicable to their filing status. See SEC 3125. The due dates would also be adjusted for foreign private issuers.]
Although not addressed in these examples, the requirements regarding unaudited comparative financial information also need to be considered in each of the respective filings (i.e., unaudited statements of comprehensive income, cash flows, and equity for the comparative transition period of the prior year, or presentation of the specified statement of comprehensive income line items in an unaudited footnote). See SEC 3185.5.
.8 Foreign private issuers
.81 How does a foreign private issuer report a transition period under the Exchange Act?
The Exchange Act reporting requirements relating to a foreign private issuer’s change in fiscal year-end are discussed in Exchange Act Rule 13a-10(g). A foreign private issuer (see SEC FRM 6250) that elects to change its fiscal year-end date would fulfill its Exchange Act transition reporting requirements through filings on Form 20-F.
For transition periods exceeding six months, foreign private issuers are required to file a complete Form 20-F and include therein audited financial statements covering the transition period. This Form 20-F is due within four months after the later of (i) the close of the transition period or (ii) the date the determination to change the fiscal year is made. See Exchange Act Rule 13a-10(g)(3). The SEC staff will consider requests for a transition period of more than twelve months if a longer period is acceptable in the issuer's home country. Issuers which receive this accommodation are required to provide complete unaudited financial statements with all of the applicable disclosures for both the twelve-month period and the remaining portion of the transition period. Further, it will be necessary to provide audited financial statements for the entire period of more than twelve months. See SEC FRM 6250.2.
For transition periods of six months or less, but more than one month, the financial statements included in transition reports on Form 20-F need not be audited, and much of the textual information required by Form 20-F can be omitted. The transition report is due within three months after the later of (i) end of the transition period or (ii) the date on which the election to change the fiscal year is made. In these situations, the statements of comprehensive income and cash flows covering the transition period would need to be included on an audited basis in the first Form 20-F for the newly adopted fiscal year. See Exchange Act Rule 13a-10(g)(4).
When the transition period is one month or less, a separate transition report is not required if the first Form 20-F for the newly adopted fiscal year covers the transition period as well as the new fiscal year. The one-month transition period must be audited. See Exchange Act Rule 13a-10(g)(5).
See also SEC FRM 6250.1.
Foreign private issuers filing a registration statement after electing to change their fiscal year may need to provide more current audited financial statements than are required under the Exchange Act transition reporting rules. A foreign private issuer’s most recent audited financial statements cannot exceed the age specified by Item 8 of Form 20-F (generally 15 months) at the registration statement’s effective date. See SEC FRM 6250.3.
.9 Frequently asked questions
.901 Does an SEC registrant’s decision to change its fiscal year end from the last day of the month to a 52-53 week fiscal year (or visa versa) trigger an Item 5.03(b) Form 8-K reporting requirement?
Yes. An Item 5.03(b) Form 8-K is required to be filed in connection with a change from a fiscal year ending as of the last day of the month to a 52-53 week fiscal year or vice versa. This is true even though separate transition period reporting may not be required pursuant to Exchange Act Rule 13a-10. See Form 8-K CDI 218.01 and SEC 3185.4.
.902 How are pro forma financial statements prepared after a change in fiscal year-end?
See SEC 4560.909 for guidance relating to the preparation of pro forma financial statements following a change in fiscal year-end.
.903 How is significance (e.g., of an acquired business) evaluated after a change in fiscal year-end?
See SEC FRM 2025.6 for interpretive guidance relating to significance evaluations following a change in fiscal year-end.
.904 How do the change in fiscal year-end reporting requirements apply to a successor issuer?
A successor issuer that has a different fiscal year-end from that of its predecessor is required to file a transition report covering the predecessor for any transition period between the close of the fiscal year covered by its last annual report and the date of succession. The reporting requirements are the same as those for changes in fiscal year-end of registrants, except that the due dates of the required reports are determined based on the date of succession. See Exchange Act Rule 13a-10(f).
.905 Has the SEC staff provided any guidance for presenting executive compensation disclosure following a change in fiscal year-end?
Yes. See Regulation S-K CDIs 217.05 (relating to the summary compensation table) and 228D.01 (relating to pay vs. performance disclosure).
PwC. All rights reserved. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Each member firm is a separate legal entity. Please see www.pwc.com/structure for further details. This content is for general information purposes only, and should not be used as a substitute for consultation with professional advisors.
Link copied
