The New Human Capital Disclosures in Form 10-Ks of Large and Small S&P 500 Companies

Abstract

Since 2020, the U.S. Securities and Exchange Commission has required a U.S.-listed company to describe its human capital (HC) management in Form 10-K to the extent such information is material to understanding its business. Instead of mandating the form or content of the disclosure or defining what HC is, the SEC relies on the registrants to use the principles-based approach in determining the details to be provided. The current research examined the HC disclosures of the 100 largest and 100 smallest S&P 500 companies to study the nature and level of the disclosures in their Form 10-Ks. The results showed that different companies disclosed different HC attributes under a variety of themes. There was a lack of quantitative details in most companies’ disclosures, and there was a significant disparity in the amount of information provided and the level of emphasis placed on the different HC attributes and themes by different companies. Company size was positively associated with some themes of HC disclosure but negatively associated with a few other themes.