2025 Disclosures: Reframing the DEI Discussion
Once a marquee term in corporate reports, the acronym “DEI” has a new script. According to a new Orrick study on the first four months of public filings, 59% of S&P 500 companies changed or eliminated voluntary DEI disclosures in the 10-K. In many cases, companies are trading in DEI terminology for overarching statements about their commitments, values and culture.
Less is More: Use of the term “DEI” fell from 90% to 34%, year over year. While the vast majority (78%) still include at least one diversity disclosure, specific discussion on the following was reduced:
Diversity slate discussions (78% to 38%).
ERG references (40% to 26%).
Details on diversity goals (20% to 5%).
Details on pay equity initiatives (24% to 20%).
Only 19% removed all discussion of DEI.
DEI Metrics in Incentives: Less than a third (30%) of the Fortune 100 removed or replaced DEI metrics in incentive plans, often swapping them for other human capital metrics like employee engagement.
A similar number (29%) continued to use DEI metrics in 2025, while 41% did not disclose in either year.
This trend may intensify as most companies established their measures prior to the backlash.
In 2024, 50% of the Fortune 100 included a “mini DEI report” in their proxies – this year about half of those continued while just over half scrapped the report.
Same Message, New Vocabulary: While DEI as a label may be fading, the spirit lives under different banners. About 40% of companies continue to use the term diversity, while 76% use inclusion and smaller numbers use culture, belonging or equity.
The repackaging of diversity disclosures appears to be largely driven by today’s political and legal landscape rather than by investor sentiments or other stakeholder views.
According to a Conference Board report, whether firms double down on DEI or quietly revise their stance, consumers don’t seem to flinch as reputational scores remain steady.
Meanwhile, anti-DEI shareholder proposals are barely registering a pulse, with median support at 1.3% and largely championed by the same activist investor.
Megan Wolf
Director, Practice, HR Policy Association and Center On Executive Compensation
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