From Disclosure Reform to Rethinking Non-Competes: Regulatory Priorities Emerge

The SEC released its latest agenda, outlining both short- and long-term rulemaking priorities. Among them: proposed rule amendments to “rationalize disclosure practices” focusing on material information that will be useful to investors. 

What This Means: These are likely the rules we’ve been waiting for. We expect substantial changes to executive compensation disclosure, an area where the SEC has sought public comment and hosted a roundtable discussion in which Center CEO Ani Huang participated. 

• Anticipated changes could include reducing the number of NEOs, eliminating duplicative pay tables, simplifying the Summary Compensation Table and streamlining the CD&A.
• While the agenda lists April 2026 as the target date for action, these timelines are best seen as guidance—not guarantees—on when, or if, the SEC will move forward. 

In other news, the FTC announced a new approach to non-compete agreements and invited comments from stakeholders.

• The Commission will no longer defend, and will eventually rescind, the Biden-era rule prohibiting most non-compete agreements (the Biden rule was blocked by court order);
• The Commission issued a new request for information on how non-compete agreements unlawfully restrict competition.

Employer Takeaways: While a federal ban on non-compete agreements does not appear to be in play, the new Trump FTC has made it clear that it will target unfair labor practices generally and unreasonable non-compete agreements specifically.

• The Association will – once again- submit comments to the FTC outlining the importance of non-compete agreements for protecting investments in talent and proprietary information.