What Disclosures Do the Fortune 500 Put in Their Annual Reports?

What Disclosures Do the Fortune 500 Put in Their Annual Reports?

April 25, 2024

Note: Originally published in Accounting Today.

Financial reporting is constantly evolving, shaped by global events, technological advancements, and regulatory changes.

As we dig into the 2023 annual reports of Fortune 500 companies, we discover that companies are increasingly prioritizing cybersecurity, executive compensation clawbacks, and more.

Cybersecurity Disclosures

On July 26, 2023, the SEC issued a final rule on cybersecurity disclosures, effective since December 2023, mandating that public companies disclose material information related to their cybersecurity risk management, strategy, and governance.

Per a review performed by Deloitte on Fortune 500 filers from Dec. 15, 2023, through Feb. 29, 2024, most companies included the following, while the details and specifics varied:

  • Incident response plans: Companies disclosed their formal incident response plans, which are crucial for managing cyber threats.
  • Employee training: Companies emphasized their regular cybersecurity training, including phishing exercises.
  • Vulnerability testing: Companies engage in penetration or vulnerability testing to assess their defenses.

Executive Compensation Clawback

On Oct. 26, 2022, the SEC issued a final rule on the clawback of executive compensation. This rule requires public companies to disclose and file their recovery policy as an exhibit with their annual report. They must also indicate by checkboxes if the financial statements in the annual report reflect a correction of an error to previously issued financial statements that triggered a recovery analysis, and disclose any actions taken because of the recovery analysis.

  • Clawback policies: Companies are increasingly disclosing their executive compensation clawback policies. These policies allow companies to recoup executive bonuses or incentives incases of financial restatements due to misconduct or errors.
  • Triggering events: Disclosures outline the conditions triggering clawbacks, the process for recovery, and the role of compensation committees in enforcing accountability.

Artificial Intelligence Transforming Business Models

As AI's transformative potential reshapes world markets, companies have added more disclosures surrounding their adoption of AI technologies.

  • Challenges and risks: Disclosures highlight the risks associated with AI, including bias, data privacy and ethical considerations (i.e., legal and compliance requirements such as those under the E.U. Artificial Intelligence Act)

Integrated Reporting Beyond the Numbers

Integrated reporting combines financial and non-financial information to convey a holistic view of a company's value creation. Key aspects in disclosures among the Fortune 500 included:

  • Materiality: Companies identify material non-financial factors (ESG metrics) that impact their long-term success.
  • Stakeholder engagement: Integrated reports engage stakeholders beyond investors, including employees, customers, and communities.
  • Sustainability goals: Companies communicate their commitment to sustainable practices and societal impact.

ESG Metrics

Disclosing environmental, social, and governance metrics is gaining prominence.

  • Environmental responsibility: Companies are reporting on carbon emissions, water usage, and waste management.
  • Social impact: Companies disclose diversity initiatives, employee well-being, and community engagement.

Climate-Related Disclosures

As climate change becomes a critical global issue, companies are providing granular disclosures on climate risks and opportunities.

  • Reputational risk: Companies discuss how environmental practices impact brand reputation.
  • Regulatory compliance: Companies address the effects of regulations like the E.U. Corporate Sustainability Reporting Directive and state-level climate laws.

In March 2024, the SEC announced its final rule for the Enhancement and Standardization of Climate-Related Disclosures. Public companies will be required to begin disclosing material impacts of climate risks and transition activities on their operations and financial statements.

While, according to a study issued in November 2023, 90% of the Russell 1000 already report on sustainability data, these rules will provide a more consistent guidance and reporting structure than what is currently occurring.

Tailored Disclosures Needed for Each Company

The 2023 annual reports reflect a shift toward transparency, sustainability, and strategic risk management. As investors and stakeholders demand more comprehensive information, companies must navigate these trends to build trust and resilience in an ever-changing world.

While these trends provide valuable insights, each company's disclosures should be tailored to its unique circumstances. For CPA consultants, consider advising your clients on effective reporting strategies that align with these evolving themes.