May 6, 2026
RE: Proposed Amendments to Permit Optional Semiannual Reporting by Public Companies File No.. S7-2026-15 Submitted by: Isaiah Owolabi, LL.M. (FinTech Law & Regulation) Founder and CEO, ESGine Originator, ESG-as-Code& Washington, DC. Email: io@esgine.io I want to start by saying I think this proposal is a step in the right direction. Quarterly reporting has created a rhythm that works well for some companies and feels like unnecessary overhead for others. Giving companies the flexibility to choose makes sense. But I want to flag something that I do not think has been addressed clearly enough in the proposal, and it matters a great deal for how companies interpret this change. Reporting frequency and disclosure obligations are two completely different things. One is about when you file. The other is about what the law requires you to say when you do. A company that switches from quarterly to semiannual reporting does not reduce what it has to disclose.. It simply consolidates those disclosures into fewer filing events. The legal obligations remain exactly the same. The clause does not move. Only the calendar does. I raise this because I have spent the past several years working at the intersection of law, technology, and ESG compliance. Through ESGine and ESG-as-Code, I have built a platform that evaluates ESG and climate disclosures against specific regulatory clauses across seven major frameworks including SEC Climate, CSRD, CARB SB253, CARB SB261, ISSB, UK FCA, and SFDR. The companies using it are not struggling with how often to report. They are struggling with knowing exactly what each regulatory clause requires and whether their disclosure actually satisfies it.. That is the harder problem. And it does not get easier with semiannual reporting. If anything it gets more concentrated because everything that would have been spread across three quarterly reports now has to land correctly in one semiannual report. My concern is that some companies will read this proposal as a signal that the regulatory burden is easing. It is not. The burden is being reorganized. That is a meaningful distinction and I think the final rule should say so explicitly. I would respectfully ask the Commission to include clear language in any final rule stating that the election of semiannual reporting does not reduce, defer, or modify any substantive disclosure obligation under the federal securities laws. Companies need to understand that frequency is a business decision. Compliance is a legal one. I would also encourage the Commission to use this moment to highlight the importance of systematic, auditable compliance infrastructure. A company that can trace every disclosure to the specific regulatory clause that requires it is a company that can file quarterly, semiannually, or annually with confidence. That traceability is what regulators actually need to see. It is also what ESG-as-Code& was built to provide. I am happy to discuss any of this further if it would be helpful to the Commission staff. Respectfully submitted, Isaiah Owolabi, LL.M. (FinTech Law & Regulation) Founder and CEO, ESGine Originator, ESG-as-Code Washington, DC io@esgine.io x.com/IsaiahOwolabi_ esgine.io