PwC's "New human capital disclosure rules: Getting your company ready" benchmarks Form 10-K human capital disclosures since the effective date of the new Reg. S-K rules and provides guidance to companies on two suggested Year 1 disclosure focus areas (COVID-19 and DE&I) given their likely impact on most companies in 2020.
Benchmarking observations based on 149 Form 10-Ks filed from the November 9 effective date include:
- 78% included both qualitative and quantitative metrics.
- 95% included disclosures related to COVID-19 and the impact to human capital, the majority of which were qualitative.
- 46% disclosed DE&I information (e.g., gender, sexual orientation, ethnicity, veteran status, culture, strategy, age, religion), much of which was qualitative. Many companies did not include measures or objectives related to management-level diversity. Quantitative metrics primarily included the total number of employees and gender percentages.
Additional noteworthy trends:

The instructive publication identifies various third-party sources of human capital metrics and standards companies may consider; offers sample metrics and disclosure topics; and suggests how companies may overcome common challenges of ensuring the reliability and consistency of any data determined to be disclosed.
See our recent reports: "Human Capital Resources Disclosure Benchmarking" and "Human Capital Disclosure Examples" and additional resources on our Human Capital/Workforce Management page. This post first appeared in the weekly Society Alert!