
Will Issuers Still Have to Provide Quarterly Reports if the SEC Moves to Semi-annual Reporting?
Scott Josefsberg, J.D. - Head of U.S. High Yield Research, Covenant Review
15 October 2025
Insights into SEC semi-annual reporting impact on high yield bond covenants, including:
- Regulatory Shift Explained: Understand the implications of President Trump’s proposal to replace quarterly SEC reporting with semi-annual requirements for issuers.
- Quarterly vs. Semi-annual Covenant Requirements: Explore document-by-document analysis showing how high yield reports covenants may still require quarterly financial disclosures, even with SEC rule changes.
- Flexibility in Public Company Covenants: See how some public company high yield bond covenants allow issuers to adapt to new SEC reporting rules.
- Tighter Credit Agreement Obligations: Learn why issuers with syndicated term loans are likely to remain bound by quarterly reporting requirements under their Credit Agreements, regardless of SEC changes.
- Customized Covenant Guidance: Discover the need for tailored legal and covenant reviews for each issuer, emphasizing the importance of professional analysis before making compliance decisions.
Executive Summary
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President Trump has recently called for an end to quarterly reporting for SEC filers and replacing it with semiannual reporting.
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In this report, we examine typical high yield Reports covenants and whether they would require continued quarterly reporting, even if the SEC enacts new rules requiring only semiannual reporting. For public issuers, we also compare the high yield Reports covenant to the corresponding provisions in the issuers’ credit agreements.
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There is variation in high yield Reports covenants that will require document–by–document analysis of whether any particular issuer would be required to continue to report on a quarterly basis to comply with their covenants.
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In general, Reports covenants of public companies might provide more flexibility to follow then current SEC rules on timing and information included in periodic reporting.
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For issuers that are also borrowers under syndicated term loans, the Credit Agreement Financial Statements covenant will likely still require the issuer/borrower to report financials on a quarterly basis.
Overview
President Trump has recently called for an end to quarterly reporting for SEC filers, instead replacing it with semiannual reporting. In light of this, subscribers have asked whether the Reports covenant for high yield bonds would typically require an issuer to continue to provide investors with quarterly reports, even if SEC rules move to 6–month reporting.
We have surveyed typical Reports covenants in high yield bonds for both public and sponsored companies, and found that the answer is not always clear. Whether an issuer would have to continue to provide quarterly reports will depend on the specific language of the Reports covenant for their bonds. However, generally speaking, public company Reports covenants may provide more flexibility for issuers to move to 6–month reporting if SEC rules are changed.