Insights and Analysis

Cross-border SEC spotlight: Preparing the 2025 20-F

23 December 2025

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This end-of year Hogan Lovells Cross-border SEC spotlight provides an overview of recent developments, trends and topics that FPIs should bear in mind when preparing their annual report on Form 20-F for the fiscal year ending December 31, 2025 (the 2025 20-F).

The headline for this annual reporting season is that, although the U.S. Securities and Exchange Commission (the SEC) has made it clear that potentially significant changes to its disclosure regime may be forthcoming in 2026, there are no new Form 20-F disclosure requirements for the 2025 20-F. While there are no new requirements, during 2025 the staff of the Division of Corporation Finance (the Staff) issued interpretive guidance on Item 16F disclosures regarding changes in a company's certifying public accountant and clawback disclosures. This SEC spotlight examines this guidance, provides a reminder of recent updates to Form 20-F and summarizes recent disclosure trends that FPIs should consider as they prepare their annual report disclosures.

Click here to read our full end-of-year publication.

Authored by Richard Aftanas, Rupa Briggs, Ben Garcia, Jonathan Lewis, Alex Parkhouse, and Stephanie Tang.

Click here to read our full Q3 – October 2025 issue.

Click here to read our full Q2 – July 2025 issue.

Click here to read our full Q1 – April 2025 issue.

In an ever-evolving regulatory landscape, staying ahead of SEC rulemaking, disclosure requirements, guidance, and enforcement trends is critical. Through our newsletter, our team at Hogan Lovells will distill the latest updates into actionable insights, helping non-U.S. companies proactively manage compliance risks and market opportunities. Each edition will feature content from client alerts and tailored analyses from our seasoned practitioners, offering practical guidance on SEC compliance.

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