Federal Register: SEC Provides Guidance on Compliance with Pay Ratio Disclosure Requirements

The SEC released interpretive guidance on compliance with the pay ratio disclosure rule, which mandates that companies begin filing reports in early 2018 for fiscal year 2017 (see previous coverage). Under the pay ratio disclosure rule, a public company is obligated to disclose (i) the median of the annual total compensation of all its employees, except that of the CEO, (ii) the annual total compensation of its CEO and (iii) the ratio of those two amounts.

The guidance was published in the Federal Register on September 27, 2017.

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