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On August 25, 2022, the Securities and Exchange Commission (SEC) finalized the Pay-Versus-Performance (PVP) Rule. This comes more than twelve years after Congress directed the SEC, as part of the Dodd-Frank Act, to require each issuer to disclose in any proxy or consent solicitation material information that shows the relationship between executive compensation actually paid and the financial performance of the issuer.

The PVP Rule applies to proxy statements filed for fiscal years ending on or after December 16, 2022. Although the PVP Rule will eventually require five years of disclosure for most filers, companies subject to the rule may disclose three years of data in their first proxy statement after the PVP Rule’s effective date. In this factsheet we outline what the PVP rule is, its reporting requirements and how it affects executive pay disclosure for companies.


Download our factsheet to learn more about:

  • SEC’s new Pay-Versus-Performance Rule
  • The PVP Rule disclosure table
  • Performance measures used to link compensation to amounts actually paid
  • Implications of the new regulation

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