On August 25, 2022, the Securities and Exchange Commission (SEC) adopted Release No. 34-95607 implementing a final rule (Final Rules) that requires covered publicly traded companies to provide both tabular and narrative and/or graphical disclosure of the relationship between executive compensation “actually paid” (as defined) by the company to its named executive officers and the company’s performance over a specified time period (Pay Versus Performance Disclosure). The Pay Versus Performance Disclosure requirements apply to all publicly traded companies, except emerging growth companies, foreign private issuers, registered investment companies. As discussed in this article developed by Latham & Watkins, smaller reporting companies (SRCs) are subject to the Final Rules but are permitted to provide scaled disclosure. Check out this article to find out where the Pay Versus Performance Disclosure is required to be included and where its not and any other relevant details including key determinations and actions required.