SEC Consultation on Semiannual Reporting

We refer to the Securities and Exchange Commission (SEC)’s request for comment on the proposed amendments to allow companies to file semiannual reports on new Form 10-S in lieu of quarterly reports on Form 10-Q to meet their interim reporting obligations under the Securities Exchange Act of 1934. We appreciate the opportunity to contribute our perspective.

Norges Bank Investment Management (NBIM) is the investment management division of the Norwegian Central Bank that manages the Norwegian Government Pension Fund Global. We work to safeguard and build financial wealth for future generations. As of year-end 2025, we managed over 2 trillion USD in assets, with the United States representing our largest market at 53% of total investments. Within our equity portfolio, 822 billion USD was invested in shares of 1,306 U.S. public companies. We are a minority shareholder in U.S. public companies, with an average equity ownership of 1.18 percent.

As a financial investor, we rely on companies' periodic disclosures to inform our investment decisions, risk management and shareholder voting. In our 2025 Asset Manager Perspective on corporate reporting frequency and long-term value creation (attached in Annex 2 to this letter), we set out how mandatory quarterly reporting and the associated pressure to meet short-term earnings guidance can encourage decisions that prioritize near-term results over durable investment and value creation. We believe a well-designed semiannual reporting framework can serve the interests of companies and investors alike, while preserving the transparency and accountability that capital markets depend on. We support providing companies with the option to report semiannually, subject to risk-based eligibility criteria, a well-governed transition process and measures to preserve the disclosure quality both in semiannual reports and between filings.

NBIM’s responses to selected consultation questions are provided in Annex 1 to this letter. We thank the Commission for considering our perspectives and remain at your disposal should you wish to discuss these matters further.

Yours sincerely

Carine Smith Ihenacho
Chief Governance and Compliance Officer                                                  

Snorre Gjerde
Policy Lead