It’s still very early in the 2026 proxy season—only 96 companies have filed proxies so far—but the direction of travel is already clear. The disclosure pullback we flagged last year is not only continuing, it’s accelerating across board diversity and broader human capital metrics.
Board Disclosures: Transparency Continues to Erode
PeopleReturn’s Board Transparency Score—which measures the extent to which companies disclose director demographic characteristics—declined sharply last year and continues to trend lower in early 2026. This pattern is consistent across indices and sectors.
So far this season, just 52.7% of companies have disclosed at least one quantitative measure of board diversity, down dramatically from 92.3% in 2024.
With no remaining mandatory disclosure requirement following the vacating of Nasdaq’s Board Diversity Rule—and limited pressure from major investors and proxy advisors—we expect this trend to persist. Notably, Glass Lewis is now the only major advisor that still explicitly references board diversity disclosure, leaving little external incentive for companies to reverse course.
Board Diversity: Progress Slows as Opportunity Shrinks
2024 marked an important milestone: white men became a minority on S&P 500 boards. However, that progress stalled last year. The share of new board seats filled by women and people of color fell to its lowest level since 2016, resulting in a modest decline in overall diversity at large companies.
Structural factors are reinforcing this slowdown. Board refreshment rates fell sharply, with Russell 1000 turnover at its lowest level since 2017. At the same time, stated commitments weakened: only 21% of Russell 1000 companies now maintain a commitment to a diverse slate of candidates (aka “Rooney Rule”), down from 40% the prior year.
Absent stronger refreshment or renewed commitments, we expect board diversity to stagnate—or modestly decline—again in 2026.
Human Capital Disclosure: A Broader Retreat
Disclosure retrenchment is not limited to the boardroom. Last year saw a decline in the number of companies publishing sustainability and/or human capital reports, with the pullback most pronounced among mid-cap companies.
The retreat from quantitative human capital and diversity metrics has been even more severe. PeopleReturn’s overall Transparency Score—covering board composition, workforce representation, employee development, and pay equity—fell across every index.
Workforce representation disclosure has been hit hardest. For many metrics, particularly at larger companies, transparency in 2025 was lower than it was in 2019, underscoring just how much ground has been lost as diversity has become a more politically sensitive topic.
EEO-1 Disclosure: Temporary Bounce, Structural Decline Ahead
To date, 54.4% of S&P 500 companies have disclosed their 2024 EEO-1 data, down from 73.2% for 2023. Based on historical timing patterns, we expect this figure to rise modestly—potentially approaching 60%—as more companies publish alongside sustainability or human capital reports. In just the past week, Cisco, Dollar Tree, and Northrop Grumman released their 2024 disclosures.
Looking ahead, however, the outlook is less encouraging. As regulatory scrutiny intensifies and investor pressure wanes, we expect EEO-1 disclosure rates to fall below 50% in 2026, mirroring the trajectory already underway in board diversity reporting.
Bottom Line
What began as selective retrenchment has evolved into a broad-based rollback of human capital transparency. With fewer mandates, reduced investor pressure, and declining voluntary commitments, companies are disclosing less—not more—about how they govern boards and manage their workforces. Unless external expectations change meaningfully, 2026 is shaping up to be a year of continued stagnation—or outright reversal—across board diversity and human capital disclosure.
What we’re reading:
- Amazon wants to know what every corporate employee accomplished last year Amazon has a new question for its corporate workforce: What did you get done last year? As part of this year’s performance review process, known internally as Forte, Amazon is asking corporate employees to submit three to five “accomplishments” that best reflect their work, according to people familiar with the matter and an internal guideline obtained by Business Insider. Employees are required to provide “specific examples” of what they delivered, along with actions they plan to take to continue growing at the company, the guideline added. (Business Insider)
- Human Capital Disclosure and Labor Market Outcomes: Evidence from Regulation S-K We examine the labor market consequences of the 2020 Regulation S-K requiring human capital disclosure in 10K filings. Using large-sample job-level data and a Generative Large Language Model (GLLM), we observe that public firms subject to the regulation increase their disclosure of diversity, equity, and inclusion (DEI) information in job postings relative to a matched sample of large private firms. The increase in job-posting disclosure is more pronounced among firms facing greater external pressure to increase their workforce diversity. These findings suggest a shift in demand for diverse candidates by public firms following the regulation. (Journal of Accounting Research)
- AI Can’t Touch These Skilled Trade Jobs. If Only Enough Humans Would Fill Them. Master engravers have etched the custom designs and lettering on Crane Stationery since the days of Paul Revere—who, according to company lore, was one of its first customers. Today, with just a dozen left and at least one set to retire this year, these tradespeople are disappearing. Artificial intelligence and automation aren’t the reason. It is because it is so hard to entice humans to learn the highly skilled precision craft. (Wall Street Journal)
- 2026 Sustainable Investment Outlook: 7 key trends for North America in the year ahead The landscape for the new year will likely be shaped by major themes that include a pragmatic focus on physical climate risk and adaptation, a heightened emphasis on labor and human capital, an increased interest in bringing sustainability and impact considerations to private markets, and the emergence of more sophisticated tools to evaluate the risks and opportunities in nature investing. (Schroders)
- Cisco’s Journey in AI Workforce Transformation One thing I hear consistently from business leaders is this: We believe in the promise of AI, but we’re still figuring out how to turn it into real business growth. At Cisco, this is the journey we’re on. Over the past 18 months, we’ve invested in AI tools and learning experiences designed to help people enhance their work and deliver measurable business results. To understand whether those investments are making a difference, the People & Communities team stepped back and asked a bigger question: When AI becomes integral to how our people work, how does it shape engagement, performance, and growth across Cisco—and what does that mean for the business? (Cisco)
- Convergence, Diversity, and Divergence: The Two Axes of Corporate Law and Governance Corporate law and governance has now divided along two axes, the axis of Internal Governance and the axis of Externalities Governance. A generation after “corporate governance” became a global phenomenon, we see an established a vocabulary of corporate governance mechanisms, norms, and behaviors on the axis of Internal Governance. Within the convergent framing standard of “investibility,” we can expect diversity that responds to local imperatives, including original and continuing ownership patterns and efforts by the State to shape corporate governance tools to promote the State’s economic and social policy objectives. But the major move in corporate law and governance over the past decade has been the development of a second corporate governance axis, Externalities Governance. (Columbia University – Law School/European Corporate Governance Institute (ECGI))
- DOJ Targets Corporate Diversity Programs Via the False Claims Act The U.S. Department of Justice (DOJ) issued policy memoranda in May and July of 2025 announcing a stated intent to investigate entities that accept federal dollars via contracts and grants while engaging in “race, ethnicity, or national-origin based preferences” in employment practices. These policies evidence the DOJ’s expanded use of the False Claims Act (FCA) to investigate and, in some cases, take action against companies whose DEI efforts are perceived to violate federal law. These policies are now beginning to take shape, as the DOJ has recently initiated multiple investigations into the DEI practices of several major companies that contract with or receive funding from the federal government. (Gentry Locke)
- Wall Street Eliminated 10,600 Jobs Last Year, Most Since 2016 The biggest US banks cut their combined headcount last year by the most in almost a decade as executives sought to keep a lid on costs through what’s typically the biggest expense line item. Efficiency is the name of the game on Wall Street these days. Most banks swelled their ranks during the pandemic-induced deal boom, only to have to cut jobs during a sharp slowdown beginning in 2022. More recently, the question has evolved into how artificial intelligence might replace humans. (Bloomberg)
- The Rationale for Stewardship Actions by Institutional Investors A Theory-of-the-Firm Perspective That Incorporates Human Capital This paper articulates mechanisms, boundary conditions, and propositions that clarify when and how stewardship enhances corporate legitimacy and competitiveness. Our contribution lies in incorporating human capital into the investor–manager–employee nexus and specifying deliberation as the process that reconciles value pluralism in globalized environments. (SSRN)