Survey of Cybersecurity Disclosures in Annual Reports on Form 20-F Filed by Selected Well-Known Seasoned Issuers

October 7, 2024

We have developed this survey to provide information to our clients and other interested parties about cybersecurity related disclosures included in annual reports on Form 20-F. Our survey focuses on foreign private issuers registered with the U.S. Securities and Exchange Commission that have disclosed that they qualify as well-known seasoned issuers and that we understand have a market-cap of more than $25 billion.

The following charts reflect selected statistics that we believe provide useful information about cybersecurity disclosure characteristics and related governance practices. A list of the companies whose annual reports we reviewed is provided in Annex A.

On July 26, 2023, the U.S. Securities and Exchange Commission adopted final rules that require annual disclosure by public companies of their cybersecurity risk, management, strategy, and governance practices (Cyber Rules). These requirements apply to annual reports for fiscal years ending on or after December 15, 2023. For more information regarding the Cyber Rules, see our client briefing: SEC Adopts New Cybersecurity Disclosure Requirements for Public Companies.

For an analogous survey focused on cybersecurity related disclosures included in annual reports on Form 10-K filed by selected well-known seasoned issuers, see: Survey of Cybersecurity Disclosures in Annual Reports on Form 10-K Filed by Selected Well-Known Seasoned Issuers.

The cybersecurity related disclosures in the annual reports on Form 20-F covered by this survey varied more widely than equivalent disclosures in the annual reports on Form 10-K that we had previously surveyed, which could reflect regional market practices as well as different home country governance approaches.

Please contact Megan Gordon, Devika Kornbacher or another member of your Clifford Chance client service team if you would like to discuss this survey or have any related questions.

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