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Navigating DEI Disclosure amid Regulatory Shifts
Executive Summary: Strategic Navigation of DEI Disclosure Shifts (2022–2025) Overview Diversity, Equity, and Inclusion (DEI) disclosures in SEC filings evolved dynamically from 2022 to early 2025, driven by a variety of factors, including legal scrutiny, shareholder demands and numerous regulatory shifts. DEI disclosures have reached a pivotal moment. Once expanding as part of corporate governance […]
Neil McCarthy is Co-Founder and Chief Product Officer, Markus Hartmann is Chief Legal Development Officer, and James Palmiter is CEO and Co-Founder at DragonGC. This post is based on a DragonGC memorandum by Mr. McCarthy, Mr. Hartmann, Mr. Palmiter, Michael Weiksner, Jennifer Carberry, and Nicholas Sasso.
Executive Summary: Strategic Navigation of DEI Disclosure Shifts (2022–2025)
Overview
Diversity, Equity, and Inclusion (DEI) disclosures in SEC filings evolved dynamically from 2022 to early 2025, driven by a variety of factors, including legal scrutiny, shareholder demands and numerous regulatory shifts. DEI disclosures have reached a pivotal moment. Once expanding as part of corporate governance and ESG strategies, DEI statements are increasingly scrutinized and, in some cases, strategically reduced. This summary provides an overview of key trends shaping DEI narratives in SEC filings among a selected group of ten S&P 100 companies, equipping legal, compliance, and investor relations teams with data-driven insights to navigate this evolving landscape.
This report combines DragonGC’s disclosure analytics to examine the selected disclosures, identify trends, and provide practical examples to guide DEI disclosure strategies in 2025. The report also examines the regulatory and legal context of the shifting DEI landscape and summarizes the key drivers influencing corporate DEI disclosures.
