Description

AI technologies now contribute substantially to corporate performance and risk, but investors lack decision-useful information. Drawing on the SEC’s 2023 cybersecurity model, we propose a materiality-first AI disclosure regime: SEC guidance clarifying what is material; a dedicated AI-incident item on Form 8-K; a standing 10-K section on AI strategy, governance, risk, and dependencies; and SEC enforcement against AI-washing. We urge reversing 2012 JOBS Act changes that let large private firms avoid public reporting and registration. Focusing on material impacts – not abstract capabilities – will discipline AI deployment and improve market oversight.

Citation

Strauss, Ilan, O’Reilly, Tim, Rosenblat, Sruly, and Isobel Moure. “Governing AI Through SEC Disclosure.” Policy Brief.Social Science Research Council, October 2025. https://www.ssrc.org/publications/governing-ai-through-sec-disclosure-materiality-standards-and-incident-reporting-lessons-from-cybersecurity/