Authored by:Eli Han and Lucia Chen
On February 27, 2026, the U.S. Securities and Exchange Commission (the “SEC”) adopted a Final Rule, which amends certain of its rules and forms to implement the requirements of the Holding Foreign Insiders Accountable Act (the “HFIA Act”). Specifically, the Final Rule requires directors and officers of foreign private issuers (“FPIs”) with a class of equity securities registered under Section 12 of the Securities Exchange Act of 1934, as amended (the “Exchange Act”) to report initial ownership of the FPI’s equity securities and any subsequent transactions involving the FPI’s equity securities pursuant to Section 16(a) of the Exchange Act. The new requirements will take effect on March 18, 2026.