On June 30, 2025, the Securities and Exchange Commission’s (SEC) Division of Corporation Finance (the Division) revised two and eliminated one of its Compliance and Disclosure Interpretations (C&DIs) related to the disclosure of environmental proceedings under Item 103 of Regulation S-K. These changes updated Questions 105.01 and 105.03 pursuant to the August 2020 modernization of Items 101, 103, and 105. The Division also withdrew its previous guidance that administrative or judicial proceedings arising under “local provisions” in Item 103(c)(3) encompass environmental actions brought by a foreign government.

This post highlights key aspects of the Japan Freelance Act and compares them with relevant legal frameworks in the United States—particularly in California and New York—as well as in Europe with an aim to help businesses operating globally understand the important legal considerations when working with freelance workers across jurisdictions.