As the 2026 proxy season approaches, companies should be mindful of developments in required executive compensation disclosures and related issues that may arise as they prepare proxy statements. This alert surveys key developments and provides specific action items for companies to consider.

On November 10, 2025, the Environmental Protection Agency (EPA or the Agency) issued a proposed rule to revise the reporting and recordkeeping requirements for per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA).

On November 7, 2025, the U.S. Department of Defense announced a comprehensive overhaul of its procurement strategy named the “Acquisition Transformation Strategy” (ATS). The ATS envisions a wartime-oriented process that aims to prioritize rapid fielding to get equipment into the hands of warfighters, industrial-base expansion, and tighter coupling of requirements, resourcing, and acquisition execution. The accompanying directives signal a consequential restructuring of U.S. defense acquisition, requirements, and security cooperation processes as the Department aims to disestablish legacy joint requirements governance in favor of an integrated, budget-aligned model that is focused on speed, accountability, and mission outcomes. The new “Warfighting Acquisition System” will replace the existing “Joint Capabilities Integration and Development System,” creating both new opportunities and risks for federal contractors as they navigate shifting compliance expectations and material risk exposures in all aspects of the defense acquisitions process, including budget overruns, timely performance, and exportability of next-generation platforms.