Introduction

In late August 2026, Merck published its 13th annual sustainability report, yet its PeopleReturn Transparency Score plummeted from 71.3 to 4.6. In contrast, AMD published extensive data tables on the same day, covering five years of workforce demographics, parental leave outcomes, training hours, and workplace safety. This divergence illustrates the central theme of the report: between 2020 and 2024, human capital disclosure reached historic peaks, but it has since entered a period of retreat. Currently, 50% of S&P 1500 companies disclosed less this year than last, while only 11.8% disclosed more.

The reports still come. They come later.

Nearly every large-cap company continues to publish an annual sustainability-related report, with publication rates for S&P 500 constituents holding at 91.6% for 2025. However, the reporting calendar has shifted significantly. Measured in early September, the percentage of S&P 500 companies that had published fell from 78.8% in 2024 to 69.8% in 2026. More reporting now lands in the final months of the year, with close to a fifth of the index reporting in the last third of the year. This indicates that while companies are still reporting, they are doing so later in the cycle.

The ESG label disappears

The branding of sustainability reports has changed drastically. The use of “ESG” in S&P 500 report titles fell from 35.3% in 2023 to just 5.9% in 2026. This collapse was rapid, with usage holding at 25.1% in 2024 before falling to 8.6% in 2025. Vocabulary has shifted toward “Sustainable” or “Sustainability”, which now appears in 47.2% of titles. The term “Impact” has also grown in popularity, appearing in 20.7% of titles today, despite having no regulatory definition or formal reporting framework.

What survived the retreat?

Operational metrics have proved durable during this retreat. Across the S&P 1500, overall turnover disclosure retained 96% of its peak prevalence, and overall new hires retained 92%. These figures describe workforce movement without identifying specific employees. Conversely, demographic detail has declined sharply. New hire reporting broken out by race and ethnicity fell from 16.6% at its peak to 7.6%, and gender-based new hire reporting fell from 27.0% to 16.5%.

The higher you look, the less you see

Disclosure rates decline as seniority increases within an organisation. Among S&P 500 companies, 78.6% disclose workforce gender representation, but this falls to 58.0% for leadership and 19.4% for executives. For race and ethnicity, representation disclosure drops from 70.0% at the workforce level to 12.4% for executives. Only 4.8% of S&P 500 companies provide a complete race and ethnicity breakdown for their executive tier. Age remains the most durable demographic category, retaining 85% of its peak prevalence.

What happens when a disclosure requirement disappears?

Board diversity disclosure was heavily influenced by the Nasdaq board diversity rule, which was vacated in December 2024. Following this, board gender disclosure among S&P 1500 companies fell from 95.1% in 2024 to 60.6% in 2026. Nasdaq-listed companies, which were previously more transparent in this area, saw gender disclosure drop by 63.8 points. Furthermore, the use of standardised reporting grids for board demographics fell from 89.8% of Nasdaq companies in 2024 to just 16.5% in 2026.

EEO-1: A decade of gains, undone in two years

Publication of EEO-1 reports, which provide intersectional workforce demographic data, peaked for report year 2023 at 72.2% for the S&P 500. For report year 2024, publication fell to 58.0%. The federal EEOC is currently moving to rescind Component 1 collection entirely. As voluntary publication without a common form lacks comparability, 2024 may be the final year that large U.S. employers can be compared on the same standardised terms.

The numbers left the filing

Quantitative workforce data is being removed from formal financial filings. In 2024, 59.2% of S&P 500 companies included at least one quantitative workforce metric in a 10-K or proxy statement; today, only 32.2% do. This represents a 46% decline in companies reporting such data in financial filings. While the SEC rule requiring human capital discussion remains in force, companies are increasingly replacing quantitative data with narrative descriptions.

Five years round trip

The PeopleReturn Transparency Score average for the S&P 1500 peaked at 32.9 and has now fallen to 21.4, which is below 2022 levels. Board composition changes accounted for 53% of this total decline. The retreat is most pronounced at the bottom of the market; 44.6% of Russell 2000 companies now score zero, compared to just 7.5% at the 2024 peak.

The movement was not uniform

The retreat started at the top, with some of the most transparent companies showing the largest declines. General Motors fell from a score of 70.7 in 2024 to zero today. Merck fell from 71.3 to 4.6. However, roughly one in eight companies increased their disclosure. American States Water rose from 5.0 to 45.2 points, and Pool Corp increased from 15.5 to 47.0 points. Other gainers included Live Nation and Avis Budget Group, which both gained more than 18 points.

Conclusion

The convergence of investor demand, SEC guidance, and exchange requirements that drove transparency between 2020 and 2024 has weakened. While companies continue to publish sustainability reports, the volume of data and its comparability have separated. For investors and stewardship teams, comparing companies on human capital measures is becoming increasingly difficult as standardised datasets and quantitative disclosures are withdrawn.