Survey of S&P 100 Insider Trading Policies in Year One of the SEC’s Insider Trading Exhibit Requirement
Client Alert | October 9, 2025
We hope that the survey offers valuable insights as companies prepare for their upcoming 2025 Form 10-K filings and consider reviewing and/or further refining their insider trading policies. In the meantime, your Gibson Dunn contacts are available to assist with any questions or provide further guidance.
This survey of the insider trading policies filed by S&P 100 companies over the past year follows
our September 10, 2024 client alert, Early Insights from Insider Trading Policies Filed by S&P 500 Companies under the SEC’s New Exhibit Requirement, which surveyed the policies of 49 S&P 500 companies filed as of June 30, 2024. As we previously reported, calendar year companies were required to file their insider trading policies as exhibits to their annual reports on Form 10-K and comply with the related disclosure requirements in their proxy statements for the first time during the 2024-2025 annual reporting season.
As discussed below, while most of the trends identified in our initial review of early-filing S&P
500 companies remain consistent, we have also seen companies continue to refine their policies to address recent legal developments. Importantly, while benchmarking can be useful, insider trading policies should be tailored to each company’s circumstances, so some observations may not apply to your organization.
Please contact a member of the Gibson Dunn team listed below with any questions about your specific policy.
Please click on the link below to view Gibson Dunn’s full alert.
Survey of Insider Trading Policies Filed by S&P 100 Companies
The following Gibson Dunn lawyers prepared this update: Mellissa Duru, Kriti Hannon, Elizabeth Ising, Thomas Kim, David Korvin, Stella Kwak, Brian Lane, Julia Lapitskaya, Nathan Marak, Sheldon Nagesh, Antony Nguyen, Jill Refvem, Annie Saunders, Andrea Shen, Meghan Sherley, Sherri Starr, Jack Strachan, Michael Svedman, Michael Titera, Hong Xuan Tran, Geoffrey Walter, and Cody Wong.
Gibson Dunn’s lawyers are available to assist with any questions you may have regarding the SEC’s announcement, or federal securities laws and regulations more generally. Please contact the Gibson Dunn lawyer with whom you usually work, the authors, or any of the following leaders and members of the firm’s Securities Regulation & Corporate Governance or Capital Markets practice groups:
Securities Regulation & Corporate Governance:
Elizabeth Ising – Washington, D.C. (+1 202.955.8287, eising@gibsondunn.com)
Thomas J. Kim – Washington, D.C. (+1 202.887.3550, tkim@gibsondunn.com)
Lori Zyskowski – New York (+1 212.351.2309, lzyskowski@gibsondunn.com)
Aaron Briggs – San Francisco (+1 415.393.8297, abriggs@gibsondunn.com)
Mellissa Campbell Duru – Washington, D.C. (+1 202.955.8204, mduru@gibsondunn.com)
Brian J. Lane – Washington, D.C. (+1 202.887.3646, blane@gibsondunn.com)
Julia Lapitskaya – New York (+1 212.351.2354, jlapitskaya@gibsondunn.com)
Ronald O. Mueller – Washington, D.C. (+1 202.955.8671, rmueller@gibsondunn.com)
Michael Scanlon – Washington, D.C.(+1 202.887.3668, mscanlon@gibsondunn.com)
Michael A. Titera – Orange County (+1 949.451.4365, mtitera@gibsondunn.com)
Geoffrey E. Walter – Washington, D.C. (+1 202-887-3749, gwalter@gibsondunn.com)
Capital Markets:
Andrew L. Fabens – New York (+1 212.351.4034, afabens@gibsondunn.com)
Hillary H. Holmes – Houston (+1 346.718.6602, hholmes@gibsondunn.com)
Stewart L. McDowell – San Francisco (+1 415.393.8322, smcdowell@gibsondunn.com)
Peter W. Wardle – Los Angeles (+1 213.229.7242, pwardle@gibsondunn.com)
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Attorney Advertising: These materials were prepared for general informational purposes only based on information available at the time of publication and are not intended as, do not constitute, and should not be relied upon as, legal advice or a legal opinion on any specific facts or circumstances. Gibson Dunn (and its affiliates, attorneys, and employees) shall not have any liability in connection with any use of these materials. The sharing of these materials does not establish an attorney-client relationship with the recipient and should not be relied upon as an alternative for advice from qualified counsel. Please note that facts and circumstances may vary, and prior results do not guarantee a similar outcome.