Financial Services Council Disclosure Working Group: Sixth Meeting Minutes
Overview
At the sixth meeting of the Financial Services Council’s Disclosure Working Group, the Japan Investor Relations Association reported on disclosure practices at listed companies and examples from overseas companies. NBIM explained its analysis of disclosure materials from six Japanese companies and others. The reports identified duplication as the number of disclosure channels grows, the need for more specific information and stronger links to financial information, and the timing of information provided before shareholder meetings as key issues. Committee members expressed differing views, including making annual securities reports the core disclosure document, dividing responsibilities between statutory and voluntary disclosure, and taking practical burdens and assurance responsibilities into account.
Key points
- The presenters identified overlap and increasing complexity among disclosure channels, the specificity and connectedness of information, and the timing of information provided before shareholder meetings as challenges.
- NBIM analyzed six Japanese listed companies and four overseas companies, comparing the number of documents and risk disclosures, among other items.
- Committee members offered differing views on making annual securities reports central, dividing roles with voluntary disclosure, eliminating duplicate information, and reviewing disclosure timing.
Overview
At the meeting, the Japan Investor Relations Association explained its survey of IR activities and disclosure examples from companies in the United States, Europe, and the United Kingdom, while NBIM reported an analysis using disclosure materials from Japanese and overseas companies.
The Japan Investor Relations Association said that expanded disclosure had increased the volume of information, while overlap between channels remained; improving disclosure quality and organizing, consolidating, and integrating channels were also issues for consideration. NBIM cited information quality and timely access for investors, and reporting efficiency for issuers, as areas for improvement.
Details
The Japan Investor Relations Association’s 2026 survey covered all listed companies and was conducted from February 9 to March 25; 948 companies responded. The percentages were calculated using the 917 respondents that conducted IR activities as the denominator. The latest IR tools survey data are from 2025: 80.8% produced presentation materials, while 51% produced integrated reports in Japanese and 46.2% in English.
In NBIM’s analysis, six companies listed on Japan’s Prime Market issued 7 to 17 individual documents a year, with 5 to 12 instances of overlap identified per company. There were 32 cases across all companies in which important information appeared outside statutory disclosure documents; nine of these appeared only in notices of convocation for shareholder meetings. Of 103 risk factors, 56% were judged to be generic. Links between sustainability information and financial or management information were barely evident for both the six Japanese and four overseas companies.
NBIM presented as examples for consideration a framework for locating important information in statutory documents such as annual securities reports, use of investor guides, references to notices of convocation for shareholder meetings, more specific risk disclosures, and links between sustainability information and financial reporting. It also raised a proposal to move the record date about three weeks later than the fiscal year-end and file annual securities reports at least three weeks before shareholder meetings. These were explained as the presenter’s personal analysis, not as official proposals.
Committee members’ views included support for consolidating disclosure in annual securities reports and making them central, as well as calls for careful consideration of the division of roles with voluntary disclosure, the scope of audit assurance and legal responsibility, and companies’ preparation burdens. On filing reports earlier, members said this should proceed alongside rationalizing disclosure content, while others argued that the assumptions about shareholder meeting schedules should be maintained.