New Insider Reporting Requirements for Foreign Private Issuers Under the Holding Foreign Insiders Accountable Act

Overview - On December 18, 2025, the Holding Foreign Insiders Accountable Act (HFIAA) was signed into law as part of the National Defense Authorization Act for Fiscal Year 2026. Effective March 18, 2026, the HFIAA requires directors and officers of foreign private issuers (FPIs) to report their equity ownership and transactions to the U.S. Securities and Exchange Commission (SEC) under Section 16(a) of the Securities Exchange Act of 1934, as amended (the Exchange Act), on Forms 3, 4, and 5.... By: Robinson & Cole LLP