As early as the 2016 proxy season, most U.S. public companies may need to include new disclosures, and should start thinking about them now.

On April 29, 2015, the Securities and Exchange Commission (the SEC) proposed rules that would require companies to include a new Pay versus Performance (PvP) table in proxy and information statements. The table will show the amount of compensation paid to the company’s principal executive officer (PEO) (typically the CEO) and its other named executive officers (NEOs), cumulative total shareholder return (TSR) and TSR of a peer group over each of the five most recent fiscal years (three years for smaller reporting companies). The rules would also require companies to use the values presented in the table to describe the relationship between executive compensation and the company’s performance, and between the company’s performance and its peer group’s performance. The rules would add a new Item 402(v) (the Proposed Rules) to Regulation S-K and would implement Section 14(i) of the Securities Exchange Act of 1934, as amended (the Exchange Act), as added by Section 953(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Proposed Rules will be subject to comment for 60 days after publication in the Federal Register (likely this week), and may be effective as early as the 2016 proxy season.