Issues In-Depth | February 2018

Non-GAAP financial measures

KPMG provides in-depth guidance on the SEC rules on non-GAAP financial measures, with examples and illustrative SEC comments. The guidance also includes the rules for foreign private issuers applying IFRS.


SEC Regulation G and Regulation S-K Item 10(e)

  • All registrants

Relevant dates

  • Effective immediately

Key impacts

Provides interpretive guidance on Regulation G,  Regulation S-K Item 10(e) and Instruction 2 to Item 2.02 Form 8-K. This includes:

  • Specific requirements and prohibitions applicable for public disclosures, SEC filings and furnished Form 8-Ks
  • Explanation of C&DIs and illustrative SEC comments based recent public filings
  • Additional considerations related to EBIT and EBITDA, segment disclosures, and REIT reporting
  • Exemptions available to foreign private issuers, including those applying IFRS
  • Management’s responsibilities related to non-GAAP financial measure disclosure and control procedures

Report contents

  • Background
  • The rules
  • The general requirements
  • Specific considerations
  • Earnings releases and similar announcement
  • Foreign private issuers
  • Controls and non-GAAP financial measures


Neil Johnson Yuan

Neil Johnson Yuan

Director, Audit, KPMG Hungary




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