On December 18, 2025, President Trump signed the Fiscal Year 2026 National Defense Authorization Act (NDAA), which includes Section 8103—the “Holding Foreign Insiders Accountable Act.” This legislation alters the compliance landscape for foreign private issuers (FPIs) listed in the United States by imposing insider reporting obligations under Section 16(a) of the Securities Exchange Act of 1934 on their directors and officers. Historically exempt from these requirements, FPI insiders must now prepare for filings on Forms 3, 4, and 5, all submitted electronically through EDGAR in English. The amendments to Section 16(a) take effect 90 days after enactment—March 18, 2026—and the SEC is expected to issue implementing regulations within the same timeframe. For more information, please see our Client Alert.