Form 18-K.SupportingStatement.Final.2025

SUPPORTING STATEMENT
FOR THE PAPERWORK REDUCTION ACT INFORMATION COLLECTION
FOR FORM 18-K

A.

JUSTIFICATION
1.

Circumstances Making the Collection of Information Necessary

One of the purposes of the Securities Exchange Act of 1934 (the “Exchange Act”)
is to help ensure that secondary markets for publicly traded securities are fair and honest.
One method by which the Exchange Act carries out this purpose is by requiring issuers
that have securities listed on a national securities exchange to file periodic reports with
the Commission. Issuer periodic reporting requirements are prescribed by the Securities
and Exchange Commission (“Commission”) pursuant to its authority in Section 13(a) of
the Exchange Act. The Commission exercised its authority under Section 13(a) to
establish a periodic reporting system for foreign governments and political subdivisions.
The system is only applicable with respect to issuers with securities registered on national
securities exchanges under Section 12(b) of the Exchange Act. Form 18-K (17 CFR
249.318) is an annual report that is filed by foreign governments or political subdivisions
of foreign governments that have securities that are listed on a national securities
exchange.
2.

Purpose and Use of the Information Collection

Form 18-K elicits disclosure of information concerning the listed securities of a
foreign government or political subdivision of a foreign government, including external
and internal debt, receipts and expenditures, foreign exchange controls, imports and
exports, and balance of payments. A copy of the issuer’s latest annual budget is required
to be filed as well. In requiring such information, Form 18-K helps to ensure that relevant
information about the issuer is available and updated annually and can help to confirm
the accuracy of previously disclosed information.
3.

Consideration Given to Information Technology

Form 18-K is filed electronically using the Commission’s Electronic Data
Gathering, Analysis and Retrieval (“EDGAR”) system.
4.

Duplication of Information

Although the statistical data published by each foreign government differs from
country to country, the Commission is not aware of any government that issues securities
in this country that does not make public the data required by Form 18-K. The form,
however, presents the data, otherwise available from a variety of sources, in one cohesive
document.

5.

Reducing the Burden on Small Entities

Form 18-K is not filed by small entities because it is an annual report form filed
by foreign governments or political subdivisions of foreign governments with securities
listed on a United States exchange.
6.

Consequences of Not Conducting Collection

Form 18-K is required to be filed annually. Not requiring Form 18-K to be filed,
or requiring it be filed any less frequently, would deprive investors of the information
protection of the Exchange Act with respect to listed securities of foreign governments or
political subdivisions thereof.
7.

Special Circumstances
There are no special circumstances.

8.

Consultations with Persons Outside the Agency

No comments were received for this request during the 60-day comment period
prior to OMB’s review of this submission.
9.

Payment or Gift to Respondents
No payment or gift to respondents.

10.

Confidentiality
Form 18-K is a public document.

11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be
required under this collection of information. The information collection collects basic
Personally Identifiable Information (PII) that may include name, job title, work telephone
number and work address. However, the agency has determined that the information
collection does not constitute a system of record for purposes of the Privacy Act.
Information is not retrieved by a personal identifier. In accordance with Section 208 of
the E-Government Act of 2002, the agency has conducted a Privacy Impact Assessment
(PIA) of the EDGAR system, in connection with this collection of information. The
EDGAR PIA, published on March 6, 2025, is provided as a supplemental document and
is also available at https://www.sec.gov/privacy.

2

12.

Estimate of Respondent Reporting Burden
Estimated Reporting Burden
Information
Collection
Title

OMB Control
Number

Number of
Responses

Burden
Hours

Form 18-K

3235-0120

37

296

For purposes of the Paperwork Reduction Act (“PRA”), we estimate that Form
18-K takes approximately 8 hours per response to comply with the collection of
information requirements and is filed once per year by an average of 37 respondents
annually, for an average total of 37 responses annually (calculated for the period 2022
through 2024). We further estimate that 100% of the collection of information burden is
carried internally by the issuer. Thus, we estimate the total annual reporting burden to be
296 hours (8 hours per response x 37 responses).
We derived our burden hour estimates by estimating the average number of hours
it would take an issuer to compile the necessary information and data, prepare and review
disclosure, file documents and retain records. In connection with rule amendments to the
form, we occasionally receive PRA estimates from public commenters about incremental
burdens that are used in our burden estimates. We believe that the actual burdens will
likely vary among individual companies based on the size and complexity of their
organization and the nature of their operations. The burden hours estimate is made solely
for the purpose of the PRA.
13.

Estimate of Total Annualized Cost Burden

We estimate that there is no cost associated with this information collection
because 100% of the burden is carried internally by the issuer.
14.

Costs to Federal Government

The SEC is in the process of revising its methodologies to estimate annualized
costs to the Federal government for all its relevant collections of information. The SEC
anticipates that future extensions of this collection of information will reflect the revised
methodologies.

3

15.

Reason for Change in Burden
Estimated Burden Hours Adjustment
Information Collection
Title

OMB Control
Number

Burden Hours
Adjustment

Form 18-K

3235-0120

(8)

The decrease in burden of 8 hours is due to a decrease in the estimated number of
Form 18-Ks filed with the Commission annually (from 38 to 37).
16.

Information Collection Planned for Statistical Purposes
The information collection does not employ statistical methods.

17.

Approval to Omit OMB Expiration Date

We request authorization to omit the expiration date on the electronic version of
the form. Including the expiration date on the electronic version of the form will result in
increased costs, because the need to make changes to the form may not follow the
application’s scheduled version release dates. The OMB control number will be
displayed.
18.

Exceptions to Certification for Paperwork Reduction Act Submissions
There are no exceptions to certification for PRA submissions.

B.

STATISTICAL METHODS
The information collection does not employ statistical methods.

4