Disclosure Rules: U.S. and EU Standards

In July 2010, the U.S. Congress passed Section 1504 of the Dodd-Frank Act, a measure requiring companies registered with the Securities and Exchange Commission (SEC) to publicly report how much they pay governments for access to oil, gas and minerals, country-by-country and project-by-project. The SEC is developing final rules to put the disclosure requirement into effect.

In October 2011, the European Commission issued draft directives requiring companies listed on EU stock exchanges and large private companies based in member states to disclose their payments to governments for oil, gas, minerals and timber, country-by-country and per project. After developing a final version, the European Parliament and European Council will send the measure to EU member states for implementation.

The EU's proposals were inspired by the U.S. law, and the reporting standards differ only slightly, but in material ways. What do these requirements look like side by side?