Form SD Filings

What Is SEC Form SD?

SEC Form SD is an important filing required under Sections 13(p) and 13(q) of the Securities Exchange Act of 1934. It is used by issuers to officially furnish specialized disclosure to the SEC relating to conflict minerals and, where applicable, payments made for the commercial development of oil, natural gas, or minerals.

This form is typically filed when an issuer is subject to the SEC’s conflict minerals rules or resource extraction payment disclosure rules. Once Form SD is submitted, it provides the required disclosure in the body of the form and, when required, includes a related exhibit report. Investors tracking the most recent SEC filing submissions often use these filings to review specialized disclosure obligations.

Form SD ensures transparency by formally notifying investors and regulators about specific supply chain and payment disclosures required under the Exchange Act. Depending on the rule that applies, the filing may include a Conflict Minerals Report or a Resource Extraction Payment Report. It can also be reviewed alongside other annual report filings to understand a company’s broader disclosure profile.

Key elements typically found in SEC Form SD include:

• Name of the issuer and period covered by the report
• Conflict minerals disclosure under Section 1, when applicable
• Conflict Minerals Report filed as Exhibit 1.01, when required
• Resource extraction payment disclosure under Section 2, when applicable
• Resource Extraction Payment Report filed as Exhibit 2.01, when required
• XBRL-tagged payment disclosure for resource extraction reporting, when required

SEC Form SD Filing Deadlines

SEC Form SD has specific timing requirements that issuers must follow depending on which disclosure rule applies. These deadlines are crucial to ensure regulatory compliance and provide proper notice to investors.

Key Things to Know About Form SD Filing Rules

• Applies to Specialized Disclosures: Form SD is not a general periodic report. It is used only for the specialized disclosure required by the SEC’s conflict minerals and resource extraction rules.
• Not Every Issuer Uses Both Sections: Some issuers file Form SD only for conflict minerals disclosure, while others may use it for resource extraction payment disclosure. In some filings, one section is marked not applicable.
• Exhibits May Be Required: If the applicable rule requires additional reporting, the issuer must include the corresponding exhibit, such as a Conflict Minerals Report or a Resource Extraction Payment Report.
• Different Reporting Periods Apply: Conflict minerals disclosure is based on the most recent calendar year, while resource extraction payment disclosure follows the issuer’s most recently completed fiscal year. Companies that use notifications for new SEC filings monitor both schedules separately.
• Electronic Filing Standards Matter: Form SD is filed on EDGAR, and resource extraction payment information must be provided in XBRL format when required by the form instructions and SEC rules.

SEC Form SD is part of the SEC’s specialized disclosure framework for conflict minerals and resource extraction payment reporting.