Five of the six Japanese companies an NBIM presenter examined filed their annual securities report between zero and seven days before their shareholder meeting. That finding, presented on 4 September 2026 to the Financial Services Agency's Disclosure Working Group, is the core of the sixth meeting's minutes, now published. The group is a body of the Financial System Council, and nothing in the minutes is a decision.
What NBIM found
The presenter represents Norges Bank Investment Management, which runs Norway's government pension fund. The presenter said the views were personal rather than NBIM's official position, and that the analysis was not a formal proposal. The sample was small: six Japanese prime-market companies from six sectors, compared with four overseas peers in autos and apparel, for which 51 disclosure documents were analysed.
The six Japanese companies issued between 7 and 17 separate reports a year, with 5 to 12 duplicated items each. NBIM counted 32 cases where information investors would want sat outside the statutory documents, nine of them only in the AGM convocation notice. Of 103 risk-factor items, 56% were generic enough to fit another company in another industry.
On timing, the presenter said gaps of zero to seven days miss the internal decision deadlines of many institutional investors, and gave as an example NBIM's target of publishing its voting policy five days before a meeting. The presenter said a record date can only be used for a meeting within three months, and that many companies set it at fiscal year-end, so filings and meetings bunch together. Japan's 90-day filing deadline was the shortest of the six jurisdictions compared, against roughly 120 days elsewhere, where meeting deadlines run from 120 days to a year after year-end.
The option floated was to move the record date about three weeks after fiscal year-end, so the report could be filed three weeks before the AGM. The presenter also suggested the securities report anchor the system, with an investor guide for company history and strategy, and an English version of the securities report provided at the same time as the Japanese one.
Where members split
An absent member's written opinion, read out by the FSA's corporate disclosure division head, opposed any discussion premised on later AGMs. It argued that delay prolongs work on the prior year and crowds out the new one, and that cutting duplication should come before earlier filing.
A corporate member said filing three weeks ahead would in practice force companies to consider pushing the AGM back, and urged the FSA to specify items in the securities report that can be cut or simplified by year-end. Another member said the review should assume an AGM within three months of the fiscal year-end, noting few companies have moved their record dates. A legal scholar said holding meetings after three months is not legally barred. The minutes record no agreement.
The duplication evidence
The Japan IR Council, an investor-relations body with 733 members at the end of March 2026, supplied survey context. Of 948 companies responding to its survey, 917 ran IR programmes. In the 2025 round of its biennial tool question, 80.8% produced investor briefing materials, the most common tool. Integrated reports were produced by 51% in Japanese and 46.2% in English. The council's presenter said Japanese reports overlap heavily, while the US Form 10-K and proxy statement barely do. The presenter said that comparison came from a METI study group, not the council's own checks.
The minutes say the date of the next meeting will be announced later.