Understanding S-1 Filings and SEC Review
PublicFinancial.com IPO Knowledge Hub Series
For many founders, the S-1 registration statement is the most intimidating part of going public. But it doesn’t have to be.
This guide explains what the S-1 filing is, why it matters, and how to prepare for the SEC review process — in plain English.
Key Founder Questions: S-1 Filing & SEC Review
1️⃣ What is an S-1 filing?
- The S-1 is your official IPO prospectus.
- It discloses detailed information about your business, financials, risks, leadership, and plans.
- Required whether you pursue an
IPO or a
direct listing.
2️⃣ What does preparing an S-1 involve?
Expect to disclose:
- Business overview and market opportunity.
- Historical financial statements (typically 2–3 years, audited).
- Risk factors.
- Use of proceeds (IPO only).
- Executive compensation.
- Ownership structure.
- Governance policies.
- Legal proceedings or contingencies.
Your legal, accounting, and banking teams will work together to draft the document.
3️⃣ How long does the SEC review usually take?
- Initial review: Typically 30 days.
- Comment rounds: 1–3 rounds, adding weeks or months.
- Total timeline: Most companies spend about 3 months from initial filing to approval.
4️⃣ Can we file confidentially at first?
Yes, under the
JOBS Act, qualifying companies (Emerging Growth Companies or EGCs) can file a draft S-1 confidentially.
Benefit:
- Allows review and comment without public disclosure.
- Limits public scrutiny until closer to the IPO or listing date.
5️⃣ What are the biggest disclosure and compliance issues?
- Accurate financial reporting.
- Full risk disclosure.
- Related party transactions transparency.
- Revenue recognition consistency.
The SEC will focus on clarity, completeness, and any red flags.
6️⃣ Are disclosures different for direct listings?
Generally no. The
S-1 content is almost identical for IPOs and direct listings.
7️⃣ What liabilities do we and our directors face?
- You (and your board) are legally responsible for the accuracy of disclosures.
- Misstatements can lead to
shareholder lawsuits or
SEC enforcement.
8️⃣ What are the stock exchange listing requirements?
Besides SEC approval, you must meet:
- NASDAQ or NYSE listing standards, including market capitalization, revenue or earnings minimums, and corporate governance.
9️⃣ Will we need to comply with Sarbanes-Oxley Section 404 immediately?
- Emerging Growth Companies often have a phase-in period.
- Full
SOX 404 compliance (auditor attestation of internal controls) will be required eventually.
Final Thought
The S-1 isn’t just a regulatory hurdle. It’s your chance to tell your story to the market.
A well-prepared S-1 can:
- Build investor confidence.
- Reduce SEC review delays.
- Prevent post-IPO surprises.
Next Step: Assess Your Filing Readiness
Preparing for an S-1 takes months. Contact PublicFinancial.com for an IPO readiness review, including a preliminary S-1 readiness assessment tailored to your company’s financials and growth story.