Harvard Law Study Finds Only One-Third of S&P 100 Companies Disclose Both Board AI Oversight Structures and Formal AI Policies

A Harvard Law School analysis of 2025 proxy statements from S&P 100 companies found that 54% disclose board-level AI oversight, but only one-third disclose both oversight structures and formal AI policies, revealing uneven governance practices across large US public companies. Of companies that do disclose board oversight, 63% assign responsibility to specific committees rather than the full board. The research also documents that US institutional investors are increasing expectations for formalized AI governance, with 46% favoring board or committee-based oversight mechanisms. For enterprise compliance teams, the findings establish a de facto market benchmark: companies lacking both a documented oversight structure and a formal AI policy are increasingly out of step with investor expectations and peer disclosure norms. Compliance and governance officers at public companies should assess current proxy disclosures against these emerging standards, particularly as the SEC and institutional shareholders intensify scrutiny of AI risk management disclosures.