Q2 2026 Quarter-End Reporting Checklist for Controllers

This checklist is for controllers and assistant controllers at calendar year-end public companies closing the books on June 30, 2026 and preparing to file Form 10-Q. Q2 2026 is not a standard quarter. Five converging pressures, tariff accounting uncertainty, the SEC's climate disclosure rescission limbo, the FASB's DISE standard, expanded cybersecurity iXBRL requirements, and a proposed shift to semiannual reporting, land directly on top of the standard close workflow. No single Big-4 publication maps all five into one actionable sequence. This one does.

Key takeaway: The Q2 2026 10-Q filing deadline for large accelerated filers and accelerated filers is August 11, 2026 (Monday), because the standard 40-day deadline falls on Sunday, August 9. Non-accelerated filers have until August 14, 2026.

Q2 2026 Filing Deadlines by Filer Status

Your hard deadline depends on your filer category. For calendar year-end companies, Q2 ends June 30, 2026. The 40-day window closes on August 9, a Sunday, so the effective deadline rolls to the next business day. The 45-day window lands on a Thursday and stays put.

Source: EY 2026 Form 10-Q Guide, Section 2.1

One practical trap: if your company recently crossed a public float threshold, confirm your filer status before locking the calendar. The SEC's proposed rule on EGC accommodations and filer status simplification (comment period closed mid-2026) could affect future determinations, but it does not change Q2 2026 obligations.

Phase 1: Pre-Close (Days 1-5 After Quarter-End)

General Ledger and Accounts Reconciliation

• Owner: Controller. Lock the sub-ledgers and pull the trial balance. Reconcile all balance sheet accounts to supporting schedules.
• Confirm all intercompany eliminations are posted and agreed across entities.
• Review period-end adjusting entries with a detailed sign-off checklist. As MagnaChip Semiconductor disclosed in its ICFR remediation, "implementing additional review of period-end adjusting entries with a detailed checklist, including the involvement of finance and operational executives" is a recognized best-practice control, and an audit committee expectation. (SEC EDGAR)
• Post depreciation, amortization, prepaid amortization, and accruals.
• Confirm revenue recognition cut-off under ASC 606 for any contracts with performance obligations spanning June 30.

Tariff Accounting Decision Gate

This is the most judgment-intensive step in Q2 2026. The tariff landscape shifted materially during the quarter: the CBP refund portal opened in April, the government filed an appeal of the IEEPA refund ruling in May, and Section 122 tariffs introduced a separate legal track. PwC's Q2 2026 Closing Statements (June 19, 2026) confirm the focus has shifted from "do we have a refund right?" to "how do we execute and account for it consistently?"

Work through these gates in order:

1. IEEPA refund receivable: apply your Q1 model consistently. If you recognized a receivable in Q1 under the legal framework or loss recovery model, apply the same model in Q2. Do not switch to a gain contingency model simply because the refund process has advanced. PwC is explicit: once a model is selected, it must be applied consistently.
2. Inventory carrying value (ASC 330). Have tariff costs increased the carrying value of inventory above net realizable value? If yes, a lower-of-cost-or-NRV write-down is required in the income statement, not a contingency disclosure.
3. Contingency accrual (ASC 450). Are there probable and estimable tariff-related losses not captured in inventory? If yes, accrue. If reasonably possible but not probable, disclose in the notes.
4. Section 122 tariffs. These are a separate legal track from IEEPA. Perform a separate analysis, do not assume the IEEPA accounting conclusion applies.
5. MD&A Item 303 disclosure. Whatever the accounting treatment, tariff impacts that are reasonably likely to have a material effect on future results require disclosure under Regulation S-K Item 303. This is where supply chain disruption, margin compression, and pricing strategy belong.

For the full disclosure framework, see What Your Q2 2026 Form 10-Q Must Say About Tariffs.

Goodwill and Long-Lived Asset Impairment Triggering-Event Assessment

Do this in pre-close, not the week before filing. Under ASC 350, an interim triggering-event assessment is required whenever events or changes in circumstances indicate that the fair value of a reporting unit may be below its carrying amount. Q2 2026 macro conditions, tariff-driven margin compression, equity market volatility, and rising discount rates, are textbook triggering-event indicators.

• Owner: Controller + FP&A. Document the triggering-event assessment for every reporting unit, even if you conclude no impairment test is required. The documentation is an audit expectation.
• Compare the reporting unit's carrying value to its estimated fair value using current market data (stock price, comparable transactions, DCF with updated discount rates).
• If a triggering event exists, initiate the quantitative impairment test before the auditor's interim review begins.

See ASC 350: Q2 2026 Goodwill Impairment Triggering Events for the full triggering-event checklist and disclosure requirements.

Phase 2: Close Week

Financial Statement Preparation (Regulation S-X Article 10)

• Owner: Controller. Prepare condensed interim financial statements per Regulation S-X Article 10. Use EY's decision diagram (Section 3.2.6 of the 2026 Form 10-Q Guide) to confirm which prior-period statements are required and in what form.
• Balance sheet: current quarter-end and prior fiscal year-end.
• Income statement: current quarter and year-to-date, with prior-year comparatives.
• Statement of cash flows: year-to-date with prior-year comparative.
• Statement of changes in stockholders' equity: year-to-date.
• Confirm per-share disclosures (basic and diluted EPS) are complete under ASC 260.
• If the company has guaranteed debt securities outstanding, prepare the subsidiary guarantor disclosures required under Regulation S-X Rules 13-01 and 13-02. These are consistently omitted from generic checklists and are a recurring SEC comment letter topic.

Non-GAAP Financial Measures

Heightened SEC scrutiny applies here, especially in Q2 2026. Companies are creating new non-GAAP measures to exclude tariff impacts, and the SEC's C&DI requirements apply to novel measures just as strictly as to established ones.

• Owner: Controller + IR. Reconcile every non-GAAP measure to the most directly comparable GAAP measure. The reconciliation must appear with equal or greater prominence than the non-GAAP figure.
• Confirm no non-GAAP measure excludes a recurring item without clear, consistent justification.
• If you introduced a new "tariff-adjusted" or "ex-tariff" non-GAAP measure in Q2, review the SEC's non-GAAP C&DI guidance before filing. A measure that cherry-picks tariff costs without symmetric treatment of tariff benefits will draw a comment letter.
• Review KPIs and other metrics disclosed under Section 2.12 of the EY guide for consistency with prior quarters.

Climate Disclosure: Three-Option Decision Framework

This is the disclosure decision that has no clean answer in Q2 2026. The SEC proposed to rescind its 2024 climate disclosure rules, the comment deadline has passed, and final action is pending. The original rules remain technically on the books, but the SEC has signaled it will not enforce them. Controllers face a genuine three-way choice:

• Owner: Controller + Legal + IR. Convene a decision meeting before the 10-Q is drafted, not after. The choice affects risk factors, MD&A, and financial statement notes simultaneously.
• If the company has California operations subject to SB 253 or EU operations subject to CSRD, removing climate disclosures from the 10-Q does not eliminate those obligations.

For the full legal and disclosure analysis, see SEC Climate Disclosure Rescission: What Controllers and SEC Reporting Teams Need to Know.

Phase 3: Post-Close, Pre-Filing

MD&A (Item 303 of Regulation S-K)

MD&A is where most SEC comment letters originate. Boilerplate liquidity and capital resources language is the most common target. Under Regulation S-K Item 303, the standard is disclosure of known trends, demands, commitments, events, or uncertainties that are reasonably likely to have a material effect on financial condition or results.

• Owner: Controller + FP&A + Legal. For Q2 2026, the highest-probability Item 303 topics are: tariff cost impacts and margin trajectory; supply chain disruption and inventory positioning; interest rate sensitivity on floating-rate debt; and any liquidity changes driven by the above.
• Liquidity and capital resources: quantify cash sources and uses. Do not simply restate the balance sheet.
• Results of operations: explain the drivers of revenue and margin changes, not just the amounts.
• If tariff impacts are material, the accounting treatment (ASC 330 write-down vs. ASC 450 accrual vs. contingency) determines where in the 10-Q the primary disclosure sits, and the MD&A must be consistent with the notes.

ICFR Item 4 Disclosure

• Owner: Controller + Internal Audit. Assess whether any significant changes in internal control over financial reporting occurred during Q2 2026 that have materially affected, or are reasonably likely to materially affect, ICFR. This is a required disclosure under Item 4 of Part I.
• Document the assessment even if the conclusion is "no significant changes." The documentation supports the CEO/CFO certifications and is an auditor inquiry point under AS 4105.
• If new systems, processes, or controls were implemented in Q2 (including AI-assisted controls), assess whether they constitute a significant change requiring disclosure. See SOX 404 Compliance Checklist for AI-Assisted Controls (2026).

Section 302 and 906 Certifications: Sub-Certification Process

Section 906 carries criminal penalties. The sub-certification chain must be documented before the CEO and CFO sign.

• Owner: Controller. Issue sub-certification memos to each business unit controller, regional CFO, and functional leader (legal, HR, treasury, tax) at least five business days before the filing deadline.
• Sub-certification memo should cover: (1) completeness and accuracy of financial data provided; (2) any known significant deficiencies or material weaknesses in ICFR; (3) any fraud involving management or employees with a significant role in ICFR; (4) any significant changes in ICFR during the quarter.
• Collect signed sub-certifications before presenting the 10-Q to the CEO and CFO for signature.
• Section 302 certifications require the CEO and CFO to confirm the 10-Q does not contain any untrue statement of material fact, the financial statements fairly present the financial condition and results of operations, and they have disclosed to the audit committee and auditors any significant deficiencies or material weaknesses. (EY 2026 Form 10-Q Guide, Section 2.4)

PCAOB AS 4105 Interim Review: Sequencing the Auditor

Filing before the auditor completes the interim review is a violation. PCAOB AS 4105, paragraph .03 is unambiguous: "The Securities and Exchange Commission requires a registrant to engage an independent accountant to review the registrant's interim financial information, in accordance with this section, before the registrant files its quarterly report on Form 10-Q."

The review consists principally of analytical procedures and inquiries, not an audit, but the auditor must evaluate management's assertions about ICFR changes. That means the auditor needs your ICFR Item 4 assessment, your sub-certification results, and any significant adjustments before they can complete their work.

• Owner: Controller + External Audit. Build the auditor's review completion into the close calendar as a hard gate, not an afterthought. A realistic sequence: sub-certifications complete by Day 25, draft 10-Q to auditors by Day 28, auditor review complete by Day 35, filing by Day 40.
• Prepare a package for the auditor's inquiries: significant accounting judgments made in Q2 (especially tariff models), any changes in accounting estimates, the triggering-event assessment, and ICFR Item 4 documentation.
• Note: the PCAOB AS 4105 amendment (effective December 15, 2026) updates paragraph .08 on audit committee communications. It does not apply to Q2 2026 filings, but controllers should brief the audit committee chair on the change before Q4.

Cybersecurity iXBRL Tagging (New for Accelerated Filers in Q2 2026)

If you are an accelerated filer, the cybersecurity iXBRL tagging requirement is new for you this quarter. It applied to large accelerated filers starting in Q1 2026. Accelerated filers join in Q2 2026. (EY 2026 Form 10-Q Guide, Section 2.2.1)

• Owner: Controller + XBRL provider. Confirm your XBRL provider has updated taxonomy mappings for cybersecurity disclosures (Item 1.05 of Part II, material cybersecurity incidents) using the CYD 2024 taxonomy.
• All 10-Q filers must tag financial statements in iXBRL under Rule 405 of Regulation S-T. Confirm standard financial statement tagging is complete and validated.
• If no material cybersecurity incident was disclosed in Q2 2026, confirm that the absence of an Item 1.05 disclosure is correctly reflected in the XBRL filing (no orphaned tags).
• Run the EDGAR XBRL validator before submission. A tagging error that delays filing can push you past the August 11 deadline.

For the full tagging workflow, see Cybersecurity iXBRL Tagging: Q2 2026 Form 10-Q Guide.

Forward-Looking Items: Start Now, File Later

DISE (ASU 2024-03): The "Start Now" Imperative

DISE is not a Q2 2026 filing requirement, but the data-gathering work needs to start this quarter. FASB ASU 2024-03 (Disaggregation of Income Statement Expenses) requires public business entities to provide significantly more detail about key income statement expense captions. It is effective for fiscal years beginning after December 15, 2026, meaning calendar year-end companies must first apply it in their 2027 annual 10-K. Early adoption is permitted.

As PwC's National Office warned in its Q2 2026 Closing Statements: "Implementation may be more complex than expected, and companies can start preparing their data, systems, processes, controls, and judgments now." (PwC, June 19, 2026)

Specific Q2 2026 actions:

• Owner: Controller + Systems/IT. Map your current expense caption structure to the DISE disclosure categories (employee compensation, depreciation, inventory and manufacturing costs, intangible asset amortization, selling costs).
• Identify data gaps: which categories require new GL codes, cost center mappings, or system queries that do not currently exist?
• Assess whether early adoption makes sense for your company. If you adopt early in the 2026 annual 10-K, you need the data infrastructure in place by Q4 2026 close.
• Flag DISE as a SAB 74 (Topic 11.M) disclosure candidate in Q2 2026 if the impact on future financial statements is expected to be material.

FASB Hedge Accounting Proposed ASU (June 17, 2026)

The FASB issued a proposed ASU on hedge accounting on June 17, 2026, with a comment deadline of August 17, 2026. The proposal would permit hedging of interest rate risk for held-to-maturity debt securities, amend the SOFR benchmark definition, and expand eligible net investment hedging instruments. (PwC, June 19, 2026)

• Owner: Controller + Treasury. Flag for treasury teams at financial institutions or companies with significant hedging programs. Comments are due August 17, two business days after the Q2 10-Q filing deadline.

SEC Semiannual Reporting Proposal: No Action Required for Q2 2026

The SEC's proposed rule to allow eligible filers to replace quarterly 10-Q filings with semiannual reporting has a comment deadline in mid-2026. It does not change Q2 2026 obligations. Every current registrant must still file a 10-Q for Q2 2026.

• Owner: Controller + Legal + IR. Track the proposal's progress and assess whether your company would be eligible and would benefit from opting in. See SEC Semiannual Reporting Proposal: What Changes for 10-Q Filers Who Don't Switch for the full analysis.

Q2 2026 10-Q Checklist: Owner and Timing Summary

FAQ

What counts as Q2 2026 for a calendar year-end company? Q2 2026 is the fiscal quarter ending June 30, 2026. For companies with non-calendar fiscal years, "Q2" is the second fiscal quarter, and the 40/45-day filing clock runs from that quarter's end date.

What is the GAAP checklist for a 10-Q? There is no single official "GAAP checklist", the standard reference is Deloitte's DART Financial Reporting Checklists, which are designed to help entities evaluate compliance with U.S. GAAP and SEC rules. Use these alongside the EY 2026 Form 10-Q Guide and PwC's Q2 2026 Closing Statements for quarter-specific issues.

What is the PwC disclosure checklist for Q2 2026? PwC publishes "Closing Statements: Quarter End Insights for Controllers" each quarter. The Q2 2026 edition (June 19, 2026) covers tariffs, SEC rulemaking proposals, and DISE implementation. It is available on PwC Viewpoint and is the most current Big-4 quarter-end guidance for this filing cycle.

Do I need to disclose climate information in my Q2 2026 10-Q? Not under the SEC's 2024 climate rules, which the SEC has proposed to rescind and has indicated it will not enforce. But voluntary climate disclosures that were included in prior filings create consistency expectations. The decision to retain, modify, or remove them requires input from legal, IR, and the controller before the 10-Q is drafted.

Does DISE require any Q2 2026 disclosures? No. ASU 2024-03 is effective for fiscal years beginning after December 15, 2026. Calendar year-end companies first apply it in their 2027 annual 10-K. However, if the impact is expected to be material, a SAB 74 disclosure in the Q2 2026 10-Q notes may be appropriate, and data-gathering work should begin now.

What happens if I file the 10-Q before the auditor completes the AS 4105 review? Filing before the interim review is complete violates PCAOB AS 4105, paragraph .03. Build the auditor's completion as a hard gate in your close calendar, targeting Day 35 at the latest for a Day 40 filing deadline.