Four times a year, a listed drug company reports its results and then takes questions from Wall Street analysts on a call anyone can join. Nobody gets the questions in advance, and every answer stays on the public record for anyone to quote. Earnings call preparation is the three weeks of work before that call: guessing what will be asked, writing answers that say nothing beyond what the company has decided to make public, checking every number against the final release, and rehearsing the people who will speak.
This guide is for anyone who touches that work: investor relations teams at pharma and biotech companies, CFO and CEO offices, corporate controllers, securities lawyers, and leaders deciding whether to automate it. No background needed.
Imagine you are the head of investor relations at a large drug company, Northwind Bio. Your third-quarter call is on Thursday, October 29, at 8:30 am. It is Wednesday, October 7, and at 7:58 am a rival, Tarnwell Pharma, publishes late-stage (Phase 3) results for a once-daily pill in psoriasis, the market where your biggest medicine, Veltrimab, leads.
Yesterday, the question "how do you think about oral competition?" looked 44% likely and medium in stakes. This morning it reads "does a pill change your view of Veltrimab above $20 billion in 2030?", and it belongs near the top of your list. While you redo the answer, you open another draft. It says topline results, the first summary of a trial's main findings, from your ulcerative colitis study will arrive "in March 2027".
Draft answers
VLT-302 topline
March 2027
Veltrimab growth
up 26%
The record
Press release, Sep 14
first half of 2027
Release draft v7
up 24.1%
Two sentences to changeA month nobody decided to announceand a growth rate left over from the previous draft.
Careful preparation catches both before the CFO or the scientific chief says them to the whole market, and it moves the question that just became dangerous to the top while there is still time to rehearse it.
The earnings call Q&A: who asks, what the law covers, how questions get ranked and where answers go wrong
What happens on a results call, what Regulation FD and the rules around it require, how an investor relations team decides which question matters most, why drug companies have harder questions than most, and what changed in 2025 and 2026. If you have never seen an earnings call from the inside, start here.
01 · In plain words
What earnings call preparation is: three weeks of work for about 40 minutes of unscripted questions
A company whose shares trade on a US exchange reports its results every quarter. On the morning of the results it publishes a press release. An hour or so later its chief executive and chief financial officer join a conference call, read prepared remarks, and then take questions from sell-side analysts, the people at banks and brokers who publish research on the company for investors. Anyone can listen, and a transcript follows within hours.
The remarks are written and reviewed in advance. The questions are the risky part. An analyst may ask where sales of an aging medicine will bottom out next year, when exactly a trial will read out, or whether a rival's data changes a long-range target. The executive answers live, in front of the whole market, and the words are permanent. A loose answer can move the share price, set an expectation nobody meant to set, or give away something the company had decided to keep to itself.
So an investor relations team, or IR team, prepares. It reads every analyst note, re-reads the last few calls, guesses the questions and writes an answer to each in a document usually called the Q&A book. The controller, the company's senior accountant, checks each number against the latest draft of the press release, and the lawyers read for anything that goes past what the company has said in public. Then the executives rehearse, often with colleagues playing the analysts.
Most of that work sits in spreadsheets and Word files copied forward from last quarter, and the ranking of questions is usually an experienced person's instinct. It works until a rival's news lands a week before the call, or a release draft changes after the answers were written. Those are the moments this guide is mostly about.
From quiet period to transcript: one quarter's call in five steps
The quarter closesMany companies start a quiet period, limiting talk with investors until results are out. In the example, it starts on October 1.
Questions get predicted and answers writtenNotes, past calls and peer news become a ranked list, and each likely question gets a short spoken answer from the public record. This step is what this guide is about.
Finance and legal signEvery number ties to the final release draft, and every sentence that goes past the record is decided by a person. In the example, the disclosure committee, the group that considers what must be disclosed and when, meets on October 22.
Executives rehearseThe CEO, CFO and head of science practice answers aloud, against the clock, with follow-up questions. In the example, on October 20 and 26.
The release, then the callThe release goes out, the call opens to everyone, and what was prepared meets what is asked. In the example, 7:00 am and 8:30 am Eastern on October 29.
The company, people and dates in this example are fictional.
Why an open call is itself a lawful disclosure, and three more surprises about the Q&A
The law does not require a call at all
The US securities regulator, the SEC, said in May 2026 that federal securities laws "do not impose general duties" on reporting companies to publish earnings, hold earnings calls or give guidance, meaning a forecast of their own results.1 The call is custom, and the rules apply to how you run it.
Regulation FD mostly bites after the call
Regulation FD is the SEC rule against telling market professionals important news before everyone else. An open, announced call is a recognized way to tell everyone at once.2 The enforcement cases come from private phone calls, small meetings and social posts, usually when someone decides to help analysts with their numbers.3,4,5
Word-for-word answers can hurt you
A study of call transcripts found that sticking closely to a script when answering questions goes with a worse market reaction and weaker later results.6 The three IR officers interviewed in a Dutch study describe talking points and key data, and none of their companies scripts word-for-word replies.7
Nobody publishes how long the work takes
One survey write-up says earnings preparation can take "dozens of hours quarterly".8 We found no measured figure. The example in this guide uses a step estimate of about 150 hours a quarter for a large company. Treat it as a prompt to time your own.
Q&A book, material, tie-out, non-GAAP: four words this work runs on
Q&A book
The confidential document of likely questions and approved answers that executives use to prepare. It stays inside the company.
Material
Information a reasonable investor would see as significantly changing the total mix of what is available.9
Tie-out
Checking each number in a document against its source, one by one, usually the latest draft of the release.
Non-GAAP
An adjusted figure, such as adjusted earnings per share, that departs from standard accounting (GAAP, generally accepted accounting principles) and must be reconciled to it.10
How long earnings calls last, who speaks and how many analyst questions to expect
In shortExpect about an hour, with roughly two-thirds of it spent on questions. The best published count comes from 20 large Dutch companies: 64 minutes, nine analysts and about 19 questions. Older survey data from the US points the same way, with most calls running 46 to 60 minutes.
Published data on call structure is thin, so keep in mind how small these samples are. Researchers who timed the results calls of the 20 non-financial companies in Amsterdam's AEX index found an average of 64 minutes, from 35 to 95. The presentation took 23 minutes and the Q&A 41.7
A 2014 National Investor Relations Institute survey, as summarized by Davis Polk, found calls of 46 to 60 minutes at 68% of companies, with larger companies running longer.11 We found no newer public US figure, since the institute's later reports are for its members.
Questions take almost two-thirds of the average call
Minutes in the average results call of 20 large Dutch companies
Prepared presentationAnalyst Q&A
Average call, 64 minutes23 min41 min
Source7 · One market and one reporting season. US calls may differ.
Show the numbers
Prepared presentation
Analyst Q&A
Average call, 64 minutes
23 min
41 min
The same study counted an average of nine analysts on a call, from four to eighteen, and 19.3 questions, from 10 to 33. So 41 minutes of Q&A across 19 questions leaves about two minutes for each question, answer and follow-up, by our arithmetic. That is why a rehearsal card, the short prompt an executive practices from, holds a single opening line and a few numbers. Sell-side analysts ask most of the questions: 83% in the 2014 US survey.11
The CFO is always on the call, and IR speaks on most
Share of 20 large-company results calls with each person taking part
What analysts ask about on a results call, and what they get back
Of the 385 questions in that study, 41% were about financial items such as revenue, margins and cash flow, and the rest covered operations, strategy and governance.7 A larger study of conference call transcripts found that about 11% of analyst questions draw a non-answer, a rate that is stable over time and similar across industries. Harder, more negative and more detailed questions draw more of them, and questions about proprietary information do too.12
About one analyst question in nine gets a non-answer
11 in 100
analyst questions on conference calls draw a non-answer, according to a linguistic study of call transcripts
analyst questions on conference calls draw a non-answer, according to a linguistic study of call transcripts
11 of 100
A prepared non-answer is often the right answer. "We will give 2027 guidance in January, as we always do" tells the analyst nothing new and sounds like a policy. The skill lies in having that sentence ready, with the words the company has used before, so nobody improvises a number under pressure.
Who gets called on matters as well. Management picks from the queue. One study found that analysts with more favorable recommendations are more likely to get a question in.13 Another found that firms favoring bullish analysts tend to underperform later, with more negative surprises and restatements.14 A team preparing for a call should plan for the skeptics, and should call on them.
03 · The rules
What Regulation FD, Regulation G and the safe harbor ask of an earnings call, as of November 2026
In shortRegulation FD bars telling market professionals something material before telling everyone. An open call satisfies it, so the rule's force falls mostly on private conversations. Three other rules govern what you say on the call itself: Form 8-K's conditions for the call, Regulation G for adjusted figures, and the safe harbor for statements about the future.
Regulation FD, in force since October 23, 2000, says that when a company or someone acting for it discloses material nonpublic information to a broker, an adviser, a fund or a holder likely to trade on it, the company must make that information public. The disclosure must be simultaneous if it was intentional, and prompt if it was not.15
"Promptly" means as soon as reasonably practicable, and no later than the later of 24 hours or the next opening of trading on the New York Stock Exchange.16 So a slip noticed at 5:00 pm on a Friday could run to the Monday open.
The rule excludes people who owe the company a duty of trust, such as its lawyers and bankers, and people who expressly agree to keep the information confidential. It does not apply to foreign private issuers, non-US companies that hold that SEC status.15,16 Public disclosure can be a Form 8-K, the report a company files with the SEC when something significant happens, or any other method "reasonably designed to provide broad, non-exclusionary distribution".16
What the SEC itself says about open calls. The SEC's adopting release names "conference calls that interested members of the public may attend" as an acceptable method, and it describes a model: issue a press release, give notice of the call, then hold it openly so investors can listen.2 SEC staff say the notice should give the date, time, subject and call-in details, and that several days is reasonable for a regular quarterly call.17 A new fact said on such a call reaches everyone at once. What makes it dangerous is that nobody decided to say it, and that it may be wrong, incomplete or missing from the release.
The rules on earnings calls are old, and the newest change is still a proposal
1995Safe harbor for forward-looking statements
Oral statements are covered if they carry the right caution.
Oct 23, 2000Regulation FD in force
Selective disclosure barred; open calls recognized.
2003Item 2.02 and Regulation G
Results releases go on Form 8-K; adjusted figures need a reconciliation.
Apr 2022SEC staff on acquired R&D
Staff object to excluding acquired in-process R&D and upfront or milestone payments, BDO reports.
Apr 12, 2024Macquarie v. Moab
Pure omissions out of Rule 10b-5(b); half-truths stay in.
Form 8-K Item 2.02, Regulation G and the oral safe harbor on a live call
Rule
What it asks
What that means in the Q&A book
Form 8-K, Item 2.02(b)
No separate 8-K for the call if it comes within 48 hours after a release furnished to the SEC, is broadly accessible, has its figures on the website, and was announced by press release.23
A completed-quarter figure that appears only in an answer needs thought. Put the number in the release or on the website.
Regulation G
A public non-GAAP measure needs the comparable GAAP measure and a reconciliation. If spoken, this can sit on the website, with its location given in the same presentation.10
Each answer with an adjusted figure should point to the table. Never quote an adjusted measure the release does not reconcile.
Safe harbor, 15 U.S.C. 78u-5(c)(2)
An oral forward-looking statement must be identified as such, say results may differ, and point to a readily available written document with the risk factors.18
The opening statement usually covers this, so check that it does. It leaves out some situations, such as initial public offerings.18
Rule 10b-5(b)
The SEC's main antifraud rule: no untrue statement of material fact, and no half-truth. The Supreme Court held in April 2024 that pure omissions, silence with no misleading statement, are not actionable under this paragraph.20
Once you speak on a subject, say enough that it does not mislead. Silence and a partial story carry different risks.
Rule 13a-15
Disclosure controls that carry information up to the CEO and CFO in time for decisions.24
The SEC recommended a committee to consider materiality.25 The signed book is one record of those controls working.
The same sentence carries different risk depending on where it is said
An unannounced fact about the current quarter, by setting
LowSomeHigh
Regulation FDMisleading statementRegulation GRelease, then open webcast callLowSomeSomeUnplanned answer on the open callLowHighSomeCall-back with one analyst afterwardHighSomeSomeReviewing an analyst's model privatelyHighSomeLowOne-on-one at a broker conferenceHighSomeSomePost on an executive's own accountHighSomeSome
Our reading of the sources15,16,2,17,21,20 · Our classification of how the rules apply, for discussion with your counsel. It is general information.
Show the numbers
Regulation FD
Misleading statement
Regulation G
Release, then open webcast call
Low
Some
Some
Unplanned answer on the open call
Low
High
Some
Call-back with one analyst afterward
High
Some
Some
Reviewing an analyst's model privately
High
Some
Low
One-on-one at a broker conference
High
Some
Some
Post on an executive's own account
High
Some
Some
Three staff positions are worth knowing by heart. Confirming a prior forecast privately can itself be material, depending on whether it adds anything and how late in the quarter it comes.17 Going through an analyst's model, the spreadsheet forecast behind their estimates, is allowed for public facts and immaterial detail, but "may not" be a vehicle for passing along material nonpublic information.17 And the adopting release warns that a company "cannot render material information immaterial simply by breaking it into ostensibly non-material pieces".2
The quiet period before earnings: a custom each company defines
A quiet period is custom too. It is the stretch before results when a company limits its contact with investors. ICR, an IR adviser, notes that there "isn't a standard length" and that each company sets its own policy.26 Whatever you pick, write it down and keep to it.
04 · Selective disclosure cases
Seven Regulation FD cases, two of them at drug companies, and what each one teaches an IR team
In shortThe usual pattern is a private conversation, often near the end of a quarter and often about earnings, and in several cases a share price move follows. Penalties run from $50,000 for one person to $6.25 million for one company. Stand-alone cases are few, and we found none in 2025 or 2026. The drug company cases are about tone and about FDA.
The two drug company penalties sit far below AT&T's $6.25 million record
Penalty in dollars, selected settled SEC cases. First Solar's was paid by its former head of IR; the company was not charged
Private messages told sell-side analysts an FDA meeting was "very positive and productive". The stock closed up 19.4% the next day. A later call and email gave analysts undisclosed FDA detail. The SEC found the company had no Regulation FD policies. $200,000.4
An adjective about FDA can be material. The SEC's enforcement official said FDA interactions "can be critical to investors".
Schering-Plough, 2003
The chief executive conveyed a negative outlook in private meetings through tone, emphasis and demeanor. $1 million for the company, $50,000 for him.27
Tone sends a signal of its own. Rehearse the way an answer sounds as well.
AT&T, 2022
Three IR executives called analysts at about 20 firms with internal sales data so that forecasts would come down. $6.25 million for the company, $25,000 each for the three.3
Pushing Wall Street analysts' forecasts down in private, known as walking the Street down, is the classic violation. IR staff can be charged personally.
Flowserve, 2005
The chief executive reaffirmed guidance to analysts in a private meeting. $350,000 for the company, $50,000 for him.28
"Nothing has changed" can be news.
Office Depot, 2010
One-on-one calls hinted that the company would miss estimates. $1 million, plus $50,000 each for the chief executive and CFO.5
A hint counts.
First Solar, 2013
The head of IR signaled to about 20 analysts and investors that a loan guarantee was unlikely. He paid $50,000. The SEC did not act against the company, citing its cooperation, disclosure committee, press release the next morning and self-report.29
A working disclosure committee and a fast public fix count for a great deal.
DraftKings, 2024
The PR firm posted on the chief executive's personal accounts about strong growth before results were out. $200,000.21
Channels count. Before posting results news, check that investors have been told to watch that account.
These are settled matters, generally without admitting or denying the findings. A law firm's review of the AT&T case recommends written protocols, advance review of topics for one-on-one calls, and a process for unintentional slips.30
05 · The sources of a Q&A book
What may feed a question and what may feed an answer: analyst notes, transcripts, filings and release drafts
In shortA Q&A book reads two kinds of material and keeps them apart. Analyst notes, peer news and investor feedback tell you what will be asked. Filings, past calls, investor day decks and this quarter's release and remarks tell you what you may say. Mixing the two is how a broker's estimate ends up in an executive's mouth.
Think of it as two shelves. The first shelf predicts: a preview from a covering analyst often says outright what they will ask, and past transcripts show who keeps returning to what. The second shelf answers: anything already public, such as the annual report (Form 10-K), quarterly reports (Form 10-Q) and press releases, plus what will become public on results morning. A draft release sits on the second shelf with a date on it. It stays confidential until it goes out, but the answer will be spoken after that moment.
Only public or about-to-be-public documents should feed an answer
Each source of a Q&A book, by what it can be used for
NoSometimesYes
Predict questionsWrite answersTie out numbersSell-side notes and previewsYesNoNoInvestor feedback logYesNoNoPeer releases and callsYesNoNoOur past call transcriptsYesYesSometimes10-K, 10-Q and 8-K press releasesSometimesYesSometimesInvestor day decksSometimesYesSometimesThis quarter's release draftSometimesYesYesPrepared remarks draftSometimesYesSometimesInternal forecasts and board papersNoNoNo
Our reading of the sources2,23,10 · Our classification. Your disclosure policy and counsel decide.
Show the numbers
Predict questions
Write answers
Tie out numbers
Sell-side notes and previews
Yes
No
No
Investor feedback log
Yes
No
No
Peer releases and calls
Yes
No
No
Our past call transcripts
Yes
Yes
Sometimes
10-K, 10-Q and 8-K press releases
Sometimes
Yes
Sometimes
Investor day decks
Sometimes
Yes
Sometimes
This quarter's release draft
Sometimes
Yes
Yes
Prepared remarks draft
Sometimes
Yes
Sometimes
Internal forecasts and board papers
No
No
No
Sell-side notes carry a second constraint. They are usually licensed through a research aggregator, a service that collects brokers' research, under terms your team should read before copying them into any tool. They also carry the analyst's own estimates, and a company repeating an estimate may seem to endorse it. Using a note to learn the question and never to supply the answer solves both.
Public, public on results day, licensed, internal: four labels every source in the book needs
Label
Example
How it may be used
Public, with a date
Press release of September 14 furnished on Form 8-K; last quarter's transcript
Repeat word for word, above all for timings, guidance and erosion curves, which show how fast a medicine's sales fall once cheaper near-copies, called biosimilars, arrive.
Public on results day
Release draft v7; prepared remarks draft v5
Use in answers. Check the words against the final version. Keep the draft inside the company until release.
Licensed, read only
A sell-side preview from a research aggregator
Read to predict a question. Never quote it in an answer.
Internal
Forecasts, trial timelines, deal papers
Leave out. A sentence resting on this needs a disclosure decision first.
228 raw questions become 41 predicted and 16 worth ranking
In the example, from 19 notes, 8 of the company's own calls and 6 peer calls
Raw questions in the sources228
After clustering into one question each41
Ranked above 20% likely16
Still carrying a disclosure flag, 22 days out4
Fictional example from this guide · The other 25 go in the book's appendix.
Show the numbers
Stage
Questions
Raw questions in the sources
228
After clustering into one question each
41
Ranked above 20% likely
16
Still carrying a disclosure flag, 22 days out
4
06 · Ranking questions
How to rank analyst questions: probability against stakes, worked through on a rival's Phase 3 news
In shortA long list helps nobody. Put each question on two scales: how likely it is to be asked, and how much damage a poor answer does. Prepare hardest where both are high. Show what pushed each probability up, so a person can argue with it, and move the question when news changes the answer.
Probability comes from signals. An analyst writing "we will ask" is a strong one. A question asked on each of the last three calls is another. So are a peer's news and what investors told you in meetings. No standard formula exists, and no public study we found tests one for this purpose, so treat any percentage as a structured judgment. Its value lies in showing the reasoning.
Stakes come from what is exposed. Is there a public target at risk? Would a precise answer amount to new guidance? Is there a transaction, a legal matter or an undisclosed date nearby? A routine question on what drove the quarter's growth may be near certain and low in stakes. A question about a deal may be less likely and very high.
The Talvoren 2027 sales floor belongs in "prepare hardest"; a tax question can wait
Six questions from the example. Across: the probability on the screen. Up: an approximate placement of the three stakes levels. 340B is a US drug discount program
What a poor answer costs →
Careful wording
Prepare hardest
Appendix
Rehearse once
Talvoren floorNegotiationVLT-302Growth mix340BTax and FX
How likely it is to be asked →
Fictional example from this guide
Show the numbers
Item
How likely it is to be asked (0–1)
What a poor answer costs (0–1)
Talvoren floor
0.88
0.79
Negotiation
0.76
0.66
VLT-302
0.64
0.55
Growth mix
0.89
0.30
340B
0.39
0.34
Tax and FX
0.31
0.12
A worked example: what one rival's release does to two questions
At Northwind Bio, the question on oral competition sits at 44% and medium stakes on Tuesday. On Wednesday at 7:58 am, a watched peer reports Phase 3 data for a once-daily pill. Two things change. An analyst had written that if the data looked competitive, he would ask whether the $20 billion 2030 target still holds, so the likely wording changes and a public target is now on the line. Stakes go to high and probability to 82%.
The same release names pricing policy as the rival's main 2027 uncertainty, so the question on 2027 gross-to-net, the gap between a drug's list price and what the maker keeps after rebates, moves from 71% to 76%.
One peer release moves the oral question 38 points and the pricing question 5
Before the newsAfter the news
Oral competition, Q-1644%82%
2027 gross-to-net, Q-0571%76%
Fictional example from this guide
Show the numbers
Question
Before the news
After the news
Oral competition, Q-16
44%
82%
2027 gross-to-net, Q-05
71%
76%
The split of signals shows why. Before the news, 62% of the oral question's probability came from analyst notes and none from peer news. After it, peer news accounts for 56%. In points, that is 0.56 × 82, or about 46 of the 82, against about 25 from notes. The team can see that the jump rests on one event, and it can ask whether the event deserves that much weight.
After the news, one peer's release supplies most of the probability
What each signal adds to the oral competition question, as a share of its probability
Analyst notesPast callsPeer newsInvestor feedback
Before, at 44%62%18%20%
After, at 82%30%56%
Fictional example from this guide
Show the numbers
Analyst notes
Past calls
Peer news
Investor feedback
Before, at 44%
62%
18%
0%
20%
After, at 82%
30%
6%
56%
8%
Keep score after each call. Count how many of the questions asked were in your book, and how many of those you ranked highly. Those two numbers tell you whether your ranking is getting better, and they are easy to get from the transcript. We found no public benchmark for either, so your first quarter is your baseline.
07 · Writing the answer
Writing an answer from the public record: precision creep, stale numbers and non-GAAP traps
In shortTwo errors do most of the harm. Precision creep is a sentence one step sharper than anything said before: a month for a half-year, a floor for a curve. A stale number is one that survived a change in the release draft. Both are invisible unless you compare each sentence with its source.
Precision creep: when "first half of 2027" turns into "March 2027"
Writers want to be helpful, and a good writer knows internal plans. So drafts drift. Analysts also ask for exactly that extra step: "could it be the first quarter?" The Q&A book has to hold the line the company chose, because a month reveals the plan, narrows the market's expectations and can later be shown to be wrong.
Topic
The record says
The draft crept to
Why that is new information
Trial readout
"first half of 2027"
"March 2027"
A month is sharper than anything disclosed.
Biosimilar erosion
About 45% US erosion for 2026; 2027 guidance comes in January
"a further decline of about 45%, with a floor near $2.5 billion"
No 2027 figure is public, so this is new guidance.
Business development
"active across immunology, neuroscience and oncology"
"late-stage talks for an obesity asset"
A specific transaction is undisclosed and could move the shares.
Sentences from the fictional example.
Every sentence should answer the same five questions before the book locks
1Is it sourced?
It links to one public passage, or to this quarter's release or remarks.
WriterEach sentence
2Is it as sharp as the source, and no sharper?
Compare dates, ranges and adjectives with the passage.
ReviewerEach sentence
3Do the numbers tie?
Match every figure to the latest release draft.
ControllerEach new draft
4Is it about the future, or adjusted?
Forward-looking wording needs the caution; non-GAAP needs the table.
LegalEach sentence
5If not, who decides?
Use the public wording, or take a disclosure decision and say it everywhere at once.
It links to one public passage, or to this quarter's release or remarks.
Writer
Each sentence
Is it as sharp as the source, and no sharper?
Compare dates, ranges and adjectives with the passage.
Reviewer
Each sentence
Do the numbers tie?
Match every figure to the latest release draft.
Controller
Each new draft
Is it about the future, or adjusted?
Forward-looking wording needs the caution; non-GAAP needs the table.
Legal
Each sentence
If not, who decides?
Use the public wording, or take a disclosure decision and say it everywhere at once.
Counsel and committee
Before the lock
The arithmetic of a stale growth rate: why "up 26%" on $5.31 billion cannot be right
In the example, a draft answer says Veltrimab sales were "$5.31 billion in the quarter, up 26%". Release draft v7 says up 24.1%. A rebate adjustment arrived between drafts. The sentence mixes two drafts, and you can prove it. If $5.31 billion is 24.1% growth, last year's quarter was $5.31B ÷ 1.241, or about $4.28 billion. Growth of 26% on that base would be $4.28B × 1.26, or about $5.39 billion. That is $80 million of sales the release does not report.
Answer written against draft v6
Sales
$5.31B
Growth
up 26%
Implied sales at that growth
about $5.39B
Release draft v7
Sales
$5.31B
Growth
up 24.1%
Implied prior-year quarter
about $4.28B
Fictional example. The derived figures are our arithmetic on the sample's numbers.
A tie-out catches this when it treats a percentage as a number with a base, and when it runs again after every new draft. In the example the book holds 188 numbers across 41 answers. Each new release draft puts every one of them back in doubt until it is checked.
Adjusted earnings in pharma: the acquired R&D rule that changed in 2022
Drug companies buy pipeline assets, and they used to strip those costs from adjusted earnings. In April 2022, according to BDO, SEC staff said they would object to non-GAAP measures that exclude acquired in-process research and development (IPR&D) in an asset acquisition, or upfront and milestone payments under R&D arrangements, as "normal, recurring operating expenses for pharmaceutical companies".19 Bristol-Myers Squibb, for one, changed its non-GAAP results that quarter and cited comments from the SEC.31
So an answer on adjusted earnings per share has a specific trap: a deal's upfront payment now sits inside the figure, and analysts will ask you to explain it. Regulation G's bar on misleading measures applies to the discussion around the number as well.10
08 · Pharma's hard questions
Why biotech and pharma earnings calls are harder: trial timing, FDA letters, Medicare negotiation, tariffs
In shortDrug companies depend on events that go one way or the other, such as a trial result, and on government decisions. Analysts press for trial dates, for how a meeting with FDA went, and for what a negotiated price will do. Newer topics have joined them: complete response letters, which FDA has published since 2025, and tariffs and most-favored-nation pricing deals. Each topic has its own careful wording.
Topic
The status, November 2026
What to prepare
FDA interactions
A complete response letter is FDA's letter listing the deficiencies that stand in the way of approving a drug application. FDA said on September 4, 2025 that it will release new ones promptly after they are issued, redacted but with company names kept, so that sponsors give "complete and contextualized information" to investors.22 Debevoise advises assuming the letter will become public and reviewing earnings remarks against FDA's feedback.32
An answer you would be comfortable seeing next to FDA's own letter. Avoid adjectives about a meeting. Keep a record of what FDA said.
Trial data and timing
Materiality has no bright line. The Supreme Court held in 2011 that a lack of statistical significance does not by itself make information immaterial.9
Your exact public timing, in the words last used. A line for "has anyone seen the data?"
Medicare negotiation
Third cycle: 15 drugs named January 27, 2026; companies accept or reject final offers by October 31; CMS publishes agreed prices by November 30; prices apply January 1, 2028.33 We found no publication as of November 3.
What you have said in filings, and a firm line on not estimating before publication.
Tariffs and most-favored-nation pricing
A proclamation of April 2, 2026, under Section 232, the US national-security trade law, sets the tariffs on covered patented drugs charted below, with generics and biosimilars out. It applies from July 31, 2026, for the companies the proclamation lists, and from September 29, 2026, for all others.34 Twenty-six manufacturers had most-favored-nation deals, which tie US prices to those in other countries, by August 31, 2026, and the agreements themselves were not released.35 We found no update from October.
Where your US supply is made, in filed words. A decision in advance on how much of any deal you will describe.
Biosimilar erosion
No rule applies, and the question returns each quarter.
The curve you gave, unchanged, and the date of your next guidance.
Business development
In the US, no rule requires comment on talks in general, and pure silence differs from a half-truth under Macquarie.20
One sentence used every quarter, so that a change in wording never signals anything.
A late October call lands days before the Medicare negotiation closes
The real third-cycle dates. The example's fictional call is on October 29, 2026
That calendar explains why the example's card says "Do not estimate the 2028 impact". On October 29, the company may know more than the public does, and CMS must publish any agreed price by November 30. A careful answer repeats the filing, says when the price will be published, and stops.
A patented drug's tariff runs from 100% to 0%, depending on origin, onshoring and a pricing deal
Rates in the Section 232 proclamation of April 2, 2026, for covered patented drugs
Covered patented drugs, standard rate100%
Company with an approved plan to make drugs in the US (onshoring)20%
From the EU, Japan, South Korea, Switzerland or Liechtenstein15%
From the UK10%
Onshoring plan and pricing agreement, until January 20, 20290%
Company with an approved plan to make drugs in the US (onshoring)
20%
From the EU, Japan, South Korea, Switzerland or Liechtenstein
15%
From the UK
10%
Onshoring plan and pricing agreement, until January 20, 2029
0%
09 · What goes wrong
Nine ways earnings call answers go wrong, from a number off the last draft to a call-back nobody logged
In shortMost errors come from documents that went out of date, or from the time after the call when people relax. Sort them by how often they happen and how much harm they do, and the highest priorities are the ones a person cannot see by reading the draft alone: precision creep, stale numbers and private follow-ups.
Precision creep and private call-backs do the most harm for how often they occur
Our judgment from the enforcement record and the sources in this guide. No public study measures these rates
How much harm it does →
Rare, serious
Fix first
Watch
Tidy up
Call-backPrecision creepStale numberDeal talkNo reconciliationMissed newsWord for wordNo caution
A stale number. The answer predates the final release draft, and nobody re-checked percentages.
Precision creep. A sentence is sharper than the record, because the writer knew the internal plan.
An answer copied forward. Last quarter's words now conflict with this quarter's facts.
A rival's news handled by email. The question that became urgent last week has no rehearsed answer.
Quoting the Street. An answer repeats an analyst's estimate, or a note's text reaches an executive's card.
An adjective about FDA. "Very productive" can be material, as TherapeuticsMD shows, and FDA's letter may now be published.4,22
An unprepared call-back. After the call, analysts ring IR for "color". These are private conversations, where Regulation FD's limits bite. Staff need a rule for what may be said and a log of it.17,30
A slip nobody escalates. The clock for a non-intentional disclosure starts when a senior official learns of it, so a person has to know whom to tell.16
Reading the card aloud. Answers that follow a script closely can read badly to the market, so prepare facts and lines, and leave the sentences to the speaker.6,7
10 · The stakes
What a bad answer can cost a life sciences company: lawsuits, enforcement, share price and a leaked release
In shortDirect penalties under Regulation FD are modest. The larger exposure is a securities suit, and life sciences companies drew 47 of 207 federal filings in 2025. Plaintiffs' firms now scan calls with software. Draft results are also valuable inside information, and thieves have stolen them before.
47 of 207
federal securities class actions in 2025 named life sciences companies, over 22%.36
Dechert, March 2026
$6.25M
the largest Regulation FD penalty, and it came with $25,000 for each of three IR executives.3
SEC, December 2022
$100M+
in illegal profit alleged from trading on earnings releases hacked from newswires before publication.37
SEC, August 2015
Financial reporting and product claims lead the 2025 life sciences suits
Of 47 securities class actions against life sciences companies in 2025; a suit can fall in more than one group
Dechert advises that disclosure plans cover what executives say on analyst calls, and it notes that plaintiffs' firms use AI tools to scan earnings calls, so companies should audit their own statements.36 An answer about FDA timing is the kind of sentence that gets compared with later events.
Many of these suits do not survive: of 14 regulatory-hurdle decisions Dechert counted in 2025, 10 were dismissed in full. Defending one is still costly. We found no public figure for the cost tied to a single answer on a call.
The call also moves markets on its own. Researchers report that both the presentation and the Q&A give investors new information.7 The SEC noted in 2026 that markets generally react when information is first disclosed, and less when it is repeated.1 What your executive says in that hour is the first telling for anything the release left out.
The book itself is a target. It holds draft results, internal thinking and legal judgments. In the 2015 case, the SEC alleged hackers took earnings announcements from newswire services over about five years and fed them to traders.37 Any system holding release drafts needs access limits to match.
11 · What AI changes
AI for investor relations: where it already helps with earnings prep and where a person must decide
In shortAdoption rose fast. Surveys report anywhere from 42% to more than half of IR teams using AI. Teams mainly use it for drafting and research, and simulating analyst questions is the use practitioners back most in one survey. The limits: models misread financial documents, materiality stays a person's judgment, and a tool that reads draft results holds inside information.
6% → 42%
of IR teams using AI, in one year, among 223 respondents to Irwin's 2026 survey.38
Irwin, a FactSet company, 2026
2%
had no plans to use AI, while more than half had embedded it, up from 30% in 2024, among nearly 700 corporate professionals.39
Nasdaq Issuer Pulse, 7th annual
81%
of finance questions answered wrongly or refused by one leading model given search over the filings, in a 2023 test.40
FinanceBench, November 2023
Practitioners back AI most for simulating analysts' questions
Share agreeing, in the words of the write-up of one 2026 survey with no published sample size
Simulating investor or analyst questions, about three-quarters75%
Stress-testing messaging, about two-thirds67%
Benchmarking shareholder proposals, nearly 60%60%
Saw a dramatic change in IR, nearly 40%40%
Source8 · Rounded from the words the article uses.
Show the numbers
Use or view
Share
Simulating investor or analyst questions, about three-quarters
75%
Stress-testing messaging, about two-thirds
67%
Benchmarking shareholder proposals, nearly 60%
60%
Saw a dramatic change in IR, nearly 40%
40%
Task
What software does well
What stays with a person
Reading notes and transcripts
Pulls stated questions, concerns and estimates, with the page
Knows which analyst's words count
Ranking questions
Clusters raw questions, shows what each signal adds, re-ranks on news
Overrules the ranking and judges stakes
Drafting answers
Works from a closed set of documents and cites each sentence
Owns the message and approves it
Checking disclosure
Compares each sentence and number with the record, and flags differences
Decides materiality and every flag
Rehearsing
Asks in the analyst's style, times answers, adds follow-ups
Judges tone and speaks for the company
What regulators have said about AI in earnings preparation: very little so far
We found no SEC rule written for AI in investor communications. The existing duties apply whoever or whatever drafts: antifraud rules, Regulation FD, disclosure controls.
The life sciences rules you may hear about were written for other work, in our reading. FDA's January 2025 draft guidance concerns AI that supports regulatory decisions on drugs.41 Part 11, FDA's rule on electronic records, is tied to records required by its other rules, known as predicate rules.42
Draft EU GMP Annex 22, part of the EU's good manufacturing practice rules, concerns critical manufacturing uses, and it remains a draft: EudraLex Volume 4, which holds those rules, listed no Annex 22 on November 3, 2026.43,44 The EU AI Act's high-risk dates moved to December 2, 2027 and August 2, 2028.45 Ask your own counsel to confirm how each applies to you.
Three cautions follow from the evidence. FinanceBench is from 2023 and models have improved, yet it shows why every figure needs a check that does not depend on the model.40 As one practitioner in the Gladstone write-up put it, AI can "check the work product, not generate it", and the same write-up recommends "human approval before materials reach the market".8 And an AI tool that reads draft results is holding inside information, so where it runs and who can reach it are disclosure-control questions.
12 · The calendar and beyond the US
Semiannual reporting, the EU's new inside information rules and foreign issuers' earnings calls
In shortQuarterly filing may become optional in the US, though a proposal is all that exists so far. Calls were never required, and companies would still choose whether to hold them. Outside the US, Regulation FD gives way to other regimes. The EU changed how it treats intermediate steps from June 5, 2026, with clinical trials and marketing authorizations among its listed examples.
In three months of 2026, the US proposed less reporting and the EU changed its inside information rules
May 5, 2026SEC proposes semiannual reporting
An optional Form 10-S for the first half.
Jun 5, 2026EU change on intermediate steps applies
Only the final event in a drawn-out process is announced.
Jul 6, 2026US comment period closes
No final rule found as of November 3.
Jul 16, 2026EU Delegated Regulation 2026/789 published
Its list of final events includes the conclusion of clinical trials.
Semiannual reporting. On May 5, 2026, the SEC proposed letting companies report twice a year in place of three Forms 10-Q: a new Form 10-S for the first half, then the Form 10-K, with the choice made by a box on the Form 10-K. Comments closed on July 6, and we found no final rule as of November 3, 2026.1
Apart from technical edits to Item 2.02, the proposal makes no general change to the rules on earnings releases or guidance, and it notes that many companies hold calls. In our reading, fewer scheduled calls would pack more topics into each one and raise the stakes of any contact with analysts in between.
Foreign private issuers. Regulation FD excludes them.16 Several global drug companies report under this status, and they answer to home rules, plus US antifraud rules where their shares trade.
The EU. Under the Market Abuse Regulation, the EU's rulebook on inside information, as amended by the Listing Act, companies need not announce intermediate steps in a drawn-out process from June 5, 2026, and only the final event is disclosed. Those steps can still be inside information, so confidentiality and insider lists continue. A company may delay only if the withheld fact does not contradict its latest public statement on the matter.46
Commission Delegated Regulation (EU) 2026/789, dated April 8, 2026, was published in the Official Journal on July 16, 2026, and applies from the third day after that. It lists typical final events, including the conclusion of clinical trials and authorization to commercialize medicines, and forms of communication that count for the contradiction test, including publicly accessible pre-close calls (calls held ahead of results), roadshows and webinars.47
Japan. A Fair Disclosure Rule has applied since April 1, 2018.48 Other markets have their own rules, so a global company's book needs a note on who may say what, and where.
The same pipeline sentence is governed differently across regimes
Which rule asks the main question, for a company by listing status
Not this rulePartlyMain rule
Selective disclosureDuty to announceMisleading statementUS domestic filer: Regulation FD, Rule 10b-5Main ruleNot this ruleMain ruleForeign private issuer in the US: home rules, Rule 10b-5PartlyPartlyMain ruleEU-listed company: Market Abuse RegulationMain ruleMain rulePartlyJapan-listed company: Fair Disclosure RuleMain rulePartlyPartly
Our reading of the sources16,18,46,48 · Our simplified reading, for discussion with counsel. Listing rules and national law add more.
Show the numbers
Selective disclosure
Duty to announce
Misleading statement
US domestic filer: Regulation FD, Rule 10b-5
Main rule
Not this rule
Main rule
Foreign private issuer in the US: home rules, Rule 10b-5
Partly
Partly
Main rule
EU-listed company: Market Abuse Regulation
Main rule
Main rule
Partly
Japan-listed company: Fair Disclosure Rule
Main rule
Partly
Partly
13 · How teams do it today
How IR teams prepare today: the controller, deputy counsel, CFO office and the hand-offs in between
In shortFive roles carry the work over three to five weeks, passing Word files and spreadsheets between them. The most time goes to drafting answers and reading. In the example's step estimate, a large company spends about 150 hours a quarter. Companies do it in house, with an adviser's help, or increasingly with software.
Role
What they do
What they ask for
Head of IR
Owns the book, reads the Street, ranks the questions, books the rehearsals
"Which question will hurt?"
CFO
Answers most of the questions and often chairs the disclosure committee
"Three numbers and the line I must not cross."
Corporate controller
Ties every number to the latest release draft and reconciliations
"What changed since the last draft?"
Deputy general counsel
Reads for new material information, caution language and adjusted figures
"Is this already public?"
CEO and head of science
Rehearse the strategy and pipeline questions
"Ask it the way that analyst will."
Counsel's part is well established: in the 2014 survey, in-house counsel reviewed the script at 71% of companies and helped develop it at 37%.11 The quoted lines are the example's fictional characters.
A Q&A book passes through five hands before the call
Timings from the example, day counts from one adviser's five-week plan
1Set themes and list questions
Compare results with guidance and consensus; compile likely topics.
IRAbout 4 weeks out
2Draft answers
Copy forward from last quarter, then update.
IR with subject experts2 to 3 weeks out
3Tie out numbers
Each figure against the latest release draft, repeated for each draft.
ControllerAfter each draft
4Legal review
New information, caution language, adjusted measures.
Counsel, disclosure committeeAbout 1 week out
5Rehearse
Bullet points, a mock Q&A, then a final run the day before.
Compare results with guidance and consensus; compile likely topics.
IR
About 4 weeks out
Draft answers
Copy forward from last quarter, then update.
IR with subject experts
2 to 3 weeks out
Tie out numbers
Each figure against the latest release draft, repeated for each draft.
Controller
After each draft
Legal review
New information, caution language, adjusted measures.
Counsel, disclosure committee
About 1 week out
Rehearse
Bullet points, a mock Q&A, then a final run the day before.
CEO, CFO, head of science
Last week
Earnings call rehearsal and mock Q&A in one adviser's five-week plan
ICR's five-week plan sets themes and compiles Q&A topics four weeks out, reviews Q&A with bullet-point responses in the final week, and holds a final mock Q&A a day before the call.49 BNY's practice note adds that pre-recorded remarks leave leaders better prepared for the live Q&A.50 The three IR officers in the Dutch study all described a briefing on anticipated questions.7
Drafting and reading take over half of the example's 150 hours
A step estimate for one large company's IR team, per quarter. No survey measures this
Drafting answers44 hours
Reading notes and transcripts40 hours
Listing and ranking questions24 hours
Legal review18 hours
Tying numbers to the release16 hours
Rehearsal cards8 hours
Illustrative · replace with your own numbers
Show the numbers
Step
Hours
Drafting answers
44 hours
Reading notes and transcripts
40 hours
Listing and ranking questions
24 hours
Legal review
18 hours
Tying numbers to the release
16 hours
Rehearsal cards
8 hours
In house, with an adviser or with software: how teams build a Q&A book
Way
How it works
Fits when
Watch for
In house
Spreadsheet of questions, Word book copied forward, hand tie-out
Few products, few analysts, a stable story
Knowledge leaves with the person. Late changes get missed.
With an IR adviser
An outside firm reads the Street, drafts Q&A and runs the mock call
Small biotech with a thin team, or a first year after listing
The adviser needs draft results under confidentiality, which Regulation FD allows only with a duty or an express agreement.15
General chat tools
Teams paste notes and drafts into a general assistant
Non-sensitive summaries of public material
Draft results in an uncontrolled tool, no citations, no record of who approved what.
Purpose-built software
Reads sources, ranks questions, drafts from a closed library, checks, routes for signature
Many analysts, many products, frequent news
Test the ranking and the flags on your own past calls.
Part B · See it working
Botminds Earnings Call Preparation on one quarter at a fictional drug company, from a rival's news to a signed Q&A book
Part A described the work without naming a product. This part shows how Botminds does it, for a fictional listed drug company reporting its third quarter of 2026. Every company, analyst, research firm, medicine, study, result and date in the screens is sample data. The sample runs each step in one sitting, so its activity trail reads October 7 throughout. In a real quarter, the same steps run across three weeks.
14 · One quarter, start to finish
Northwind Bio's Q3 2026 call: a peer's Phase 3 news at 7:58 am, a matrix re-ranked, 41 answers signed in order
In shortThis is the example from the top of the page, inside the product. Six AI agents read the notes, calls and news, and rank 41 predicted questions. Lena Ortiz, the VP of investor relations, re-ranks when a rival reports. The controller, deputy general counsel and disclosure committee then sign in that order, and every flag is decided by a person.
1
Every likely analyst question on one matrix of probability against stakes
Lena opens the question matrix on Wednesday, October 7, 22 days before the call. The 16 questions above 20% sit in a grid: probability across the top, stakes down the side. The top-right cell reads "Prepare hardest". Each chip's dot gives its status: disclosure flag, drafted, in review or approved.
She picks the question on the Talvoren 2027 floor, the level where that medicine's falling sales stop, at 88%. The panel shows what each signal adds: analyst notes 44%, past calls 41%, investor feedback 15%. Below that sit the evidence, the likely askers and the draft answer. Rachel Kim of Harbor & Pike wrote that she expects "the Q&A to focus on where Talvoren bottoms in 2027".
The question matrix. Likely analyst questions by probability against stakes, the peer news banner on top, and the reasons for the selected question on the right.
2
A peer's Phase 3 news arrives, and one click re-ranks the questions
At 7:58 am, a banner reports that Tarnwell Pharma, one of three watched peers, has published oral Phase 3 results in plaque psoriasis. It says which questions may move before anyone asks. Lena clicks "Re-rank with this news".
The steps run where she can see them. The Research Reader reads the release, the Question Forecaster matches it to all 41 questions, the Answer Drafter re-drafts from the disclosure library, and the Disclosure Guard checks the result. The banner gives 18.6 seconds for the run in this sample. The last step waits for her.
Re-ranking on peer news. Each step in the open, ending with a person. You can set this to re-rank automatically, or to ask first.
3
Oral competition jumps from 44% to 82% and moves to "prepare hardest"
The chip slides across the grid and leaves a marker: "Q-16 was here · 44%". Its stakes go from medium to high, because the $20 billion 2030 target has been on the record since investor day. The 2027 gross-to-net question rises from 71% to 76%, since the peer named pricing policy as its main uncertainty.
Peer news now supplies 56% of the oral question's probability. The panel says when it moved, from what, and why.
After the news. The moved question, the marker where it was, and the new mix of signals.
4
Three sentences for the CEO, each cited to a public passage
The question is reworded the way Victor Salas of Thornlea Capital Markets is likely to put it: does a once-daily pill change your view of Veltrimab above $20 billion in 2030? The answer for Dana Okafor, the CEO, comes only from the investor day presentation and prepared remarks. The 2030 outlook already assumes oral competitors from 2028, Veltrimab leads new-to-brand prescriptions in psoriasis, and sales above $20 billion in 2030 are still expected.
The checks read "Every sentence cited", "Approved sources only", "Numbers tie to release v7", "Nothing new or material" and "Forward-looking covered". The rehearsal card adds the line not to cross. Lena approves it.
A cited answer and its card. Three sentences, three sources, the checks, and "Do not comment on Tarnwell's data or compare trials."
5
"March 2027" is flagged: a month is sharper than "the first half of 2027"
Anika Bose of Tidemere Equity Research will press for the date of the VLT-302 study results. The draft for Dr. Maya Chen, the chief scientific officer, says "We now expect topline results in March 2027." The Disclosure Guard flags it as new material information, shows the press release of September 14 with "the first half of 2027" marked, and proposes that wording with its citation.
Lena can use the public wording, or keep it and ask legal. The agent never clears its own flag. On an open, announced call the month would reach everyone at once, which usually satisfies Regulation FD's selective disclosure rule. The problem left over is a new date that nobody decided to announce. Your counsel will want to make that decision on purpose, and keep the words from reappearing in a private call-back.
A disclosure flag. The sentence, the reason, the public wording, and the source passage on the right.
6
Rehearsal in the analyst's voice, timed to 30 seconds
For Rehearsal 1 on October 20, the Rehearsal Coach asks the question as Rachel Kim would and times Omar Haddad, the CFO, against a 30-second target. Then it throws the follow-up: "So is it fair to model a 2027 decline similar to 2026?"
The card gives the opening line, three numbers ($1.12B, −41.3%, about 45% US erosion), the bridge, a sentence that moves on to Veltrimab's growth, and the line not to cross: "Do not give a 2027 Talvoren number or a floor." While a flag is open, the screen warns him to practice the public wording.
A rehearsal card. The question, the follow-up, the card and a warning that this answer still carries an open flag.
7
188 numbers tied to release draft v7, and one that was not
Lena submits the book. Tomás Reyes, the corporate controller, runs the tie-out across 41 answers and 188 numbers. 187 tie. One answer still says Veltrimab was "up 26%", from draft v6, before a rebate adjustment. Draft v7 says 24.1%.
He applies the v7 number and signs. Adjusted earnings per share, operating margin and R&D are checked against the reconciliation tables in the same step.
The finance tie-out. The book on the left, and on the right the run, the one number that fails and the fix.
8
No legal signature while an answer carries wording that is not public
Priya Ranvelle, the deputy general counsel, cannot sign with three flags open: a 2027 Talvoren decline and floor, "late-stage talks for an obesity asset", and "March 2027". The screen shows each next to the public wording.
She uses the public wording for all three and signs. The original sentences stay on the audit trail, in case anyone later asks what was considered and why it changed.
Legal review. Three sentences, the wording to use for each, and one decision by a named lawyer.
9
Locked for the call: version 1.0, 41 questions, no flags open
The disclosure committee, chaired by Omar Haddad, meets on October 22 in the plan. Twelve answers still lack IR approval. Each has been cited and passed through the Disclosure Guard, finance and legal. The committee approves them as they stand, and it could send them back. The book locks as one record: 41 questions, 41 approved, no disclosure flags open, version 1.0.
The rehearsal cards go to the CEO, CFO and chief scientific officer. Any change from here needs the committee.
The signed Q&A book. Every answer by theme, the four signatures in order, and the trail. The sample's signatures read "today" because it runs in one sitting.
With 22 days to go, only 6 of the 16 ranked answers are approved
Status of the ranked questions on the morning of October 7, before the re-rank
16ranked
Drafted3
Disclosure flag4
Approved6
In review3
Fictional example from this guide
Show the numbers
Status
Questions
Drafted
3
Disclosure flag
4
Approved
6
In review
3
The design goals for a live deployment are 46 hours of IR preparation a quarter against about 150 by hand (the solution's own step estimate), 89% of questions asked on the last call already in the book, and nine flags caught before legal review with none reaching the call. These are targets, and the sample dashboard shows them on fictional quarters. Measure your own.
15 · Every other screen
The ranked question list, the Street, the source passage, the dashboard and your disclosure settings
In shortThe walkthrough above followed one quarter's main path. These screens show the rest: signals and the run-up to the call, the ranked table, the moved question in full, a source document, covering analysts and their estimates, the rehearsal plan, the committee's last check, the trail, the dashboard and the settings that hold your policy.
Signals and the run-up. Each note tied to the questions it moved, and the calendar: quiet period October 1, book draft October 14, rehearsals October 20 and 26, committee October 22, results October 29.
Ranked questions. All 16 by probability, with stakes, likely askers, speaker and status. The 25 questions under 20% sit in the book's appendix.
The moved question. Why it is expected, with the peer release, the analyst's note and the 2030 target as evidence, and the source passage on the right.
A source document. Its role, its public status and date, and which answers use it. The press release is the sample's own fictional text.
The Street. 18 covering analysts, 19 notes read, consensus (the average of analysts' estimates) of $11.38 against a new guidance midpoint of $11.50, and estimates plotted against both ranges.
One analyst. Her note, with the passage marked, and the questions she is likely to ask. Notes are read to predict questions and are never quoted in an answer.
The committee's last check. What is still open, with the choice to send it back.
The rehearsal plan. Progress by speaker, then the first rehearsal, a full simulated call with eight analysts in queue order, and a last check that morning.
The activity trail. Who changed what, when, including the wording that was replaced.
Sign-off and disclosure rules. Who signs, in order. Approved sources, citations and flags for new material information are always on.
The dashboard. Sample figures: 41 predicted, 89% of questions on the last call already in the book, 9 flags, 46 hours. The screen marks the coverage line as illustrative.
Flags and hours. Nine flags by kind, each decided by a person, and estimated hours by step.
Who asks about what. Theme mentions in each analyst's notes, so you can see who to expect on which topic.
Late-breaking news. Ask before re-ranking or re-rank automatically, the 20% line for the book, and the peers you watch.
Most flags caught in the sample are about wording that goes past the record, or numbers
Nine disclosure flags on the sample quarter, each decided by a person
9flags
New material information4
Number does not tie3
Forward-looking wording1
Non-GAAP wording1
Fictional example from this guide
Show the numbers
Kind
Flags
New material information
4
Number does not tie
3
Forward-looking wording
1
Non-GAAP wording
1
16 · Who drafts, who signs
Six agents read, rank and check; the IR lead, controller, counsel and disclosure committee decide
In shortEach agent has one job and limits it does not cross. Agents read notes and draft from approved documents, and none can clear a flag, sign or lock. People approve each answer, tie out and sign, decide every flag and lock the book, in an order you set.
The six earnings call agents, and what each must never do
Research Reader
Reads each analyst note, preview and peer release, and lists stated questions, concerns, estimates, ratings and targets, each with its page.
Never quotes licensed research in an answer.
Transcript Analyst
Splits your last eight calls and peers' calls into who asked what and how it was answered, and marks public positions such as a timing or a curve.
Never paraphrases a public position. It is reused word for word.
Question Forecaster
Clusters raw questions, scores probability from four signals and stakes from what is exposed, and names the likely askers.
Never hides its reasons. Every probability shows what each signal added, and people can overrule it.
Answer Drafter
Drafts each spoken answer for the named executive from the approved library and this quarter's release and remarks, cites every sentence and writes the card.
Never uses a number that is not in a source.
Disclosure Guard
Checks every sentence before people see it: new material information, numbers off the latest draft, outlook statements with no caution, adjusted measures with no reconciliation.
Never clears its own flag. A person decides, seeing both the draft and the public source.
Rehearsal Coach
Plays the analysts in rehearsal: asks each question in the analyst's style, times the answer against its target and adds a realistic follow-up.
Never suggests wording outside the approved answer.
Who signs a Q&A book: the order from investor relations to the disclosure committee
Owns and approvesVP Investor RelationsOwns the book, overrules the ranking, approves each answer and submits for sign-off.
Ties out and signsCorporate controllerTies every number to the latest draft and signs with the meaning "reviewed and approved".
Decides every flagDeputy general counselDecides each disclosure flag. Cannot sign while wording that is not public remains.
LocksDisclosure committeeApproves the remainder, or sends it back, and locks version 1.0. Later changes come back to it.
SpeakCEO, CFO and science chiefRehearse from the cards, and answer on the call in their own words.
Maker and checker stay apart: agents draft and check, and people approve and sign. Every re-rank, edit, flag decision and signature is on the audit trail with who and when. Draft results stay on your company's platform. These are controls that support your own disclosure controls and procedures, and the legal judgment stays yours. Botminds is SOC 2 Type II audited and manages information security to ISO 27001.
Lena, Omar, Tomás, Priya and Dana: five people who carry one results call
Fictional, from the sample data
LO
Lena Ortiz · VP Investor Relations
Reads 19 notes, owns the book and books the rehearsals.
"I don't need more questions. I need to know which one will hurt."
OH
Omar Haddad · chief financial officer
Answers most of the questions and chairs the disclosure committee.
"Give me three numbers and the line I must not cross."
TR
Tomás Reyes · corporate controller
Ties out every number to the latest draft.
"When draft seven lands, every answer with a number is wrong until proven right."
PR
Priya Ranvelle · deputy general counsel
Decides every disclosure flag and signs.
"If it isn't public yet, it isn't in the book."
DO
Dana Okafor · chief executive officer
Rehearses the strategy questions.
"Ask it the way Victor will ask it."
17 · Inputs and systems
From sell-side notes and draft releases to a signed book: what the solution reads, writes and connects to
In shortIt reads what IR already reads, keeps sources that predict apart from sources that answer, and produces a ranked matrix, cited drafts, flags with public wording, rehearsal cards and a signed book. It connects to your research feed, transcript provider and IR drive, and re-checks answers whenever a new draft arrives.
Read to predict, never quoted
Sell-side notes and previews
Peer releases and calls
Investor feedback
Read to answer
Approved disclosure library: filings, press releases, transcripts, investor day decks
Your past call transcripts
This quarter's release draft and prepared remarks
Agents read, rank, draft and checkEvery sentence keeps its source
A person decides every flag
Signed in order
What comes out
Question matrix: probability against stakes, with reasons
Cited draft answers for each speaker
Disclosure flags with the public wording to use
Rehearsal cards and sessions
Finance tie-out record
Signed Q&A book, watermarked on export, with its trail
Coverage, flags and hours after each call
Research feeds, transcripts and the IR drive: systems an earnings prep rollout connects to
Research aggregatorNotes and previews, licensed, read only, daily
Transcript providerYour calls and peer calls, within an hour
News and peer releasesThe peers you choose to watch
IR drive10-K, 10-Q, press releases, investor day decks
Release and remarks draftsEach new draft re-checks every answer with a number
Identity and accessRoles, separation of duties, need to know
The solution scales across products, analysts and quarters, inside the roles and access rules you set, with a full audit trail and export. The settings hold your order of signatures, the switchable rules, the probability that puts a question in the book, and how news is handled. Before you connect a research feed, check your license with the aggregator.
Part C · Are you ready to automate?
Automating earnings call Q&A prep: what a loose answer costs, what it returns and how to test it on your last call
You run investor relations, or you sit in the CFO's office, the controller's team or the legal department. This part is written for you: what errors and late surprises cost today, what automating the Q&A book could return, whether your team is ready, and what to ask any vendor of earnings call software, including us.
18 · What a loose answer costs
What hand-built earnings prep costs you: IR hours, stale numbers and the question nobody rehearsed
In shortThe hours are the part you can count, and they are modest for one company. The larger exposure is one unplanned sentence, a number from the wrong draft, or a surprise on the question that a rival's news made urgent. Published penalties frame the risk without telling you your odds, so start by measuring your own last call.
19.4%
one-day share price rise after a drug company privately called an FDA meeting "very positive and productive".4
SEC, TherapeuticsMD, 2019
13 of 47
2025 securities class actions against life sciences companies alleged misstatements on regulatory hurdles or FDA timing.36
Dechert, March 2026
$50,000
paid personally by a head of investor relations who signaled to about 20 analysts and investors that a loan guarantee was unlikely.29
SEC, First Solar, 2013
Reading and first drafts shrink most; legal review keeps a large share
IR preparation hours a quarter, from the solution's own step estimate for a large company
By hand (estimate)With the solution (design estimate)
Reading notes and transcripts40 hours6 hours
Listing and ranking questions24 hours4 hours
Drafting answers44 hours18 hours
Tying numbers to the release16 hours6 hours
Legal review18 hours8 hours
Rehearsal cards8 hours4 hours
Illustrative · replace with your own numbers · 150 against 46. Neither is a measurement. Time your own next quarter, and measure the second column in a pilot.
Show the numbers
Step
By hand (estimate)
With the solution (design estimate)
Reading notes and transcripts
40 hours
6 hours
Listing and ranking questions
24 hours
4 hours
Drafting answers
44 hours
18 hours
Tying numbers to the release
16 hours
6 hours
Legal review
18 hours
8 hours
Rehearsal cards
8 hours
4 hours
What nobody publishes. We found no measured public figure for hours per quarter on a Q&A book, the share of questions a team predicts, how often a book carries a stale number, or the market for this software. Vendors quote savings without an independent test. Your last four calls can answer most of this.
Scoring your last four calls: a one-week baseline for your Q&A book
Cost
Where it hides
How to find your number in a week
IR and finance hours
Evenings in the three weeks before each call
Ask each person to estimate last quarter's hours by step, then log the next one
Questions you did not predict
The transcript, once the call is over
Mark each question on your last four calls: in the book, ranked high, or a surprise
Answers that drifted past the record
A sentence on the call that appears in no filing
Pick the ten most specific statements from the last transcript, and find each one's earlier source
Stale numbers
Corrections made late by the controller
Count corrections after the last release draft, last quarter
Late news
Email threads in the last week
List peer and policy news in the 10 days before each call, and how long your answer took to change
Executive time
Rehearsals on questions nobody asks
Compare rehearsed questions with those asked
Call-backs
Analyst calls in the days after results
Check whether a rule and a log exist, and read a sample
The surprise on the call, the expectation you set by accident, and other costs a return model misses
The expectation you set by accidentA month or a floor becomes the market's number, and you are measured against it from then on.
A fumbled answer to an obvious questionIt can take days of follow-up conversations, each with its own disclosure risk.
Credibility with covering analystsAnswers that shift quarter to quarter cost trust, which is slow to rebuild.
A letter that contradicts youFDA now publishes complete response letters, so an upbeat answer can be read beside FDA's own words.32,22
What leaves with your IR leadWho asks what, which wording has been used, and which answers took years to get right.
19 · Your return
What automating the Q&A book returns: IR hours, executive rehearsal time and fewer late rewrites against the tool's cost
In shortPut in your own numbers. Every default is an assumption to replace. For one company, hours alone roughly cover a modest yearly cost, so the case rests on better prediction and fewer unplanned sentences. A small company with few analysts, one product and a skilled adviser may get more from writing down its method.
IR hours, rehearsal time, tie-out and prediction: where earnings prep can pay back
IR time
Reading and first drafts
Notes, transcripts and first answers come off the team, which keeps the judgment.
calls × (hours by hand − hours with software) × hourly cost
Executive time
Rehearsing what will be asked
Better ranking means fewer hours on questions nobody raises.
calls × executives × hours saved × hourly cost
Tie-out
Every draft re-checked
Each new release draft re-checks each number, so late changes stop being a scramble.
late corrections per call; hours from new draft to clean book
Prediction
Fewer surprises
More questions on the call were in the book, and ranked high.
questions asked that were in the book ÷ questions asked
Disclosure
Flags before legal reads
Counsel starts from a list of sentences to decide, with sources beside them.
flags caught before legal review; flags reaching the call
News
Faster re-ranking
A rival's release changes the plan the same morning, with time left to rehearse.
time from peer news to a checked answer
Calls a year, hours per call and executive time: your earnings prep numbers
No source publishes these inputs. Every default is an assumption, marked illustrative.
The teamThe executivesYour cost
Illustrative yearly value
Preparation today, valued$0
Team time released, valued$0
Executive time released, valued$0
After your yearly cost$0
Hours released a year0
Calls a year to cover your cost0
Formulas, per year: Preparation today = calls × hours by hand × hourly cost Team time = calls × (hours by hand − hours with software) × hourly cost Executive time = calls × executives × hours saved × executive hourly cost After your cost = team time + executive time − yearly cost Calls to cover your cost = yearly cost ÷ value per call
Not counted: penalties or lawsuits avoided, share price effects, or the value of a question rehearsed in time. Released hours are value only when you decide what they are for, such as more investor meetings or better peer analysis.
Released time is worth more as a company's preparation hours grow
Yearly value before cost, with the calculator's defaults and hours scaled by company size
Small biotech, 80 hours a call by hand$43K
Large drug company, 150 hours$68.5K
Global company with many products, 300 hours$122.6K
Illustrative · replace with your own numbers · Hours with software taken at about 31% of hours by hand, as in the example.
Show the numbers
Company
Yearly value, before cost
Small biotech, 80 hours a call by hand
$43K
Large drug company, 150 hours
$68.5K
Global company with many products, 300 hours
$122.6K
On these defaults, four calls release $68,480 of time against a $60,000 cost, so about 3.5 calls of value cover it, which the calculator rounds to 4. Change the cost to $120,000 and time alone no longer pays. Then the decision rests on the risk you wish to reduce, and that is worth saying out loud in your business case.
Start here20 · Readiness check
How ready your IR team is: a disclosure library, a written flag policy, a scored last call and a clear signer
In shortPick the answer closest to your team today. Eight questions score 0 to 2, and the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.
1
Analysts and products
How much do you have to read and answer each quarter?
Why it mattersVolume and news flow make the case. With few analysts and one product, an experienced IR lead can hold it in their head.
A strong answer"Eighteen analysts, three major products, and news nearly every week."
2
A disclosure library
Can you put your hands on every approved public document, with its date?
Why it mattersAnswers can only cite what is in the library, so a gap here turns into a false flag.
A strong answer"One folder holds filings, releases, transcripts and investor day decks, and someone owns it."
3
A written disclosure policy
Is your policy on guidance, call-backs and quiet periods written down?
Why it mattersSoftware applies the rules you give it. The SEC noted that TherapeuticsMD had no Regulation FD policy.4
A strong answer"Yes, reviewed last year, with who may speak and how we log follow-up calls."
4
Your baseline
Do you know how many questions on your last call were in the book?
Why it mattersNo public benchmark exists, so your own figure is the only way to prove a change.
A strong answer"We scored four calls: about 70% were in the book, and half of those ranked high."
5
The tie-out today
When a new release draft lands, how do you know which answers changed?
Why it mattersThis is where stale numbers come from. If the answer is "we read it again", you have a clear place to start.
A strong answer"We compare drafts, and the controller re-ties anything touched, and logs it."
6
Who decides a flag
Is one lawyer named as the decider for wording that goes past the record?
Why it mattersA flag with no owner waits until the last day.
A strong answer"The deputy general counsel, with the disclosure committee for anything new."
7
Draft results and AI
Have security, legal and finance agreed where draft results may be processed?
Why it mattersA draft release is inside information. Newswire hacks show what it is worth.37
A strong answer"Our own environment, named roles, no training on our data, and access logged."
8
Owner and budget
Is there a named owner with budget, and a CFO who will use the result?
Why it mattersThis work crosses IR, finance and legal, and executives must trust the cards.
A strong answer"The VP of IR owns it, and the CFO will rehearse from it next quarter."
9
The call you wish you had · for reflection
Think of the hardest moment on your last three calls. If you had seen that question coming a week earlier, what would you have done differently, and what would have told you?
Why it mattersYour answer names the signal you should be watching, which may be a peer, a note or a policy.
A strong answerA specific story, for example: "the margin question. Two notes raised it, and we never connected them."
A low score means gathering the disclosure library and scoring old calls first
0–6
Explore
Gather your public documents in one place, write the policy on guidance and call-backs, and score your last four calls. Those three steps improve your next book on their own.
7–11
Ready to pilot
Replay one past call using only what was public before it, and score the prediction and the flags. Then run one live quarter in parallel with your usual book.
12–16
Ready to implement
Plan the research feed and license, roles, sign-off order, your switchable rules and which peers to watch, then choose the first real call and name the backup plan.
21 · Questions for any vendor
What to ask earnings call software about citations, draft results, flags and analysts' licensed research
In shortAsk every vendor the same questions, us included. The answers show where each sentence comes from, what happens when a draft changes, who decides a flag, where your draft results go, and how you would score the tool on your own past calls.
Ask
A good answer
A warning sign
Sources and citations
Which documents may an answer draw on?
A closed library you control, each with a public status and date
"It searches the web and your files"
Can an analyst's note reach an answer?
No: notes predict questions and are read only, and that rule cannot be switched off
Notes and filings in one index
What happens to a sentence with no source?
It never reaches the book, and you can see why
A reviewer is expected to notice
Numbers and drafts
What happens when release draft v8 arrives?
Every answer with a number is re-checked, and changes are listed
You re-run it by hand and compare
Do you check percentages and non-GAAP measures?
Yes, including growth rates and the reconciliation table
Only exact number matches
Disclosure judgment
How do you spot a sentence sharper than the record?
It compares dates, ranges and specifics with the public passage, and shows both
A keyword list
Who clears a flag?
A named person, on the trail, with the original sentence kept
The tool rewrites it silently
What do you say about Regulation FD?
That your counsel decides, and that an open call and a private call differ
"Regulation FD compliant"
What can you say about controls?
Which controls support your disclosure controls, and what remains yours to do
Any claim of certification for GxP, Part 11 or disclosure compliance
Prediction
How good is the question forecast?
Share of asked questions in the book, and in the top tier, on your own past calls
One accuracy figure, on other companies
Can we see why a probability is what it is?
Each signal's share, with the passages behind it, and people can overrule it
A black-box score
How fast does news change the ranking, and who is asked?
Minutes, by your setting, with the moved question named
A daily batch
Your draft results and the research license
Where do draft results go, and who can reach them?
A named environment and region, roles on need to know, all access logged
"Encrypted", and no more
Which AI models do you use, and do our documents train them?
Named models and no training on your data, in writing
"Proprietary AI"
How do you handle our research aggregator's license?
Read-only use, agreed with you and the aggregator
"Upload your PDFs"
Proof
Can we replay our last call before we sign?
Yes, using only what was public before it, scored against the transcript
Demo data only
We found no published independent test of any vendor's accuracy at predicting analyst questions as of November 2026. A replay on your own past call is the fairest comparison, and it is easy to do honestly, because the transcript already holds the answer key.
22 · How to start
Replay your last earnings call using only what was public before it, then run one quarter in parallel
In shortScore your last four calls, gather the library, replay one call blind and run one live quarter beside your usual book. None of these steps commits you to a vendor. The scoring and the library improve your next call either way.
Score your last four calls. Mark each question asked as in the book, ranked high, or a surprise.
Gather the library, with public status and date on each document, and write down your policy on guidance and call-backs.
Replay one past call blind, using only documents dated before it. Score prediction against the transcript and flags against what you know now.
Run one live quarter in parallel, with your usual book still going to the CFO, and compare the two at the lock.
Decide with five numbers: questions in the book, questions in the top tier, flags caught early, numbers caught by the tie-out, and hours.
A pilot of about sixteen weeks ends with one real call compared side by side
Your teamVendor
Score four past calls; gather the library
Clear draft results and research license
Connect feeds; set rules and sign-off order
Replay one past call blind
Score prediction and flags
Live quarter in parallel, through the call
Score the call; decide
Week 0481216
Illustrative · replace with your own numbers · Fit it around your reporting calendar. Week 9 should fall near your quarter end.
Show the numbers
Activity
From
To
Score four past calls; gather the library
0
3
Clear draft results and research license
1
4
Connect feeds; set rules and sign-off order
3
6
Replay one past call blind
5
8
Score prediction and flags
7
9
Live quarter in parallel, through the call
9
15
Score the call; decide
15
16
Questions in the book, top-tier hits and flags: how to score an earnings prep pilot
Measure
How
Why
Asked and in the book
Questions in the transcript that the book predicted ÷ questions asked
The plainest test of prediction. Compare with your baseline
Asked and ranked high
Of those, the share in your top tier
A long list scores well on the first measure and still leaves executives unready
Flags that were real
Counsel's share of flags accepted, plus any wording counsel would have flagged and the tool missed
Too many false flags and people stop reading; a miss is worse
Citations that hold
Open a sample of sentences. Does the passage say that, and no more?
Citation that only looks right gives false comfort
Numbers caught
Plant a stale number and a stale percentage in a test draft
An easy test that either passes or fails
Hours by step
A log for one quarter, legal and executive time included
The business case rests on them
The full working-session questions: 12 questions in four groups
Bring IR, the controller, legal, security and someone from the CFO's office into one room. Each question says why it matters and what a strong answer looks like.
A
Your covering analysts, peers and call calendar
A1
Which peers' news should move your ranking, and who decides?
Why it mattersToo many peers makes noise, and too few misses the event.
Strong answer"Three direct rivals, reviewed yearly, and the IR lead can add one."
A2
When does your quiet period start, and what may staff say in it?
Why it mattersNo standard length exists, so your own rule has to be clear.26
Strong answer"From quarter end to the call; public information only, and no one-on-ones."
A3
Would you move to semiannual reporting if Form 10-S is adopted?
Why it mattersIt is only a proposal, but your calendar and tools should be able to follow.1
Strong answer"Probably not at first, and we would keep quarterly calls."
B
Public positions on pipeline, FDA and guidance
B1
Where is the list of every public timing, curve and target, in exact words?
Why it mattersPrecision creep is measured against this list.
Strong answer"In the library, marked up by IR and checked by legal each quarter."
B2
How do you describe a meeting or letter from FDA?
Why it mattersFDA may publish its letter, and one adjective has already drawn an SEC case.4,22
Strong answer"Facts, in words regulatory affairs and counsel have approved."
B3
What is your sentence on deals, and has it changed?
Why it mattersA change in wording is itself a signal.
Strong answer"The same sentence for eight quarters, and any change goes to the committee."
C
Adjusted measures, tie-out and new release drafts
C1
Which adjusted measures may be spoken, and where is each reconciled?
Why it mattersRegulation G applies to oral measures as well.10
Strong answer"Three measures, each in the release tables and on the website."
C2
How do you explain acquired R&D in adjusted earnings?
Why it mattersSEC staff objected to excluding it in 2022, and analysts ask.19
Strong answer"It stays in adjusted earnings, and a footnote shows the amount."
C3
Who has the last draft, and how late can a number change?
Why it mattersThat sets the deadline for re-checking the book.
Strong answer"The controller; numbers freeze a day before the committee."
D
Call-backs, slips and who is on point after the call
D1
What may IR say on a call-back, and is it logged?
Why it mattersMost of the enforcement cases in this guide began in private calls or messages.3,4,5,29
Strong answer"Only the transcript and release, with two people on the line and a note kept."
D2
If someone slips, who is told, and how fast can you publish?
Why it mattersThe clock for a non-intentional disclosure is short, and a quick fix helped First Solar's position.16,29
Strong answer"The general counsel, at once, with an 8-K template ready."
D3
What will you never let software do?
Why it mattersThis tells you where the signatures belong.
Strong answer"Clear a flag, approve an answer, or talk to an analyst."
23 · Frequently asked questions
Earnings call preparation questions answered: Q&A books, Regulation FD, quiet periods, safe harbor and AI
In shortQuestions IR teams and buyers search for, each answered on its own.
What is earnings call preparation?
Earnings call preparation is the work an investor relations team does in the weeks before a results call so executives can answer analysts' questions. It covers predicting the questions, writing answers from public information and the coming release, tying numbers to the final release draft, clearing disclosure with legal, and rehearsing. The output is usually a confidential Q&A book.
How do you prepare for earnings call Q&A?
Read every analyst note and your recent transcripts, list the likely questions, and rank them by how likely they are and how much a poor answer would cost. Write a short spoken answer to each from public documents and this quarter's release, then have finance tie out the numbers and legal read for anything new. Rehearse aloud with follow-ups, and re-rank when a peer's news arrives.
What is an earnings Q&A document?
An earnings Q&A document is an internal document, often called a Q&A book, holding the questions analysts are likely to ask and the approved answer to each, usually by theme and speaker. Good ones give each answer a source, a few key numbers and a line not to cross. It stays confidential because it often contains draft results before they are released.
Does Regulation FD apply to earnings calls?
Regulation FD applies to earnings calls, and a properly run call meets it. The SEC's adopting release accepts conference calls that the public may attend, with adequate notice, as a way of making information public. New material facts said on such a call reach everyone at once, so the rule's force falls mostly on private call-backs, small meetings and social posts. Foreign private issuers are outside the rule.
Can a company reveal new information on an earnings call?
A company can reveal new information on an earnings call if the call is open and announced, and the decision to do so should be deliberate. Item 2.02 of Form 8-K asks that figures from a call be on the website, and new information about a completed quarter may call for its own 8-K analysis. An unplanned statement may also set expectations or mislead, so most companies keep new facts in the release and decide them in advance.
How long is an earnings call?
An earnings call usually lasts about an hour. A study of 20 large Dutch companies timed an average of 64 minutes, with 23 of presentation and 41 of questions. A 2014 US survey found 46 to 60 minutes at 68% of companies, with larger companies running longer. Few recent public figures exist.
What is a quiet period before earnings?
A quiet period is a stretch before results when a company limits its contact with analysts and investors. No SEC rule sets a quarterly quiet period, and advisers note there is no standard length, so each company writes its own policy. Some companies stop talking to investors altogether in that stretch, and others limit staff to public, fact-based answers.
What is a mock Q&A for an earnings call?
A mock Q&A is an earnings call rehearsal in which colleagues play the analysts and executives answer aloud, with follow-up questions. ICR's five-week preparation plan reviews bullet-point responses in the final week and holds a final mock Q&A a day before the call. Practice from points and numbers, because a study of call transcripts links sticking closely to a script with a worse market reaction.
Do you need a safe harbor statement on an earnings call?
To use the statutory safe harbor for spoken forward-looking statements, the speaker must say the statement is forward-looking, that results may differ materially, and that further factors appear in a named, readily available written document. Most calls do this at the start. The safe harbor has exclusions, such as initial public offerings, so ask counsel how it applies.
Can you use non-GAAP numbers on an earnings call?
A company can use non-GAAP numbers on an earnings call. Regulation G lets it meet the reconciliation requirement for a spoken measure by posting the comparable GAAP figure and the reconciliation on its website at the time, and giving the location in the same presentation. A measure also must not mislead. Pharma companies should know that SEC staff objected in 2022 to excluding acquired in-process R&D and upfront or milestone payments.
Can executives reaffirm guidance privately?
Reaffirming guidance privately carries risk. SEC staff say that confirming a prior forecast privately may be material, depending on whether it adds to the original forecast, its timing and later events. Flowserve and its chief executive settled charges in 2005 after he reaffirmed guidance to analysts in a private meeting. Many companies reaffirm only in public.
What should a biotech say about a trial readout on a call?
Repeat your last public timing in the same words, and decide in advance how to handle a push for more. A month or quarter that is sharper than "the first half" is new information, and it should be a disclosure decision taken by the right people. Materiality has no bright line, and the Supreme Court has said a lack of statistical significance does not settle it.
Can AI predict analyst questions?
Software can read notes, transcripts and news, cluster the questions and rank them, and practitioners are using it this way. We found no published independent test of how accurate this is. Score any tool yourself by replaying a past call on what was public beforehand and comparing the result with the transcript, and let people overrule the ranking.
Is it safe to use AI on draft earnings results?
Draft results are inside information, so treat any AI tool like any other system that holds them. Ask where it runs, who can reach it, whether your data trains a model, and what is logged. Keep the tool inside your disclosure controls, and let a person approve what goes into the book. General chat tools rarely meet this bar without specific arrangements.
Do Part 11, FDA's AI guidance or draft Annex 22 apply to investor relations work?
In our reading, those rules mostly do not apply to investor relations work. FDA's January 2025 draft concerns AI supporting regulatory decisions on drugs, Part 11, FDA's rule on electronic records, follows records required by its other rules, known as predicate rules, and draft EU GMP Annex 22, part of the EU's good manufacturing practice rules and still unadopted, concerns manufacturing. Securities rules and your disclosure controls are the frame for a Q&A book. Ask your quality and legal teams to confirm for your own records.
24 · One-page summary
Earnings call preparation on one page: the method, the November 2026 rules and the terms
Print this page
In shortThe whole guide on one screen: the method, the rules as of November 2026, the readiness bands and the terms.
The method
Keep sources that predict questions apart from sources that answer them.
Rank each question by likelihood and stakes, and show what each signal adds.
Write answers from the public record and this quarter's release, citing each sentence.
Hold every date, range and number to the sharpness of its source.
Tie out all numbers again after every release draft, including percentages.
Have a named person decide every flag, and sign in order.
Rehearse aloud with follow-ups. Re-rank on news. After the call, follow a rule on call-backs and score the book.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of November 2026: Regulation FD in force since October 23, 2000 · Form 10-S proposed May 5, 2026, no final rule found · FDA publishes complete response letters promptly since September 4, 2025 · Medicare third-cycle prices due by November 30, 2026 · Section 232 pharmaceutical tariffs from July 31 and September 29, 2026 · EU Market Abuse Regulation changes from June 5, 2026 · FDA's AI guidance still a draft · draft EU GMP Annex 22 not adopted, and about manufacturing.
14 terms
Sell-side analyst
A bank or broker's analyst who publishes research on a company.
Q&A book
The internal document of likely questions and approved answers.
Material
Likely to change the total mix of information for a reasonable investor.
Selective disclosure
Telling market professionals something material before the public.
Regulation FD
The SEC rule against selective disclosure.
Quiet period
A company's self-set time of limited investor contact before results.
Consensus
The average of analysts' estimates.
Guidance
A company's own public forecast.
Tie-out
Checking each number against its source.
Non-GAAP
An adjusted measure that must be reconciled to standard accounting.
Safe harbor
Protection for forward-looking statements that carry the right caution.
Disclosure committee
The group that considers what must be disclosed, and when.
Gross-to-net
The gap between a drug's list price and what the maker keeps after rebates.
Topline
The first summary of a trial's main results.
25 · Sources
Sources
Accessed November 2026. Regulatory status statements are as of November 2026. Named companies in the enforcement and court sources are real; every company in the example is fictional.
SEC, "Semiannual Reporting", proposed rule, Release 33-11414, 91 FR 24968, May 7, 2026; comments due July 6, 2026; page 24975 on earnings calls; page 24996 on market reaction. govinfo.gov
U.S. Securities and Exchange Commission, "Selective Disclosure and Insider Trading", Release 33-7881, August 2000. sec.gov
SEC, press release 2022-215, AT&T and three executives settle Regulation FD charges, December 5, 2022. sec.gov
SEC, press release 2019-156, TherapeuticsMD, August 20, 2019. sec.gov
SEC, press release 2010-202, Office Depot and two executives, October 21, 2010. sec.gov
Lee, "Can Investors Detect Managers' Lack of Spontaneity? Adherence to Predetermined Scripts during Earnings Conference Calls", The Accounting Review 91(1): 229-250, 2016. doi.org
Meirkulov, Pavlides, Pronk, Roelofsen, "Earnings conference calls and annual reports, similar or different information?", Maandblad voor Accountancy en Bedrijfseconomie 98(6): 379-389, November 27, 2024: 20 AEX companies, one set of annual results. doi.org
Gladstone Place Partners survey, as discussed on the CLS Blue Sky Blog, Columbia Law School, September 25, 2026; no sample size given. clsbluesky.law.columbia.edu
Supreme Court of the United States, Matrixx Initiatives, Inc. v. Siracusano, No. 09-1156, decided March 22, 2011. law.cornell.edu
17 CFR 244.100, Regulation G, including the note on oral disclosures. law.cornell.edu
Davis Polk, "Interesting Findings from NIRI's Earnings Call Survey", July 28, 2014. davispolk.com
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