Coronavirus Resource Hub

Legal and business insights on the COVID-19 pandemic

Our guidance for businesses on the legal, regulatory and commercial implications of the COVID-19 pandemic. Given the rapidly changing environment, we will update this page frequently. To receive the latest information quickly, join our mailing lists or manage your subscriptions from our alert sign-up page.

Topics by region


April 9 – Competitor Collaborations During COVID-19: The EU and UK Competition Law Perspective
The EC and CMA have launched various initiatives and published guidance to assist business in potential competitor collaborations.

March 30 – Antitrust Implications of Dynamic Pricing, Online Third-Party Seller Platforms and Price Gouging
All participants in the supply chain for essential goods affected by the pandemic should anticipate close scrutiny of their pricing practices, especially at the intersection between third-party marketplaces, technology-assisted pricing, and price gouging.

March 27 (Updated April 4, 2020) – EU Loosens State Aid Rules Amid COVID-19 Outbreak
The European Commission has committed to a quick clearance procedure for all aid measures that member states are planning to take supporting sectors directly affected by the pandemic.

March 27 – [Recorded webinar] Minding Your Antitrust Business During the COVID-19 Outbreak
Cooley’s antitrust team discussed managing merger review timelines, creating competitor collaborations, information exchanges and maintaining compliant pricing strategies.

March 25 –  DOJ and FTC Issue Statement to Expedite Antitrust Review For Coronavirus Competitor Collaborations
The statement recognizes that the COVID-19 response will required “unprecedented cooperation” and that the agencies will account for “exigent circumstances” in evaluating the antitrust impact of COVID-19-related collaborations, including expedited review of proposed collaborations.

March 23 – Will COVID-19 Impact Antitrust Review of M&A Deals + How Can Parties Minimize Disruption?
Cooley reviews antitrust FAQs for merging parties. (Updated April 2, 2020)

March 20 – UK Government Relaxes Application of Competition Law to Ease Grocery Supplies
The UK government has temporarily relaxed the application of competition law to enable supermarkets to cooperate with each other to maintain food supplies.

March 18 – DOJ Increases Enforcement Related to COVID-19
The DOJ's Antitrust Division has signaled it will step up enforcement in response to COVID-19.


March 23 –  Highlights of Hong Kong SAR Government’s Policies in Light of COVID-19
Hong Kong SAR government has implemented stricter immigration control and public health measures to help enterprises and individuals during the epidemic.

March 20 – Highlights of Chinese Government’s Policies in Light of COVID-19
We offer a high-level summary of policies published by the Chinese central government recently, which may have practical implication to the daily operations of our clients and companies who have a business presence in China or have a business connection with China.

Business restructuring & reorganization

March 23 – Fiduciary Duties and Financial Distress in the Time of COVID-19
With the COVID-19 pandemic threatening even well-performing companies, it is important to review the fiduciary duties owed by directors and officers and how discharging those duties may change in the face of financial distress.

March 19 – Guiding Borrowers and Creditors Through the Turbulence Created by COVID-19
Cooley’s business restructuring & reorganization lawyers are actively crafting intermediate solutions for businesses confronted with significant interruption and other complex issues.

Capital markets

United Kingdom

April 8 – UK FCA Publishes Policy on Recapitalisation Issuances by Listed Companies During COVID-19 Crisis
The UK Financial Conduct Authority (FCA) published a policy statement and two associated technical supplements on April 8, 2020, announcing a series of measures aimed at assisting companies to raise new share capital in response to the coronavirus (COVID-19) crisis and related disruption, while retaining an appropriate degree of investor protection.

April 2 – UK Pre-Emption Group Provides Temporary Additional Flexibility for Pre-Emption Disapplication Authorities
The UK Pre-Emption Group has issued a statement providing temporary additional flexibility for pre-emption disapplication authorities for UK listed companies which will apply under September 30, 2020. In certain circumstances, this will allow UK listed companies to undertake non-pre-emptive placings up to 20% of their existing issued share capital.


April 6 – FCC and FTC Crack Down on COVID-19 Robocall Scammers
The FCC and FTC warned three companies providing gateway services for COVID-19 robocall scammers that their access to US telecom networks will be shut down unless service to the scammers is cut off.

April 6 – FCC Adopts Order Setting Rules for COVID-19 Telehealth Funding
The FCC has released an order implementing the provision of the CARES Act that appropriated $200 million for use for telehealth and adopting a new Connected Care Pilot Program with $100 million in funding over the next three years.

March 31 – FCC Waives Additional Universal Service Rules for Rural Health Care Providers
The FCC has adopted a second order waiving additional universal service rules for entities that participate in its Rural Health Care Program, including extending the deadline to apply for new funds.

March 29 – CARES Act Provisions That Impact Telecommunications Industry
In addition to the provisions that affect businesses generally, the CARES Act contains several provisions that are targeted to the telecommunications industry, including $375 million in new government funding.

March 27 – FCC Announces Postponements
The FCC has postponed two scheduled spectrum auctions and the comment deadlines in four proceedings in response to COVID-19. (Last updated on March 27, 2020. This post will be updated if additional deadlines are changed.)

March 25 – FCC Permits Schools and Libraries to Make Wi-Fi Available to Public
The FCC has released a public notice confirming that schools and libraries receiving support from the federal Universal Service Fund can make their Wi-Fi networks available to the general public.

March 24 – FCC Warns of COVID-19 Scams
The FCC has issued a warning about phone- and text-based COVID-19 scams and has provided advice on how consumers and businesses can respond to scammers.

March 24 – FCC Grants Narrow Exemption to Robocall and Text Rules for COVID-19 Information
The FCC has issued a narrow order that allows healthcare providers, state and local health officials and other government officials to make autodialed and prerecorded calls and send text messages providing information on the COVID-19 outbreak but does not address how the emergency exemption applies to other entities.

March 24 – FCC Waives Universal Service Rules for Low-Income Consumers, Schools, Libraries and Rural Health Care Programs
The FCC has waived some of its universal service rules to ensure low-income customers continue to receive service and to permit carriers to offer additional low-cost or free services to schools, libraries and rural healthcare providers affected by the pandemic.

March 20 – Reminders for Broadcasters Facing COVID-19 Challenges
The FCC provided guidance for stations that may be sharing news and news gathering resources to cover COVID-19. We also remind stations of potential compliance obligations with the FCC’s accessibility rules regarding emergency programming.

Compensation & benefits

United States

April 2 – Employers Have an Opportunity to Provide Tax-Free Reimbursements and Payments to Employees
IRC section 139 provides employers with the ability to reimburse or cover certain employee expenditures on a tax-free basis in connection with the COVID-19 pandemic.

March 23 – Considerations for Private Companies in Connection With Implementing Salary Reductions
Private companies considering base salary reductions, whether on a limited basis or broadly across the organization, should be mindful of certain considerations and common pitfalls.

March 19 – Compensation Arrangements in Light of the COVID-19 Pandemic
Cooley lists considerations and proactive steps to assist companies in preserving the ongoing effectiveness of their equity incentive and other compensation arrangements in light of the COVID-19 pandemic.

United Kingdom

March 24 – Considerations for UK Companies to Take with Share Options and Other Compensation Arrangements in Light of the Coronavirus Pandemic
For UK companies, a list of considerations and proactive steps to assist UK companies in preserving the on-going effectiveness of their option plans (including specific EMI considerations) and other compensation arrangements in light of the COVID-19 pandemic.

Contracts + commercial litigation

April 3 – Contractual Tools for Customers in Managing Ongoing Service Provision During COVID-19
Whether or not service providers seek to rely on force majeure provisions to excuse non-performance, customers will be well-served in familiarising themselves with other contractual tools available to them in order to manage the ongoing provision of services which remain unaffected by COVID-19, mitigate the effects of COVID-19 on those services which are affected and safeguard their contractual position.

March 26 – The Effect of the COVID-19 Pandemic on Online Marketplace Providers
As marketplace providers are not generally party to user agreements made between the buyers and sellers, we have provided a checklist of key provisions in the online market agreements for market providers to look for and suggestions for future protections.

March 18 – COVID-19 and the Performance of Contracts in England and Wales
With the COVID-19 pandemic causing major disruption globally, the incidence of commercial parties seeking to avoid liability for failure to perform by reliance on force majeure clauses is set to increase.

March 18 – English Courts Give Guidance on Plans to Address COVID-19 Challenges
Lord Chief Justice announced that English courts are planning to continue with court hearings.

March 17 – Applicability of Force Majeure and Related Doctrines in Response to COVID-19
One recurring issue businesses will face through the COVID-19 pandemic is whether, in the face of unprecedented disruption, they still need to meet their contractual obligations.


United States

March 31 – Rigorous Privacy and InfoSec Requirements May Be in Store for Companies That Accept Government Equity Stakes
Robust federal laws that govern federal agencies’ privacy and information security practices may apply to companies that accept federal government aid under the CARES Act.

March 19 – US Guidance on Collection, Use and Disclosure of Personal Information to Combat COVID-19
As companies balance the privacy of their employees with the need to keep them informed and safe during the COVID-19 pandemic, there are key privacy and cybersecurity considerations to keep in mind.

United Kingdom

March 20 – Europe Issues Pragmatic Privacy Guidance for COVID-19 Data Processing
European data protection authorities have issued important guidance on the processing of personal data in connection with COVID-19.

March 20 – GDPR and Coronavirus: What Organisations in the UK Need to Know
The UK’s Information Commissioner’s Office has published advice to organisations and data subjects in respect of the coronavirus pandemic.

Debt finance

March 17 – Considerations for Borrowers and Lenders Navigating Existing Debt Facilities
In light of COVID-19, borrowers are reviewing terms of existing credit facilities to help weather uncertain times, and lenders are surveying their loan portfolios and weighing how to manage existing relationships.


April 6 – Accrediting Agencies Adopt Temporary Measures to Address COVID-19 Challenges
Following ED’s release of guidance to accrediting agencies on March 17, including the flexibility to bypass public comment periods and adoption by full agency membership, accreditors have been developing and adopting new (and notably temporary) policies to address COVID-19 challenges.

April 3 – Institutional Relief Under the CARES Act
The CARES Act authorizes ED to allow institutions to ease certain federal student aid requirements, provide relief for certain students and borrowers with federally held student loans and relax certain requirements.

March 30 – First Look at Postsecondary Institution Funding Under the CARES Act
The CARES Act allows ED to make grant funding available to institutions of higher education to transition to online learning in the wake of COVID-19.

March 25 – Legislative Fix Protects GI Bill Benefits
On March 21, President Trump signed into law S.3503, aimed at protecting student veterans benefits as more and more transition to online programs.

March 24 – Managing COVID-19 Disruption: ED Updates Guidance for Changes and Interruptions of Study
The US Department of Education has issued a supplemental FAQ to its March 5 guidance for interruptions of study.

March 23 – Managing COVID-19 Disruption: Key Student Privacy Requirements Remain Unchanged
As students of all ages urgently transition from a classroom to a virtual environment, concern over the protection of student privacy remains at a high level.

March 18 – Managing COVID-19 Disruption: Online Accessibility and Anti-Discrimination in Schools
The US Department of Education’s Office for Civil Rights released guidance on civil rights issues in education when responding to COVID-19.

March 13 – Managing COVID-19 Disruption: FERPA
The Department of Education released guidance for schools subject to FERPA requirements related to implementing plans in response to COVID-19. 

March 12 – Managing COVID-19 Disruption: Title IV Processing
On March 5, the US Department of Education issued guidance on Title IV processing flexibilities associated with the response to COVID-19 and has set up a website dedicated to COVID-19-related issues.

March 12 – Managing COVID-19 Disruption
The coronavirus is causing major disruption to education, with schools and colleges canceling classes, shutting down campus operations and offering programs online.


United States

April 6 – San Diego County Issues Revised COVID-19 Health Officer Order
San Diego County issues revised COVID-19 regulations for San Diego employers, including new requirements for social distancing protocols and cloth face coverings for certain essential businesses.

April 6 – US Labor Department Publishes Temporary Regulations for Emergency Family and Medical Leave Expansion Act + Emergency Paid Sick Leave Act
Key aspects regarding the Families First Coronavirus Response Act (FFCRA), including employee certifications for requesting sick leave and benefits under the FFCRA, employer certifications to obtain tax credits from the IRS under the FFCRA, the small business exemption that could allow employers with fewer than 50 employees to deny leave and benefits to employees under the FFCRA, and the interplay between local “stay at home” and similar orders and the FFCRA.

April 1 – Six Bay Area Counties and City of Berkeley Issue Revised Shelter-in-Place Orders
The updated shelter-in-place orders will remain in effect until May 3, 2020.

March 23 – Reducing Personnel Expenses in an Uncertain Economy
There are a variety of measures that employers may consider for short-term labor cost savings in response to the COVID-19 public health emergency.

March 20 – US Enacts Families First Coronavirus Response Act
The Family First Coronavirus Response Act will provide paid leave to various categories of workers impacted by the pandemic.

March 20 – New York State Enacts Law to Provide Sick Leave and Expand Benefit Eligibility for Quarantined Workers
Governor Andrew Cuomo signed a bill that immediately provides temporary sick leave to New York workers subject to quarantine orders.

March 19 – Governor Temporarily Modifies California's WARN Act for Employment Actions Taken in Response to COVID-19
Certain provisions of the California WARN Act are temporarily modified by Governor Gavin Newsom due to the COVID-19 state of emergency and related rapid changes in workforce needs.

March 17 – Bay Area Counties Issue Shelter-in-Place Orders Effective March 17
Six counties issued orders directing all individuals to shelter at their place of residence, except to provide or receive certain Essential Services, engage in certain Essential Activities or perform work for Essential Businesses and Governmental Services

March 6 – Proactive Steps for Employers to Take in Light of the Coronavirus (COVID-19) Outbreak
As COVID-19 spreads throughout the United States and around the globe, employers are wondering what they can or should be doing to ensure health and safety among their personnel. Cooley lists the key steps that employers should implement or consider implementing.

United Kingdom

April 1 – COVID-19 Key Developments in UK Employment Law: What You Need to Know
Updated guidance on the Coronavirus Job Retention Scheme and other developments impacting UK employment law.

March 25 – Reducing Staff Costs in an Uncertain Economy
The impact of COVID-19 on businesses in the UK is becoming increasingly apparent, causing many businesses to consider how they can reduce staff costs. This alert reviews the variety of measures that UK employers may consider to help manage business viability and continuity.

March 23 – UK Coronavirus Job Retention Scheme
The UK Government announced plans to set up a Coronavirus Job Retention Scheme as part of a package of temporary measures to support businesses amid the disruption caused by COVID-19.

Fund formation

March 27 – SEC Relaxes Conditions of Form ADV Filing Extension
In response to the developing COVID-19 situation, on March 25, 2020 the SEC issued a new order to relax certain conditions contained in a previous order issued March 13, 2020 applicable to Exempt Reporting Advisers (“ERAs”) and Registered Investment Advisers (“RIAs”) who need more time to file annual amendments to Form ADV.

Government contracts

March 19 – Trump Invokes Defense Production Act to Surge Industrial Capacity
President Trump issued an executive order invoking Section 101 of the Defense Production Act of 1950 in an effort to "surge capacity and capability to respond to the spread of COVID-19."


March 18 – Business Interruption Cover and the Coronavirus
The UK government announced that its current measures relating to the use of public spaces, such as bars and restaurants, would be sufficient to trigger some business interruption policies.

March 13 – Your Insurance Checklist for Coronavirus Losses
With many organizations likely to suffer substantial losses due to the COVID-19 pandemic, businesses should take several critical steps in order to maximize their insurance recovery.

March 6 – Coronavirus and Insurance Coverage
To the extent that existing policies currently provide coverage, either directly or indirectly, we can expect that the insurance market will react quickly and add additional exclusions for disease or quarantines to many existing insurance policies, at least until the current outbreak subsides.

Intellectual property

United States

April 2 – USPTO Extends Certain Deadlines in Response to COVID-19 Pandemic
The US Patent and Trademark Office has announced a 30-day extension for select patent and trademark filings.

United Kingdom

March 30 – UKIPO Extends Deadlines in Response to COVID-19 Pandemic
The UK Intellectual Property Office has extended, until further notice, deadlines for UK trade marks, designs, patents and supplementary protection certificates, as well as applications for these rights.

March 20 – EPO Extends Most Deadlines in Response to COVID‑19 Pandemic
The European Patent Office has announced that it will be extending some deadlines to 17 April 2020 and that this date may be further extended.

March 19 – EUIPO Extends Deadlines in Response to COVID-19 Pandemic
The EU Intellectual Property Office has announced that it is extending all time limits expiring between 9 March and 30 April inclusive that affect all parties in proceedings before the office to 1 May 2020.

March 18 – European Patent Office Informally Announces Intended Extension
The EPO has informally announced that it intends to extend all time limits to 17 April 2020 and that this date may be further extended.

Investment funds

March 17 – SEC Extension of Form ADV Amendment Deadline
The SEC has provided a conditional extension of the March 30, 2020, deadline for annual amendments to Form ADV. The extension applies to both Exempt Reporting Advisers and Registered Investment Advisers.


United States

April 8 – [Recorded webinar] Loans and Other Financial Assistance Under the Coronavirus Economic Stabilization Act of 2020 (CESA)
Key issues for businesses seeking loans under CESA will be examined along with practical advice on the procedures, requirements and future implications for CESA participants.

April 4 – SBA Programs Under the CARES Act: ‘Affiliation’ Interim Final Rules and Guidance
On April 3 the Treasury issued interim final rules and associated guidance on how to determine whether an entity is an affiliate of an applicant.

April 1 –  Treasury Releases New Procedures and Requirements for CARES Act Loans for Airlines and Businesses Critical to National Security
To allow prospective borrowers to begin preparing to submit their applications, on March 30, 2020, the Treasury released new procedures and minimum requirements for loans to airlines and businesses critical to the national security under the CARES Act. These new procedures and requirements may also be instructive for prospective borrowers under other portions of the Act in indicating the direction and scope of the Treasury’s requirements for loan applications.

April 1 – SBA Programs Under the CARES Act: Loan Application and Information Sheet Issued
A key feature of the CARES Act $2 trillion relief package is the creation of the Paycheck Protection Program (PPP), which authorizes $349 billion for businesses to obtain loans of up to $10 million per applicant to be used on payroll, benefits, rent and other costs from February 15, 2020, through June 30, 2020.

March 29 – CARES Act: What You Need to Know
The CARES Act is a $2 trillion relief package that provides much needed sources of liquidity for businesses, relief for the unemployed and incentives to businesses to keep workers employed, support for the healthcare system in combatting COVID-19 and other relief to help individuals and businesses in the United States withstand the harsh impact of COVID-19.

March 29 – SBA Programs Under the CARES Act: Are You Eligible for Federal Assistance?
We have addressed questions of business eligibility.

March 27 – Multiple Layers of Oversight in the CARES Act: The Appetite for Accountability Will Long Outlast the Current Crisis
The CARES Act creates several new investigative entities that will directly impact businesses receiving economic stimulus funds.

United Kingdom

March 23 – UK Government Proposes the Coronavirus Bill 2020 – Key Takeaways
On 19 March 2020, the UK Government published the Coronavirus Bill 2020, which sets out emergency powers and reforms to address the growing public health crisis. We outline the key takeaways for Cooley clients.

Life sciences

March 20 – COVID-19 Pandemic: FDA Recommendations for Companies Involved in the Conduct of Clinical Trials
The FDA has released guidance taking immediate effect that addresses the unique challenges to companies involved in the clinical development process due to the COVID-19 pandemic.

Mergers & acquisitions

March 23 – Long-Term Focus: Preparing for Activism + Takeovers Amid COVID-19 Risks
It is especially important for companies, their boards and management teams to redouble their efforts to prepare for activist or otherwise hostile overtures amid COVID-19 market volatility.

March 17 – Public Company Hot Spots and M&A Negotiations with the Impact of COVID-19
Cooley M&A covers key issues that touch governance and M&A matters in our current environment.


April 7 – Nonprofit Guide to the CARES Act
Nonprofit organizations can take advantage of many of the relief options offered by the CARES Act.

April 7 – Four Fast Ways to Form a Charity to Address COVID-19-Related Matters
In the face of the COVID-19 outbreak, groups ranging from small neighborhood projects to large national initiatives are mobilizing quickly to help. Many of those groups have questions about whether they can achieve their goals by starting a nonprofit - that is, by forming a new entity that qualifies as a tax-exempt charitable organization under Section 501(c)(3) of the Internal Revenue Code.

Product liability + supply chain management

March 25 – Considerations for Manufacturers in Europe Switching to Production of Medical Supplies
Four key considerations for companies moving into manufacture and supply of medical supplies in Europe, with a view to assist in navigating the ever-changing regulatory environment and taking into account the significant time pressures involved.

March 18 – COVID-19 and Consumer Rights in the UK
Cooley lists considerations for UK companies regarding the significant impact the ongoing restrictions will have on businesses and their consumers.

March 9 – Disruption Caused by COVID-19
Many of the measures that have been taken or are under consideration by governments, businesses and other organisations are already having or will have a significant effect on commercial relationships and commercial life generally.

February 26 – Coronavirus Gives Companies Sourcing Headaches
The spread of the coronavirus has had a disruptive impact on the global economy – and the market has reacted to that anxiety.

Public companies

United States

April 7 – Corp Fin staff extends conditional relief to incorporation of Part III information
The Corp Fin staff has extended the conditional relief provided by the March 25 COVID-19 order to the filing of Form 10-K, Part III information.

April 7 – Delaware Emergency Order Provides Relief Regarding Changes to Annual Meetings
Delaware Governor issues emergency order easing notice requirements for companies to change physical annual meetings to virtual-only annual meetings.

April 7 – SEC Chair Clayton Highlights Need for Complete Disclosure Even if Periodic Reports are Delayed due to COVID-19
In a statement issued on April 2, SEC Chair Jay Clayton emphasized that, although the timing of certain company filings may be impacted by COVID-19, the SEC is “keenly focused on ensuring that issuers and other registrants continue to provide material information to investors, including information related to the current and expected effects of COVID-19, as promptly as practicable.”

April 7 – SEC Chief Accountant Addresses CECL and Accounting Estimates in Light of COVID-19
SEC Chief Accountant Sagar Teotia issued a statement that stressed the importance of continuing to provide high-quality financial information for investors and other stakeholders and addressed the challenge inherent in making estimates and judgments in an environment of uncertainty.

March 24 – SEC Emphasizes Need for Market Integrity in Context of COVID-19 Pandemic
On March 23 the SEC Division of Enforcement issued a brief cautionary statement which acknowledged the unprecedented impact of COVID-19 on the securities markets and emphasized the importance of “maintaining market integrity and following corporate controls and procedures.”

March 16 – COVID-19 Pandemic: Governance and Disclosure Considerations for Public Companies
With the COVID-19 outbreak now categorized as a global pandemic, we’ve briefly addressed certain frequently received questions pertaining to corporate governance and disclosure considerations for public companies.

March 13 – Guidance Provides Regulatory Flexibility Regarding Annual Meetings
In light of the spread of COVID-19, the SEC announced new Corp Fin staff guidance regarding annual meetings because of limitations on in-person gatherings and health and travel concerns.

March 4 – SEC Provides Conditional Relief Related to Coronavirus (COVID-19)
SEC officials issued an order providing “conditional regulatory relief for certain publicly traded company filing obligations.”

February 19 – SEC Issues Public Statement on Impact of Coronavirus on Financial Reporting and Audit Quality
In a public statement, the SEC provided guidance regarding the impact of the coronavirus on financial reporting and audit quality, as well as the potential availability of regulatory relief.

United Kingdom

March 30 – Updates for UK + European Capital Markets: FCA, FRC + PRA Joint Statement, AIM Guidance and ESMA Public Statement
Several key updates for UK and European capital markets have recently been released (focusing primarily on financial reporting), including a joint statement by the Financial Conduct Authority, Financial Reporting Council and Prudential Regulation Authority, an Inside AIM publication by the London Stock Exchange and a public statement from the European Securities and Markets Authority.

March 23 – UK FCA Asks Companies to Delay Preliminary Financial Statements Amid COVID-19
The UK Financial Conduct Authority has strongly requested that companies with securities listed on the Official List observe a moratorium on the publication of preliminary financial statements for at least two weeks.

March 23 – AIM Regulation Announces Temporary Measures to Support Companies, Nominated Advisers Amid COVID‑19
AIM Regulation announced temporary measures for applying discretion to the application of certain of the AIM Rules for Companies and AIM Rules for Nominated Advisers in light of restrictions and challenges due to COVID-19.

March 20 – UK Financial Reporting Season: UK Financial Reporting Council Publishes Guidance for Auditors on Audit Issues
The UK Financial Reporting Council issued updated guidance for auditors, which may be facing practical difficulties in carrying out audits as a result of the COVID-19 pandemic.

March 19 – COVID-19: UK Financial Conduct Authority Provides Commentary to Issuers and Market Participants
Cooley offers key takeaways from the March 17 UK Financial Conduct Authority’s Primary Market Bulletin.

March 18 – Market Abuse Regulation: Reminder of Ongoing Disclosure Obligations in the Context of COVID-19
Remember that issuers should disclose as soon as possible any relevant significant information concerning the impacts of COVID-19 on their fundamentals, prospects or financial situation in accordance with their transparency obligations under MAR.

March 18 – UK Financial Reporting Season: UK Financial Reporting Council Publishes Advice to Companies and Auditors on COVID-19 Risk Disclosures
Given the rapid spread of COVID-19 in the month since the guidance was published, the FRC advice on risk disclosures should be read more broadly.

March 17 (Updated April 7, 2020) – UK AGM Season: How to Deal With Challenges Posed by COVID-19
Actions UK public companies should consider taking to ensure their AGMs are compliant with the law and to facilitate shareholder participation in light of new challenges posed by COVID-19.

March 16 – COVID-19: Recent Statements by UK Financial Conduct Authority + European Securities and Markets Authority
Cooley gives a brief summary of recent statements by the UK FCA and ESMA on COVID-19.

Real estate

March 26 – Considerations for Landlords and Tenants
We have provided a list of provisions to review for language addressing what landlords and tenants can and cannot do to avoid breaching their leases.


United States

March 30 – CARES Act Provides Tax Relief in Response to COVID-19 Pandemic
The CARES Act provides federal income and payroll tax relief for businesses.

March 23 – US Treasury Moves Return Filing Deadline to July 15
The US Treasury has extended the deadline for filing federal income tax returns due April 15, 2020, to July 15, 2020.

March 19 – US Treasury Provides Relief for Taxpayers Amid COVID‑19 Pandemic
The US Treasury and IRS are extending the time to pay federal income taxes due on April 15, 2020, to July 15, 2020.

United Kingdom

March 23 – UK Tax Support: VAT and Self-Assessment Income Tax Deferrals, and Scaled Up Time to Pay Scheme
The UK Government announces deferral until 2021 of VAT payments for the next three months, and six month deferral of 31 July 2020 self-assessed income tax due from self-employed. It also sets up a dedicated helpline to improve access to its Time to Pay scheme.

March 19 – New UK Tax Rules on Off-Payroll Working: Postponed Until 2021
In a bid to support British business through the COVID-19 pandemic, the UK government has postponed the introduction of changes to the UK’s off-payroll working rules (IR35), from April 6, 2020, until April 6, 2021.

Trade secret litigation

April 7 – Protecting Trade Secrets in the Current Climate
Practical tips to protect your confidential information with a remote workforce, or though furloughs and staff reductions.

Venture capital investing

March 9 – Q4 2019 Quarterly VC Update: Impact of Coronavirus on Chinese VC Market
By the time of publishing, the coronavirus had become a significant factor in the state of venture capital investing and, more broadly, our global economy. This discussion spotlights the burgeoning impact of it on the Chinese market, as well as how Qiming’s portfolio is assisting with the response.

White collar

March 20 – Remaining Vigilant to Compliance and Enforcement Concerns in Times of Crisis
Companies and executives need to be especially attuned to signs of potential fraud and criminal activity during this economic and health crisis. The temptation to take shortcuts can saddle a company with investigations and liability for years to come.

Government + legal resources

Media commentary

COVID-19 Contacts
Barbara Borden Partner, San Diego
Wendy Brenner Partner, Palo Alto
Nicole Brookshire Partner, Boston
Rod Freeman Partner, London
Jacqueline Grise Partner, Washington, DC
J.G. Harrington Special Counsel, Washington, DC
Greg Hoffnagle Special Counsel, New York
Matthew Johnson Special Counsel, Washington, DC
Heidi Lawson Partner, Boston
Joshua Mates Partner, San Francisco
Chadwick Mills Partner, San Francisco
David Mills Partner, Washington, DC
Adam Ruttenberg Partner, Washington, DC
Gregory Tenhoff Partner, Palo Alto
Jay Vaughan Partner, Washington, DC