Regulations May Change Around Print vs. E-Delivery

This information was originally published by Two Sides NA and is being excerpted here for AOTC readers with an interest in regulations and public perception regarding the value of paper, print, and printed media. Read the full article online.

Banks are driving a quiet rule change that could reshape paper financial and health communications. If you work in paper or print, you may have missed this quiet but consequential move in federal regulations.

Two agencies—the Securities and Exchange Commission (SEC) and the US Department of Labor—each proposed rules that would make electronic delivery the default way millions of Americans receive important financial and health information, rather than something they have to actively choose.

Neither proposal completely bans paper; both reserve the right to request it. But the shift from “default to paper unless you opt in to email” to “default to email unless you opt out” is a meaningful one, and it’s worth understanding exactly what’s being proposed—and where the consumer’s voice fits in the conversation.

That distinction matters more to consumers than either proposal acknowledges. According to the Two Sides NA 2025 Trend Tracker, eighty percent of US consumers say they should have the right to choose how they receive important communications—on paper or electronically—especially when dealing with financial and service providers.

What the SEC is Proposing

The SEC’s new Regulation E-Delivery would let issuers, broker-dealers, and investment advisers send prospectuses, shareholder reports, proxy statements, trade confirmations, and other required disclosures electronically without first getting an investor’s affirmative sign-off. The proposal is being driven and supported by large financial institutions at the expense of the consumer. Consumers already read the motive that way: 63 percent believe the government, banks, and other organizations want to persuade them to “go paperless”—and it is not truly paperless, since many still need to print hard copies at home. Today, paper is still the default unless someone elects otherwise; under the proposal, that flips. Chairman Paul Atkins framed it as retiring a “relic” default in favor of a modern one.

The rule includes a two-notice transition process, and paper delivery remains available on request. However, it is done via email which could be ignored, missed, or misidentified as spam or fraud.

What the DOL is Proposing

Separately, the Department of Labor’s Employee Benefits Security Administration proposed a new safe harbor that would let the roughly 2.8 million group health plans governed by ERISA deliver required disclosures digitally by default. The department points that these plans currently print and mail up to 11 billion sheets of paper a year with critical health care information.

The 60-day public comment window for both proposals is open and ends September 21, 2026.

Why This Matters Beyond the Headlines

It’s easy to read these as narrow regulatory housekeeping. But taken together, they represent two of the largest touchpoints Americans have with paper-based communication—investment accounts and health benefits—moving toward an opt-out model at the federal level. That’s a meaningful signal about how regulators are thinking about paper’s role going forward, and it’s the kind of shift that tends to ripple into how other industries frame their own “digital by default” decisions.

It’s also worth being clear-eyed about who these defaults affect most. Not every investor or plan participant is reliably online, confident navigating a portal, or comfortable storing sensitive financial and health documents digitally. That unease is widely held: 65 percent of Americans say they are increasingly worried that personal information held electronically is at risk of being hacked, stolen, lost or damaged.

Older Americans (and by default, their caregivers), rural households, and people with limited broadband access are disproportionately represented among those who still prefer—or need—paper. An opt-out model puts the burden on exactly the people least equipped to notice and act on it in time.

The Sustainability Argument Doesn’t Always Consider All the Data

There’s also a sustainability case that gets overlooked in these announcements. Paper is a renewable and recyclable material, and North America’s printing and writing paper comes largely from sustainably managed, replanted forests. “Going paperless” is often marketed as the automatically greener choice, but the environmental footprint of digital storage, data centers, and device manufacturing is real and rarely part of the conversation when agencies tout the savings from cutting paper use.

Where You Come In

There is a business risk in getting this wrong: nearly 46 percent of US consumers say they would consider switching providers if forced to go paperless—up from 41 percent in 2021. Both proposals still need to run their comment periods, and that’s where facts can shape outcomes.

If you are a consumer concerned about digital-only access or a business that touches financial services, healthcare benefits communication, or print and mail fulfillment for either sector, please share your voice as both rules move through the comment and finalization process. Both comment periods close September 21, 2026.

• Click here to submit your comments on S7-2026-25 Top of Form Electronic Delivery of Information Under the Federal Securities Laws.
• Click here to submit your comments on the Electronic Disclosure by Group Health Plans Under ERISA.
• You can also submit your comments using a coalition site for the SEC at ProtectPaperChoice.org
• Comments for the DOL can be made here: Take Action Now!

Paper isn’t going away. But mandating the defaults matters—and this is the moment to make sure paper’s value, and the people who rely on it, stay part of the conversation.

Two Sides North America is part of the non-profit Two Sides global network which includes more than 600 member companies across North America, South America, Europe, Australia and South Africa.  Member companies span the Graphic Communications and Paper-based Packaging value chain, including forestry, pulp, paper, paper-based packaging, chemicals and inks, pre-press, press, finishing, printing, publishing, envelopes and postal operations. Learn more about Two Sides.