Pay-performance sensitivity before and after SOX

The purpose of this paper is to investigate the impact on pay-performance sensitivity of the Sarbanes–Oxley Act (SOX), an effect that has been examined in prior research but with often conflicting findings. Using a more comprehensive sample of executives and of compensation components than in prior research, we compare managers’ pay-performance sensitivity before and after 2001–2002, a period during which regulatory changes were initiated to increase scrutiny over managerial manipulation and improve financial reporting quality. Based on ExecuComp data from 1992 to 2005 (and excluding the years 2001 and 2002), our results show that pay-performance sensitivity using either market-based or accounting-based measures of performance increased significantly following these events. When we further decompose executive pay into its cash-based and equity-based components, we find evidence of an increase in the link between performance and executive compensation for five of six measures for each performance metric. Thus, in contrast to most prior studies on the impact of SOX on executive incentives and compensation, our evidence is consistent with an improvement rather than weakening in the alignment of managerial and shareholder interests.