The pace of change in the external risk environment has been unrelenting over the past 12 months, as US companies have faced an unprecedented and highly dynamic set of external drivers impacting their businesses. These drivers have included significant political and regulatory shifts, a complex business environment combining low economic optimism and high interest rates with fairly stable economic growth and labor markets, ongoing and mutating global conflicts and other geopolitical challenges, and substantial disruptions in the global trade environment.

Deloitte and the USC Marshall School of Business Peter Arkley Institute for Risk Management (USC Marshall Peter Arkley Institute for Risk Management) have completed our fifth year of analysis of annual risk factor disclosures of Standard & Poor’s (S&P) 500 companies. Although the Securities and Exchange Commission (SEC) sought to reduce the volume of risk factor disclosures in its 2020 risk reporting reforms, companies have provided lengthier risk factor disclosures this past reporting season reflecting this complex and dynamic environment.

This year, we also conducted a review of the first quarterly reports filed after April 2, 2025 to understand whether companies chose to update their risk factors to reflect any material changes since the filings of their annual reports, an update required by SEC regulations. In fact, over 75% of companies did not update their risk factor disclosures. However, 94 companies did, either restating their risk factors in their entirety or disclosing one to seven stand-alone risk factors. As expected, many of these updated risk factors related to evolving trade policies, government funding and/or contracting, and corporate sustainability reporting.

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