The 2026 SEC Disclosure Landscape Is Shifting: What Companies Need to Know

Key Trends in the 2026 SEC Disclosure Landscape

For public companies, the 2026 disclosure landscape will likely come with meaningful change. In addition to the fast-paced technological and geopolitical changes impacting these companies, the U.S. Securities and Exchange Commission (SEC) has committed to modernizing disclosure requirements for U.S. filing companies.

To help prepare for the year ahead, Nasdaq Lens™, an AI-native platform, was leveraged to analyze data from SEC filings and comment letters.* This analysis reveals a clear story of increased regulatory body attention and shifting corporate priorities across targeted areas, causing disclosure practices to evolve rapidly.
 

Key Takeaways

1. AI is accelerating. From risk factors to SEC comment letters, AI-related disclosures are accelerating at unprecedented rates.
2. Geopolitical and operational risks are in focus. Tariffs, trade wars, and supply chain vulnerabilities remain top concerns.
3. Sustainability narratives are shifting. While sustainability remains important, its declining prominence in filings signals a pivot toward technology and compliance.
4. Regulatory complexity is intensifying. With new risk categories emerging and traditional ones persisting, companies are adopting agile governance and disclosure frameworks.

Trends in SEC Comment Letters and Regulatory Focus (2020–2025)

Over the past five years, the regulatory environment has undergone significant transformation. SEC comment letters, which serve as critical communication tools, have seen a steady rise from 1,099 in 2020 to a peak of 1,498 in 2024.

While 2025 shows a temporary dip to 844 comment letters, likely driven by SEC leadership changes and a government shutdown, the underlying trend remains clear: scrutiny is intensifying, and the focus areas are shifting.

Traditional priorities remain, but new themes are emerging. MD&A, M&A, and non-GAAP disclosures continue to dominate the SEC’s attention, yet the surge in AI-related disclosures is striking, rising to the seventh most commented area in 2025. Segment reporting also appeared in the top 10 most commented areas, signaling heightened interest in transparency and operational clarity.

Conversely, revenue recognition dropped from the fifth to most commented area in 2024 to the sixth spot in 2025, suggesting a slight pivot away from legacy accounting concerns toward emerging technology and data-driven risks.
 

How AI and Geopolitical Risks Are Changing in 10-K Risk Factor Disclosures

Risk factor trends identified in 10-K filings echo these shifts. While core risks such as cybersecurity and data protection, competitive pressures, and regulatory changes have remained stable, the real story lies in the rise of new risk categories. AI appears as a standalone risk factor in 33% of filings in fiscal year 2025 10-K filings.

This is up from just 1% three years ago, underscoring AI’s rapid evolution from a niche concern to a mainstream business priority. Tariffs and trade wars also show meaningful adoption, with 41% of fiscal year 2025 10-K filings highlighting it as a standalone risk factor.

From 2023 to 2025, regulation and regulatory changes, M&A, equity and stock-related issues, AI, and financial reporting and controls accounted for nearly 40% of all new risk disclosures. This concentration highlights that companies are doubling down across compliance, deal activity, and technology areas.

Meanwhile, business-specific risk factors, such as activist investor actions, share repurchases, and strategic business model shifts, reveal a dynamic environment where governance and shareholder expectations continue to reshape corporate priorities.
 

AI Mentions Surge While Sustainability Language Declines in SEC Filings

Perhaps the most dramatic signal of change comes from SEC filings’ language trends, which offer a real‑time look at shifting corporate priorities. As companies prepare for evolving regulatory expectations, the language appearing most frequently in filings reveals where attention—and risk identification—is quickly accelerating. The data shows a clear tilt toward technology and geopolitics, while sustainability‑related terminology is beginning to recede.
 

AI‑Related Terminology Is Dominating Filings

AI‑related keywords are appearing at unprecedented rates across 2025 SEC filings, reflecting the rapid adoption of AI tools, model governance frameworks, and automation strategies across industries. This surge suggests that companies are increasingly acknowledging AI as both a strategic asset and a material risk.

• “AI agent” mentions surged 6,550% year‑over‑year.
• “GPU” references rose 189% as compute requirements and infrastructure investments grow.
• “Artificial intelligence” mentions increased 39%, cementing AI as a mainstream disclosure category.

These increases indicate not only more widespread AI deployment, but also greater awareness of regulatory, operational, and ethical implications tied to AI systems.
 

Geopolitical Focus Is Accelerating

In addition to technology‑focused disclosures, geopolitical concerns are also rising sharply. Companies continue to face uncertainty around global trade, supply chain dependencies, and shifting alliances. That tension is reflected in the filings:

• “Tariffs” appeared 163% more often across filings.

This spike reinforces how trade policies and global instability remain persistent areas of concern for public companies navigating cross‑border operations.
 

Sustainability Language Is Declining

While sustainability remains an important long‑term theme for many organizations, its prominence in SEC filings has declined as companies rebalance toward more immediate regulatory and technological issues. Mentions of key environmental and social‑related terms have fallen notably:

• “Net zero” references fell 19% year‑over‑year.
• “DEI” mentions dropped 71%, highlighting a significant shift in corporate messaging.

These declines suggest that companies are adjusting their disclosure strategies—moving away from broader purpose‑driven language toward more operational, compliance‑driven priorities.
 

New Regulatory Terms Are Emerging

At the same time, new terms are entering filings at scale, signaling how emerging legislation and regulatory proposals are already influencing corporate reporting. One of the newest and most notable examples is the:

• “One Big Beautiful Bill Act” (OBBBA), which appeared more than 11,000 times across filings.

This early volume indicates that companies are beginning to assess and integrate new regulatory frameworks into their disclosures long before formal compliance deadlines arrive.
 

What Companies Should Consider in Preparing for 2026 SEC Disclosure Changes

The data paints a clear picture: business risks and practices are moving at a rapid pace. Traditional risk factors like cybersecurity and regulatory compliance remain foundational, but the explosive rise of AI-related disclosures and the resurgence of geopolitical concerns signal a new era of complexity. Meanwhile, sustainability narratives remain relevant, but their declining prominence in filings signals a pivot toward technology adoption and compliance readiness.

In this dynamic environment, companies need advanced, AI-powered tools to help manage growing complexity and stay ahead of rapid change. Nasdaq Lens is an AI-native platform designed for finance, legal, sustainability, and risk teams. The platform helps streamline research and compliance activities with domain-specific workflows, automate regulatory gap analysis and benchmarking, and delivers source-cited insights in minutes.

To benchmark and draft your company’s risk factors using AI, book a complimentary 1:1 risk factor session with Nasdaq: nasdaq.com/solutions/nasdaq-lens/risk-factor-drafting.

_{*Analyzed 10-K, 10-Q, 20-F, 40-F, DEF 14A, and SEC comment letters over the last four fiscal years of companies over $250M in market capitalization. Annual comparisons use stub periods and data is compared using consistent periods for each year. Data as of November 20, 2025.}