16 January 2025

White & Case: Considerations for updating risk factors in annual reports

New York-based law firm White & Case has set out five topics US companies should consider when updating their risk fact disclosures for their 2025 annual reports.

It recommends that companies consider AI, cybersecurity, climate change, US politics and international geopolitics when updating their risk factors.

In addition, White & Case offered four drafting recommendations for companies updating their risk factors.
It advises that companies:

  • Avoid boilerplate disclosures
  • Scrutinise hypothetical statements
  • Utilise financial models to support projections and forward-looking statements
  • Review for consistency across disclosures
  • Update or delete risk factors that have changed or are no longer relevant

Full article

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