Insights Analyst Raquel Oliveira has done a deep dive analysis of 175 Item 1A Risk Factor disclosures from 10-K and 20-F filings submitted to the SEC — the five largest US-listed companies in seven sectors for fiscal years 2021–2025. Each filing was scored across ten risk themes. Here’s what was found.
In 2021, the average company in this analysis disclosed roughly 10,102 words of risk factors. By 2025, that number had grown to 13,119 words.
Technology companies increased their disclosure volume by approximately 63%. Energy companies, which were among the least verbose risk disclosers in 2021, expanded by 103%. Retail grew by 49%. The shocks did not resolve sequentially. They compounded. Supply chain fragility rebuilt after COVID, then broke again under tariffs. Macro risk peaked not in 2022 at peak inflation, but in 2025, after rates had been cut.
AI governance obligations arrived just as geopolitical fragmentation was forcing supply chain redesigns. ESG commitments became liabilities in the same year they were being completed. The organizations that will navigate the next five years are not those with the most comprehensive risk registers. They are those that have abandoned the annual cycle entirely — continuously monitoring the external environment and building intelligence into strategy before risks appear in their own filings.
In this edition, we’re highlighting 3 key findings from our recently published ‘The Evolution of Risk: An Analysis of Enterprise Risk Disclosures’ report.
- Risk Timeline: Year-over-year growth for average disclosure volume
- Risk Priority: How Board priorities shifted over the last 5 years
- Risk Themes: Growth of risk mentions across themes
Risk Timeline: Corporate risk transitioned from pandemic-driven supply and labor shortages to geopolitical-induced commodity volatility and systemic inflation
Across all 175 filings, average disclosure volume rose from approximately 10,000 words in 2021 to over 13,000 by 2025, but this average masks significant divergence across sectors.
Technology shows the steepest sustained growth across all five years, driven by successive waves of new disclosure obligations, including AI risk, export control exposure, and mandatory cybersecurity governance. Auto and Retail also grew steadily throughout the period, reflecting expanding EV transition complexity and digital infrastructure risk, respectively.
While all sectors are feeling the pressure, the impact is highly divergent: Technology is grappling with waves of new obligations, such as export controls and cybersecurity governance, while Energy is responding to sudden commodity and regulatory shifts.
Risk Priority: AI & Automation and Cybersecurity & Data Privacy moved to the top of the agenda
How did Board priorities shift over the last 5 years?
Each row tracks how prominently a risk theme featured in the Item 1A (Risk Factors) sections of annual 10-K filings submitted to the SEC by the top five US-listed companies across seven sectors, totaling 35 companies and representing over $15 trillion in combined market capitalization.
Ratings reflect both the frequency with which a theme appeared and the materiality of the language used: a theme rated Very High dominated filings in explicit, forward-looking terms; a theme rated Low indicates the theme was either absent or mentioned only in passing. Ratings are based on qualitative analysis of year-over-year changes in filing language and are not derived from a quantitative scoring model. They are designed to show direction and momentum — where risk attention is moving, rather than to assign absolute values.
Our qualitative analysis shows that AI and Automation Risk moved from Low in 2021 to Very High by 2025, making it the fastest-growing risk theme across all sectors. During this same window, Cybersecurity and Data Privacy also reached a Very High rating, proving that technological and regulatory maturation has forced these themes from secondary operational concerns to the top of the board agenda.
Risk Themes: AI & Automation is the fastest-growing theme, with mentions up 658%
AI & Automation is the fastest-growing risk theme across all sectors by a wide margin, with mentions up 658% and dedicated word count up 711% between 2021 and 2025, while Regulatory & Compliance remains the highest-volume theme but shows the slowest growth of any category.
Final thoughts
Organizations that disclosed 13,000 words of risk factors this year are already behind. The ones ahead abandoned the annual cycle entirely; monitoring continuously, not retrospectively. The single most important operational change for modern risk management is the shift from Quarterly Reporting to Continuous Monitoring.
Now what?
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