S&P 500 / THE 2026 DISCLOSURE STUDY

AI is now in
the risk disclosures.

Nearly every extracted S&P 500 risk section mentions AI. Far fewer business descriptions do. We read the filings to measure the gap.

THE DISCLOSURE RECORDITEM 1A / 2026
95.2%

AI is in almost every
extracted risk section.

458 mention AI23 do notOne mark, one filer. 481 extracted S&P 500 risk sections.
Latest 10-K filed by 22 October 2026. Automated extraction.
ORIGINAL ANALYSIS / PUBLIC RECORDSAutomated extraction. Manual review pending.

01 / THE BRIEFING

The finding.
Not the inference.

This is a study of what companies disclose. It does not measure AI adoption, exposure or incidents.

Read the methodology

Before you cite: the manual review of 30 sentences is not yet complete. Figures report automated extraction. Verification & limits

  • 95.2%

    AI appears in 458 of 481 extracted latest risk sections.

    458 of 481 registrants with extractable Item 1A, newest 10-K filed by the 22 Oct cutoff

  • 60.6%

    All-filer AI mentions rose from 5.9% in 2019 to 60.6% in 2026.

    3,724 of 6,142 documents dated 1 Jan to the 22 Oct cutoff; 368 of 6,285 in 2019

  • 25.6%

    Generative AI language appears in one in four 2026 filings.

    1,572 of 6,142 annual reports in 2026; 55 of 6,794 in 2023

  • 57.1%

    Business sections mention AI less often than risk sections.

    267 of 468 filers for Business and 446 of 468 for risk factors, same 10-Ks

  • 83.0%

    AI and security or fraud appear together in risk sentences.

    380 of 458 registrants with AI in Item 1A

02 / INSIDE THE FILINGS

Three views of
the disclosure gap.

Each view answers a different question.
Keep its population and denominator attached.

01

What the headline number means

We read the risk factors in the latest 10-K for 481 large US filers. Our search found artificial intelligence in 458 of them. Two years earlier, the same test hit 315 of 471 filings.

Most companies that were silent two years ago have since written AI into their risk factors. Of the 156 that had no AI language then, 132 added some.

This counts mentions, not exposure. A single sentence counts as much as a full page. Think of the number as a record of what companies chose to tell investors in writing.

FIG. 01

From two-thirds to almost all.

S&P 500 filers mentioning AI in their risk factors

S&P 500 companies mentioning AI in Item 1A risk factors. About 2 years earlier: 66.9%, 315 / 471 extracted sections; Latest 10-K: 95.2%, 458 / 481 extracted sections0255075100%About two years earlier66.9%315 / 471 extracted sectionsLatest annual report95.2%458 / 481 extracted sectionsSame constituent snapshot. Different extraction bases.S&P 500 companies mentioning AI in Item 1A risk factors. About 2 years earlier: 66.9%, 315 / 471 extracted sections; Latest 10-K: 95.2%, 458 / 481 extracted sections0255075100%About two years earlier66.9%315 / 471 extracted sectionsLatest annual report95.2%458 / 481 extracted sectionsSame constituent snapshot. Different extraction bases.

28.3 percentage points separate the two readings. Extraction bases differ; this is not a fixed-panel change estimate. Latest filing cutoff: 22 October 2026.

The extraction bases differ: 315 of 471 older risk sections and 458 of 481 latest risk sections. Both use the 23 October 2026 constituent list, not the historical index membership.Source: Paloren analysis of newest and older annual reports for index constituents (Wikipedia snapshot, 23 Oct 2026).

Source CSV
View exact values
S&P 500 companies mentioning AI in Item 1A risk factors
CategoryValue (%)
About 2 years earlier66.9%
Latest 10-K95.2%
02

The wider filing population

We zoomed out to every 10-K, not just the index. Mentions climbed from 5.9% of annual reports in 2019 to 60.6% this year. Generative AI wording barely existed in 2023 and now turns up in a quarter of 10-Ks.

Strip out asset-backed trusts and blank-check shells and the picture gets sharper, from 6.6% to 72.6%. These counts come from EDGAR's search engine, which matches phrases. It doesn't read what the sentence says.

FIG. 02

AI language has moved into the mainstream.

Share of all 10-K filings mentioning artificial intelligence

Share of 10-K filings mentioning artificial intelligence, 2019 to 2026. 2019: 5.9%; 2020: 7.7%; 2021: 10.4%; 2022: 14.2%; 2023: 16.5%; 2024: 34.8%; 2025: 49%; 2026: 60.6%0204060% OF FILINGS5.920197.7202010.4202114.2202216.5202334.8202449202560.6%2026+18.3 points in 2024Largest annual increase in this seriesSame window each year: 1 January - 22 OctoberShare of 10-K filings mentioning artificial intelligence, 2019 to 2026. 2019: 5.9%; 2020: 7.7%; 2021: 10.4%; 2022: 14.2%; 2023: 16.5%; 2024: 34.8%; 2025: 49%; 2026: 60.6%0204060% OF FILINGS5.9'197.7'2010.4'2114.2'2216.5'2334.8'2449'2560.6%'26Same window each year: 1 January - 22 October

The largest annual step is in 2024: 16.5% to 34.8%, a rise of 18.3 percentage points. Endpoint counts: 368 of 6,285 filings in 2019; 3,724 of 6,142 in 2026.

The chart includes asset-backed trusts and blank-check firms. Excluding them, the share runs from 6.6% in 2019 to 72.6% in 2026. These are phrase matches from EDGAR search, not a manual review of every sentence.Source: EDGAR full-text search counts and EDGAR full index, all 10-K filings dated 1 Jan to 22 Oct of each year.

Source CSV
View exact values
Share of 10-K filings mentioning artificial intelligence, 2019 to 2026
CategoryValue (%)
20195.9%
20207.7%
202110.4%
202214.2%
202316.5%
202434.8%
202549%
202660.6%
03

Risk is written more often than the business

Across 468 registrants where we could pull both sections, about 57% mention AI in the business description. Nearly all of the same firms, 95.3%, mention it in the risks.

If you read only the business section, you'll miss most of the story. Anyone using these documents to judge strategy should read both halves.

FIG. 03

The risk section tells a different story.

AI mentions in two sections of the same 468 annual reports

Business section versus risk factors, same 468 companies. Item 1 Business: 57.1%, 267 / 468 filers; Item 1A Risk factors: 95.3%, 446 / 468 filers0255075100%Item 1 / Business57.1%267 / 468 filersItem 1A / Risk factors95.3%446 / 468 filersSame filers. Same reports. Different sections.Business section versus risk factors, same 468 companies. Item 1 Business: 57.1%, 267 / 468 filers; Item 1A Risk factors: 95.3%, 446 / 468 filers0255075100%Item 1 / Business57.1%267 / 468 filersItem 1A / Risk factors95.3%446 / 468 filersSame filers. Same reports. Different sections.

A 38.2-point gap within a matched sample. This is a comparison of disclosure, not a measure of AI use. Latest filing cutoff: 22 October 2026.

It's a rough cut. We find each section by its line-start heading, which will miss some sections, and the comparison covers 468 companies in our sample.Source: Paloren analysis of newest annual reports, index companies with both sections extracted.

Source CSV
View exact values
Business section versus risk factors, same 468 companies
CategoryValue (%)
Item 1 Business57.1%
Item 1A Risk factors95.3%
THE INTERPRETATION / AARON AGIUS
Ninety-five percent of the S&P 500 now mention AI in their risk factors, but only about half mention it when they describe the business. Companies have written down what AI could do to them faster than what it does for them.
Aaron Agius
Co-founder, Paloren
04 / THE SECURITY CONNECTION

Risk language often sits next to security and fraud

We counted that roughly four in five filers that mention AI in their risks (380 of 458) put it in the same sentence as a cybersecurity or fraud term at least once.

That pairing shows the two topics sit together on the page. It tells you nothing about how seriously the company takes the threat or whether anything has happened.

05 / THE BOARDROOM QUESTION

What boards should ask for

A risk paragraph costs an afternoon. A working inventory of AI systems, a data boundary and a named owner take much longer.

The filings don't show which companies have done that groundwork. Board members and reporters can ask for it directly.

03 / ACROSS THE INDEX

Not just
a tech story.

The latest risk-section share is at least 75% in every sector. The bars show older and latest readings, not a measure of risk severity.

Sectors follow the 23 October 2026 index snapshot. Extraction bases differ between periods.

FIG. 04 / THE SECTOR VIEW

AI risk language reaches across the index.

Share mentioning AI in risk factors, by sector

Sector comparison of AI mentions in risk factors. Exact counts are in the data table.Older reportLatest report0255075100%OLDER / nLATEST / nCommunication Services95.0% / 2095.5% / 22Consumer Discretionary68.9% / 4597.8% / 45Consumer Staples71.9% / 32100.0% / 32Energy *36.8% / 1978.9% / 19Financials80.9% / 68100.0% / 69Health Care64.9% / 5793.1% / 58Industrials54.5% / 7796.2% / 79Information Technology88.9% / 72100.0% / 74Materials39.1% / 2375.0% / 24Real Estate51.7% / 2996.6% / 29Utilities44.8% / 2990.0% / 30Sector comparison of AI mentions in risk factors. Exact counts are in the data table.Older reportLatest report0255075100%Communication ServicesOlder 95.0% / n=20Latest 95.5% / n=22Consumer DiscretionaryOlder 68.9% / n=45Latest 97.8% / n=45Consumer StaplesOlder 71.9% / n=32Latest 100.0% / n=32Energy *Older 36.8% / n=19Latest 78.9% / n=19FinancialsOlder 80.9% / n=68Latest 100.0% / n=69Health CareOlder 64.9% / n=57Latest 93.1% / n=58IndustrialsOlder 54.5% / n=77Latest 96.2% / n=79Information TechnologyOlder 88.9% / n=72Latest 100.0% / n=74MaterialsOlder 39.1% / n=23Latest 75.0% / n=24Real EstateOlder 51.7% / n=29Latest 96.6% / n=29UtilitiesOlder 44.8% / n=29Latest 90.0% / n=30

Every extracted latest report in financials, consumer staples and information technology mentions AI in its risk factors.

* Energy has only 19 extracted latest reports. Older and latest extraction bases differ. Both use the 23 October 2026 constituent snapshot, not historical index membership.Source: Paloren analysis of SEC EDGAR annual reports; sectors from the Wikipedia index snapshot, 23 Oct 2026.

Source CSV
View all sector counts and denominators
Sector breakdown, newest and older annual report
SectorLatest 10-K: AI in risk factorsOlder 10-K: AI in risk factorsCompanies extracted (latest)
Communication Services21 of 22 (95.5%)19 of 20 (95.0%)22
Consumer Discretionary44 of 45 (97.8%)31 of 45 (68.9%)45
Consumer Staples32 of 32 (100.0%)23 of 32 (71.9%)32
Energy (small sample)15 of 19 (78.9%)7 of 19 (36.8%)19
Financials69 of 69 (100.0%)55 of 68 (80.9%)69
Health Care54 of 58 (93.1%)37 of 57 (64.9%)58
Industrials76 of 79 (96.2%)42 of 77 (54.5%)79
Information Technology74 of 74 (100.0%)64 of 72 (88.9%)74
Materials18 of 24 (75.0%)9 of 23 (39.1%)24
Real Estate28 of 29 (96.6%)15 of 29 (51.7%)29
Utilities27 of 30 (90.0%)13 of 29 (44.8%)30

04 / THE AUDIT TRAIL

The method.
And its limits.

Two analyses, kept separate. Public sources. No estimates for missing filings.

VERIFICATION STATUSAutomated checks complete.

Manual sentence review pending.

What we analysed

We ran two checks, and we kept them separate. Analysis A counts 10-K annual reports filed from 1 January to 22 October in each year from 2019 to 2026, using EDGAR full-text search for the phrases. Analysis B reads the latest and an older 10-K for each S&P 500 constituent, then extracts Item 1 (Business) and Item 1A (Risk factors) from the filing text.

The latest filing is the newest 10-K dated on or before the 22 October cutoff. The older one is the filing closest to two years earlier, and it only counts if it falls within six months of that target. A company missing either filing drops out of that comparison. We don't estimate its numbers.

The company list is the index snapshot taken on 23 October 2026. Firms that left before then aren't in the sample.

Primary records & constituent list

  1. 01EDGAR full-text search
  2. 02EDGAR full index (form.idx)
  3. 03EDGAR submissions (SIC codes and filing lists)
  4. 04Wikipedia, list of S&P 500 companies (snapshot 23 Oct 2026)

Definitions and exclusions

Each share is a count divided by the number of companies or filings in the stated sample. Companies or filings that could not be read are excluded, never estimated.

What this cannot tell you

  • Analysis A counts EDGAR search hits for each phrase. It doesn't re-check every hit against the document text, so false positives are possible.
  • Mention is not exposure. We don't rate how seriously a company takes an AI risk, and we don't know whether it has suffered an incident.
  • Text extraction relies on line-start headings. Where a section couldn't be extracted, that company drops out of the comparison. The failure list is in the downloads.
  • The list is a snapshot, so registrants that left the index before 23 October 2026 aren't included. Energy has only 19 firms extracted in the latest annual reports, which makes its share a small sample.

How we verified

An independent script recomputed every number on this page from the cached EDGAR files. A separate reviewer checked the results, and all 68 checks passed.

The manual review of 30 extracted sentences isn't finished. The reviewer verdict column is still blank, so this study reports automated extraction only.

05 / OPEN DATA

Every number.
Yours to inspect.

Download the source tables. Each chart also has SVG and PNG exports, including its source and sample notes.

06 / FOR THE NEWSROOM

A source,
not a sales pitch.

Use the findings with credit to Paloren Research. Retain the sample and methodology notes when reporting a figure.

Request comment
THE INTERPRETATION / AARON AGIUS
A risk factor tells investors someone is watching the risk. The question for boards is whether there is an inventory, a data boundary and a named owner behind that paragraph, or just the paragraph.
Aaron Agius
Co-founder, Paloren

Media enquiries

aaron@research.paloren.ai

Aaron Agius, co-founder of Paloren, is happy to talk through the numbers. Write to aaron@research.paloren.ai to book a slot.

How to cite this study

Aaron Agius (2026). S&P 500 AI risk disclosures, 2026. Paloren Research. Analysis of SEC EDGAR 10-K filings dated 1 January to the 22 October cutoff. https://paloren.ai/research/sp500-ai-risk-disclosures-2026

Paloren Research is a small team that measures how firms adopt and describe AI, using public records. We publish the data and the limits with every number.

BEFORE YOU REPORT

Worth
distinguishing.

How many filers went into the risk factor comparison?

458 of 481 companies with extractable risk factors in their latest 10-K mention AI. That is 95.2%.

Does mentioning AI in risk factors mean a company is at risk from AI?

Not by itself. We count mentions and don't rate severity. Around 83.0% (380 of 458) of the registrants that mention AI also pair it with cybersecurity or fraud in one risk sentence. That shows the topics sit together, not how big the exposure is.

How were the 10-Ks chosen?

We took the newest 10-K dated on or before the 22 October cutoff. The older one sits closest to two years earlier, within six months of that target. Among those older documents, 315 of 471 mention AI.

Why does the all-filer figure differ from the index figure?

We would not line those counts up. The all-filer count covers 6,142 10-K filings dated 1 January to the 22 October cutoff, matched by EDGAR search. The S&P 500 figure reads the risk section of 481 large firms. Those shares are 60.6% and 95.2%.

Can I cite these figures?

Yes, please do. Use the citation below, credit Paloren analysis of SEC filings, Oct 2026, and link to the study. The method section lists four limitations, and any quote should carry them.