BlackRock, Inc. (BLK) Risk Factors

Recent key developments

Concrete developments — dated events, named agreements and instruments, legal proceedings — that BlackRock, Inc. surfaced in its latest filing.

• At December 31, 2025, BlackRock's net economic investment exposure was approximately $4.9 billion, primarily from co-investments and seed investments in sponsored investment funds.December 31, 2025
• As of December 31, 2025, the amount of securities on loan subject to indemnification was approximately $353 billion, with cash and securities collateral held for indemnified loans totaling approximately $375 billion.December 31, 2025
• Performance fees represented $1.4 billion, or 6%, of total revenue for the year ended December 31, 2025.December 31, 2025
• Acquisitions include the GIP and HPS Acquisitions.
• Iran Threat Reduction and Syrian Human Rights Act of 2012 requires disclosure of certain Iran-related activities.2012
• FSB and IOSCO workstreams may lead to new regulations in multiple jurisdictions.
• EU launched a consultation on macroprudential policies in 2024, including enhanced requirements for liquidity management tools.2024
• UK consultation in December 2023 indicated intent to change regulatory requirements for MMFs, including material increases in required liquidity levels.December 2023
• SEC adopted changes to Rule 2a-7 under the Investment Company Act of 1940, including changes to required liquidity levels and mandatory liquidity fees.
• ISSB disclosure standards adopted by national regulators in Hong Kong, Mexico, Singapore and Australia, with UK, Canada and Japan expected to issue ISSB-aligned standards.
• California passed laws requiring climate-related disclosures, with Senate Bill 261 enforcement stayed by Ninth Circuit injunction pending appeal in November 2025.November 2025
• European Parliament and Council approved proposals to simplify and reduce scope of CSDDD and CSRD in December 2025.December 2025
• European Commission published SFDR 2.0 proposal in November 2025 to revise Sustainable Finance Disclosure Regulation, introducing three new categories of sustainable and transition products.November 2025
• EU and UK are developing rules for ESG ratings providers; Japan, Singapore and India have published codes of conduct or regulatory frameworks for ESG data and rating providers.
• FTC and DOJ approved October 2024 amendments to HSR rules that significantly expanded required HSR filing information, potentially increasing pre-merger notification expenses and delaying transactions.October 2024
• FTC and DOJ issued updated merger guidelines in December 2023 that could impact BlackRock’s ability to expand through acquisitions and funds engaging in transactions affecting US commerce.December 2023
• FSOC finalized amendments in November 2023 removing prioritization of an activities-based approach over entity-specific designation, potentially increasing the chance of BlackRock being designated as a SIFI.November 2023
• SEC adopted rules in December 2023 mandating central clearing of US Treasury repurchases and certain other Treasury transactions.December 2023
• SEC adopted a rule in 2023 requiring institutional managers to report short positions.2023
• SEC adopted a rule in 2023 requiring reporting of securities loan transactions.2023
• US outbound investment screening program from January 2025 restricts certain investments in designated 'countries of concern'.January 2025
• Fiscal 2026 National Defense Authorization Act authorizes US Treasury to expand the outbound investment regime.2026
• In 2025, SEC clarified guidance on when a 5% shareholder’s engagement could cause loss of Schedule 13G eligibility.2025
• FinCEN issued a final rule in 2024 requiring registered investment advisers to establish AML programs and report suspicious activity, with effective date pushed to January 2028.2024
• SEC adopted new rules and amendments to Form PF in 2024 requiring new disclosures and enhanced reporting, with compliance deadline extended to October 2026.2024
• The EU's Digital Operational Resilience Act (DORA) became applicable in 2025, introducing governance, risk management, incident reporting, resilience testing, and information sharing requirements.2025
• EMIR 3.0 was adopted in December 2024, introducing an 'active account' requirement at an EU central counterparty for clearing certain euro-denominated instruments.December 2024
• In November 2025, the EC proposed a Digital Omnibus package including a delay to high-risk AI rules, targeted GDPR changes, and streamlining of incident reporting obligations.November 2025
• Regulators in the EU, UK, and Switzerland have announced a transition to a T+1 settlement cycle by October 2027.October 2027
• In December 2025, the EC published a proposal for wide-ranging reforms to EU capital markets rules, including changes to the supervisory regime for asset managers.December 2025
• The UK's policies regulating services provided by certain third parties designated by HMT as 'critical' to the financial sector became effective in January 2025.January 2025
• FTC identified common ownership as a key enforcement area in 2021 and passed a resolution to investigate shareholder conduct.2021
• FTC and DOJ submitted a joint comment letter to FERC in 2024 encouraging consideration of common ownership.2024
• In January 2026, the OECD announced a package including a Side-by-Side System for multinationals with parents in certain jurisdictions like the US, which may mitigate adverse impacts of Pillar Two.January 2026
• OECD Pillar Two global minimum tax of 15% has been adopted by EU member states and other countries including the UK since the beginning of 2024.2024