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.

• Net economic investment exposure of approximately $4.9 billion at December 31, 2025, primarily from co-investments and seed investments in BlackRock's sponsored investment funds.December 31, 2025
• As of December 31, 2025, approximately $353 billion of securities on loan subject to indemnification, with approximately $375 billion of collateral held for indemnified securities on loan.December 31, 2025
• Performance fees represented $1.4 billion, or 6%, of total revenue for the year ended December 31, 2025.December 31, 2025
• The GIP Acquisition and HPS Acquisition have increased private markets as a component of performance fee generating assets.
• BlackRock has entered into strategic joint ventures, including a joint venture to provide investment solutions in India.
• The acquisitions include the GIP and HPS Acquisitions.
• Aladdin infrastructure and environment for BlackRock and its external Aladdin clients are hosted on Microsoft Azure and Amazon Web Services.
• BlackRock has migrated certain systems that support its corporate functions to cloud-based platforms.
• The EU launched a consultation on macroprudential policies in 2024, including enhanced requirements for liquidity management tools, which may increase oversight of OEFs.2024
• UK consultation released in December 2023 indicated intent to change regulatory requirements for MMFs domiciled in the UK and non-UK MMFs sold into the UK, 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 under certain circumstances.
• In November 2025, the Ninth Circuit granted an injunction pending appeal staying enforcement of California Senate Bill 261.November 2025
• In December 2025, the European Parliament and Council approved proposals to simplify and reduce scope of CSDDD and CSRD.December 2025
• In November 2025, the European Commission published SFDR 2.0 proposal to revise the Sustainable Finance Disclosure Regulation, introducing three new categories of sustainable and transition products.November 2025
• FTC and DOJ approved HSR rule amendments in October 2024 significantly expanding information required for merger filings.October 2024
• FTC and DOJ issued updated merger guidelines in December 2023 that could impact BlackRock's ability to expand through strategic investments or acquisitions.December 2023
• FSOC finalized amendments in November 2023 removing prioritization of activities-based approach, potentially increasing regulatory uncertainty.November 2023
• SEC adopted rules in December 2023 mandating central clearing of US Treasury repurchases.December 2023
• SEC's 2023 short position reporting rule requires certain institutional managers to report short positions to the SEC for aggregate publication.2023
• SEC's 2023 securities loan reporting rule requires reporting loan transactions to a registered national securities association; temporary exemptions until 2028.2023
• US outbound investment screening program beginning January 2025 prohibits US persons from certain transactions and requires notification for others involving advanced semiconductors, AI, and quantum computing in countries of concern.January 2025
• Fiscal 2026 National Defense Authorization Act authorizes Treasury to expand outbound investment restrictions.2026
• SEC's 2025 guidance on 5% shareholder engagement may cause shareholders to lose Schedule 13G eligibility.2025
• FinCEN's 2024 final rule requires registered investment advisers to adopt anti-money laundering programs and report suspicious activity under the Bank Secrecy Act; effective date pushed to January 2028.2024
• SEC's 2024 Form PF rules and amendments require enhanced reporting for registered investment advisers; compliance deadline extended to October 2026.2024
• DORA became applicable in 2025 and introduced governance, risk management, incident reporting, resilience testing and information sharing requirements to several of BlackRock's European entities and certain Aladdin clients.2025
• EMIR 3.0 was adopted in December 2024 and requires an active account with an EU central counterparty for clearing certain euro-denominated instruments, with initial compliance obligations effective from June 2025.December 2024
• In November 2025, the EC proposed a Digital Omnibus package that would delay high-risk AI rules, change GDPR to facilitate AI data use, and streamline incident reporting.November 2025
• EU, UK, and Switzerland regulators announced plans for T+1 settlement by October 2027.October 2027
• In December 2025, the EC published a proposal for wide-ranging reforms to EU capital markets rules.December 2025
• UK policies regulating third parties designated as critical to the financial sector became effective in January 2025.January 2025
• In 2021, the FTC identified common ownership as a key enforcement area and passed a resolution empowering individual commissioners to investigate shareholder conduct.2021
• In 2023, the FTC and DOJ released new merger guidelines recognizing that common ownership may reduce competitive incentives.2023
• In 2024, the FTC and DOJ submitted a joint comment letter to FERC encouraging consideration of common ownership in updating regulatory relief for asset managers.2024
• In 2025, the FTC and DOJ stated they have not taken a view on whether common ownership alone implicates US antitrust laws.2025
• OECD Pillar Two establishes 15% global minimum tax; EU member states and UK adopted Pillar Two minimum tax laws since 2024.2024
• OECD January 2026 package includes Side-by-Side System for multinationals with US parent.January 2026