Just in time for third-quarter 10-Qs, KPMG recently released the results of its analysis of disclosures about tariffs and trade policy in Form 10-Q filings from April through August 2025. “Out of approximately 880 Form 10-Q reports from Fortune 500 SEC registrants analyzed, nearly 90% mentioned tariff- and trade-related concerns” — not surprisingly, this was nearly double the number from the same period in 2024. The analysis also showed that disclosures are now more “detailed, quantified, and operationally focused.” Almost all related disclosures were in the financial statements, MD&A, risk factors, and disclosures about market risk.

– Financial Statements: Most disclosures were outside the financial statements, but in Q2, more companies began discussing the impact of tariff uncertainty and its impact on estimates — for example, whether tariff uncertainty has triggered a goodwill impairment, estimation uncertainty in allowance for loan losses for banks or incorporating tariff estimates into baseline economic forecasting.

– MD&A: 75% of 10-Qs reviewed addressed tariffs in MD&A. In Q1, disclosures were largely qualitative and addressed management’s strategies to address uncertainty. In Q2, disclosures became more specific and detailed, with many registrants reporting “actual, material effects—often quantified” and specific mitigation strategies.

– Quantitative and Qualitative Disclosures About Market Risk: Few tariff-related disclosures are included here currently, but KPMG expects this to change “to include anticipated macroeconomic effects and management strategies to mitigate risk exposures.”

– Risk Factors: Disclosures focus on uncertainty, regulatory compliance, supply chain risks and adaptation strategies, with risk factors in Q1 mostly anticipating effects and Q2 disclosures shifting away from hypothetical to start to address effects that are already occurring.

KPMG also addresses major themes in the disclosures. For example:

– Uncertainty: Companies acknowledge that the impact of tariff policies on the economy and their operations specifically is uncertain, discuss current and potential risk mitigation strategies and are beginning to quantify, model and embed tariff and trade policy risk into their financial processes — including economic forecasting and asset impairment testing — and providing detail about the actual and potential impact on financial results.

– Increased Costs: Disclosures about increased raw material costs and impact on margins have become more explicit in Q2 with many companies providing “specific dollar amounts or quantified margin effects.”

– Supply Chain Disruptions: Similarly, Q2 disclosures addressed actual supply chain disruptions and specific strategies used to address them.

– Adaptation: Disclosures discuss ways companies are adapting their business strategies to address tariff risks and also getting more specific. These adaptations include supply chain reconfigurations and supplier diversification efforts, the use of new technologies, price increases and changes to sourcing and business models to reduce exposure.

– Regulations: Disclosures highlight increasing compliance costs and regulatory challenges.

Also, take a look at this Deloitte article that addresses accounting implications of tariffs — for example, asset impairments, revenue recognition and income tax implications — that you should consider when preparing your third quarter 10-Q.

For more, check out our “Trump Administration Tariffs” Practice Area and, specifically, the “SEC Disclosure Issues” subsection.

– Meredith Ervine