In addition to implications for disclosure outside the financial statements — including risk factors, MD&A, non-GAAP and legal proceedings — there are also potential financial statement implications of the SCOTUS decision in Learning Resources v. Trump. This KPMG alert highlights one time-sensitive one: that the SCOTUS ruling is a subsequent event evaluated under ASC 855 for companies that have imported goods that were subjected to IEEPA tariffs and had not yet issued financial statements for a closed fiscal period by February 20.

ASC 855 requires companies to evaluate events that occur after the balance sheet date but before financial statements are issued (or available to be issued) to determine whether those events require recognition or disclosure.

ASC 855 also distinguishes between two categories of subsequent events:

Recognized (Type 1) subsequent events provide additional evidence of conditions that existed at the balance sheet date and require adjustment to the financial statements.

Nonrecognized (Type 2) subsequent events relate to conditions that arose after the balance sheet date and do not require adjustment, but disclosure is required if the event is material and omission would be misleading.

Determining whether a subsequent event is Type 1 or Type 2 requires judgment.

We believe it is acceptable to treat the Supreme Court’s decision as a nonrecognized (Type 2) subsequent event in financial statements that have not yet been issued as of February 20, 2026.

That means companies should disclose the decision and its implications as a subsequent event if the decision “is expected to have a material effect on the financial statements when recognized, or not disclosing it would otherwise result in the omission of material information.”

Such disclosures may address, for example, the potential effect on existing and future tariff exposure, supply chain arrangements, liquidity or ongoing or anticipated legal proceedings. Any estimate of financial effects is based on information known as of the date the financial statements are issued (or available to be issued), and companies should avoid speculative or overly forward‑looking statements. As with all subsequent events analyses, conclusions should be grounded in company‑specific facts and circumstances.

Companies should also consider whether related disclosures are required under other US GAAP topics, such as ASC 275 on risks and uncertainties, ASC 205-40 on going concern or ASC 450 on contingencies.

I ran a search and quickly found an example.

– Meredith Ervine