1.06 The 2025 restructuring charge is disclosed without the required reconciliation of the restructuring liability

Company C · a US-listed specialty healthcare products company · SEC-style question

QuestionLowInterpretationFinancial statements, US GAAP and Regulation S-X
Area of the 10-K
Notes: restructuring costs (Note 2)
Year
Latest 10-K
Status
Interpretation: Established from the documents; the conclusion rests on a reading of the standard or regulation.
Who acts
Chief Accounting Officer, SEC Reporting
When
Next Form 10-K (fiscal 2026), which still presents 2025

In brief

In [date] the company announced a plan to cut operating expenses, completed it by [date] and charged [amount] of restructuring costs, mainly one-time severance. The note gives the description, timing, amount and income-statement line, but no reconciliation of the restructuring liability (opening balance, charges, amounts settled, closing balance) and no statement of what, if anything, was still owed at [date]. The charge is 2.8% of the pre-tax loss, so the point is small, but the reconciliation is a specific requirement for the year a plan starts.

The evidence, as filed

Masked extract: Form 10-K 2025, page 76
Form 10-K 2025, page 76Plan announced [date] and completed by [date]
Masked extract: Form 10-K 2025, page 76
Form 10-K 2025, page 76Charge of [amount], mainly one-time severance
Masked extract: Form 10-K 2025, page 76. Where the disclosure should appear: nothing here
Form 10-K 2025, page 76Where the disclosure should appear: nothing hereWhere the item should appear: the reconciliation of the restructuring liability (charges, amounts settled, balance at [date]) or a statement that no liability remained is not shown here
Masked extract: Form 10-K 2024 (prior year), page 65. The prior-year filing
Form 10-K 2024 (prior year), page 65The prior-year filingPrior year: The prior-year statement of operations has no restructuring line; there was no restructuring in 2024, so the prior-year report had nothing to reconcile.

What the filing shows, and what the rule requires

What the filing showsWhat the rule requires

Restructuring costs of [amount] described (plan, timing, severance, income-statement line). No liability reconciliation and no year-end liability figure anywhere in the report.

A short reconciliation (or one sentence) showing costs charged of [amount], amounts settled in the year and the liability at [date], even if nil.

What we checked. Restructuring policy paragraph, statement of operations, management's discussion, segment note, accrued expenses note, whole-report search, later quarterly reports

The rule

ASC 420-10-50-1 (exit or disposal cost obligations: disclosure)

Summary; FASB/IFRS text is copyrighted For exit or disposal activities, disclose description, expected completion, total, period and cumulative costs by major type and segment, and a liability rollforward.

Version: Text in force at the date of this review · Source: FASB Accounting Standards Codification, ASC 420-10-50-1 (as in force for fiscal 2025); summary wording of the study's US GAAP law pack

Why it applies here. for an exit or disposal activity, the Codification requires, in the period the activity starts and until it is complete, the total cost expected and incurred by major type and a reconciliation of the beginning and ending liability. Because the plan was completed within the year, the reconciliation may well end at nil, which is why the point is put as a question rather than a finding.

Why it matters

Readers cannot see whether any severance remained unpaid at the year end or confirm that the plan is fully settled. The realistic result is a staff comment asking for the reconciliation, or a one-line confirmation in the next Form 10-K.

Exposure

A question for management; the amounts charged are not in question.

Our workings

Fact

the note states that the plan was announced in [date], completed by [date] and gave rise to [amount] of restructuring costs, mainly one-time severance benefits, shown on the statement of operations line 'Restructuring costs'. Management's discussion repeats the charge (rounded to millions) and its cause; the segment note includes the charge in other segment items. Nothing in the report states the liability recognized, the amounts settled or any balance outstanding at the year end; the accrued expenses note has no restructuring line.

Our computation

the charge is 2.8% of the pre-tax loss of [amount].

ItemComputationSource
Restructuring costs, 2025[n]Note 2 and statement of operations
Share of pre-tax loss[n] / [n] = 2.8%computed

Management’s best defense, and our reply

The finance team may say the charge is small (under 3% of the pre-tax loss and about half a percent of revenue), the plan began and finished within one quarter, and the severance was settled before the year end, so a reconciliation from nil to nil would add nothing; materiality allows an immaterial disclosure to be left out. They may add that management's discussion and the segment note already explain the charge. However, the year-end balance is not stated anywhere, so a reader cannot confirm that nothing remained owing, and the Codification asks for the reconciliation in the period the activity starts. A single sentence would meet the requirement, which is why the point is a low-severity question.

The fix

  1. Add: 'Restructuring costs of [amount] were charged in 2025; $[x] was settled in cash during the year and $[y] remained accrued at [date].' (or 'no liability remained').

Question for the company

How much of the [amount] restructuring charge was settled during 2025 and what liability, if any, remained at [date]? Was the reconciliation left out on materiality grounds?

Evidence relied on

#What it showsTypeWhere
1Plan announced [date] and completed by [date]DocumentForm 10-K 2025, page 76
2Charge of [amount], mainly one-time severanceDocumentForm 10-K 2025, page 76
3Pre-tax loss of [amount] for 2025, the materiality benchmarkDocumentForm 10-K 2025, page 49

Absence check

Document
Form 10-K 2025
Where it would appear
Restructuring Costs
What is missing
the reconciliation of the restructuring liability (charges, amounts settled, balance at [date]) or a statement that no liability remained
Pages looked at
p.49, [n]
Result
'restructuring liabilit' and 'restructuring accrual' have no hits. 'severance' hits only p.76 (this paragraph). 'separation benefits' hits only p.51 (management's discussion: amount and cause). 'restructur' also hits p.12 and [n] (risk factors on curtailment or restructuring of operations), p.49 and [n] (management's discussion: the [amount] charge), p.63 (statement of operations line) and p.95 (segment note: the charge sits in other segment items). None gives the liability, the amounts settled or the year-end balance.

Prepared by Pramanex from the company’s public SEC filings, without the company’s involvement, to show how a 10-K Pre-filing Check reads. The company is not named, and nothing on this page is a statement about any identifiable company. Observations are not an audit, review or other attestation or assurance engagement, and not legal advice. An SEC-style question is a question, not a conclusion.

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