Apple rewrote a third of its risk factors. Here is what moved.
Two annual reports, 314 sentences each, and only one in three survived untouched. Tariffs, a new line on AI training data, and a quieter word about where the iPhone gets built.
Apple filed its annual report for the year ending September 27, 2025 on October 31. The Risk Factors section runs 9,688 words, a little shorter than the 9,818 a year earlier. Same five headings. Same 314 sentences, by count. Line them up against last year's and only about one in three is unchanged word for word. The rest was rewritten, cut, or new.
Most of that is lawyers polishing. Some of it is the company telling you what it is worried about now that it was not worried about then. Below is the second kind.
Tariffs got their own paragraph
Last year's report handled trade in one sentence about tensions between governments that "have in the past led to tariffs and other restrictions." That sentence is gone.
In its place is a run of new sentences that reads like a diary of 2025. New tariffs on imports to the U.S. beginning in the second quarter, including on goods from China, India, Japan, South Korea, Taiwan, Vietnam and the European Union. Other countries imposing or threatening reciprocal tariffs. A Commerce Department investigation under Section 232 of the Trade Expansion Act into semiconductors and the products that contain them. And a plain admission that the company cannot say how far any of it goes: what gets announced, what other countries do in response, and how long it lasts.
The old language was general. The new language names the countries Apple builds in and the law being used against them.
Where the iPhone gets built, in one changed word
Last year: "Substantially all of the Company's manufacturing is performed in whole or in part by outsourcing partners located primarily in China mainland, India, Japan, South Korea, Taiwan and Vietnam."
This year: "A significant majority of the Company's manufacturing is performed in whole or in part by outsourcing partners located primarily in China mainland, India, Japan, South Korea, Taiwan and Vietnam, in addition to sourcing from partners and facilities located in the U.S."
"Substantially all" became "a significant majority," and the U.S. appears in the list for the first time. The supply-chain risk that follows is otherwise the same paragraph it always was: single-source partners, final assembly mostly in Asia, and a warning that supply agreements may not renew on the same terms or at all. One more phrase was added to the consequences of a shortage this year: "and stock price."
AI is now a copyright risk
A new sentence sits in the intellectual-property section. The risk of infringement claims "may be exacerbated by the use of new and emerging technologies, including machine learning and artificial intelligence, which can involve, among other things, the acquisition and use of copyrighted materials for training as well as the potential reproduction of copyrighted materials" in what the models produce. That sentence did not exist a year ago.
People
Two new sentences under general risks say that immigration, labor and employment laws and export controls can hurt the company's ability to recruit and keep a global workforce, and that failing to manage "changing workforce dynamics and regulatory requirements" could hit its culture, flexibility and costs. The 2024 report talked about competition for talent. It did not mention immigration law.
What did not change
The five headings: macroeconomic and industry, business, legal and regulatory, financial, general. The list of countries. The single-source warning. The line that past performance is not a guide. Risk-factor sections are mostly furniture, and Apple's furniture stayed put.
[ADAM: your read]
How to read one of these yourself
Every US stock page on this site now has a Risk changes tab that runs this same comparison between a company's two most recent annual reports: how many sentences were added, how many dropped, and the text of each. The sweep reads about 40 companies a day, so if your name is not there yet, it is coming. Apple's is at /stock/us/AAPL/risk-changes.
Two cautions. A reworded sentence shows up as one dropped and one added, so a heavy edit reads as a low "kept" number even when the meaning barely moved. And a company adding a risk is not predicting it. Apple added a tariff paragraph because tariffs arrived, not because it knows what comes next. Neither do we.
Opinion and personal record, not investment advice.