AI is everywhere and the S&P 500 risk factors agree

• 95.2% of the S&P 500 disclosed a confirmed AI-related risk factor in the most recent trailing twelve-month period, up from 65.8% three periods ago.
• 7 of 11 sectors are at 95% adoption or higher in the most recent period, up from none three periods ago
• 81% of Energy sector filers now disclose this risk, up from 33.3% three periods ago, the largest swing of any sector

The S&P 500 disclosures are close to universal

Artificial Intelligence (AI) has moved from a novel risk to a routine one in the S&P 500's disclosures. In the most recent trailing twelve-month (“TTM”) period, ending September 2026, 476 of the S&P 500's 500 unique filers, 95.2%, had a confirmed AI-related risk factor inside Item 1A Risk Factors. Three years earlier, in September 2024, the figure was 329, or 65.8%. What was already a common disclosure three years ago is now close to universal.

September TTM periods

Source: Ideagen Audit Analytics

Twenty-three S&P 500 companies still had no confirmed AI-related disclosure in Item 1A Risk Factors in the most recent period, down from 171 three years earlier. Seven of the 23 companies that did not explicitly include AI in their Item 1A risk factors included it as a risk in Cybersecurity, Business, or MD&A instead of Risk Factors.

The pace of change is slowing as adoption nears saturation: the S&P 500 figure rose 20 percentage points in the FY2024-25 period and 9.4 percentage points in the most recent one.

Every sector moved, not just the obvious ones

Share of each sector's S&P 500 filers

AI-related risk factor language by sector (S&P 500)

Source: Ideagen Audit Analytics

Energy shows the largest swing of any sector: 33.3% of its S&P 500 filers had a confirmed disclosure in the first period, 81.0% in the most recent one, a gain of 47.7 percentage points. Real Estate moved almost as far, 51.6% to 96.8%, and Industrials climbed from 51.9% to 95.1%.

Consumer Staples, Financials, and Information Technology all reached full adoption in the most recent period: every S&P 500 filer in each of those three sectors now has a confirmed Item 1A disclosure. Seven of the eleven sectors are at 95% adoption or higher; three periods ago, none were.

Materials remains the laggard on an absolute basis at 76.9%, though that's still up from 38.5% three periods earlier, a gain of 38.4 percentage points. Adoption rose in every one of the three periods for every sector.

Adoption by sector, all three periods

GICS sector	S&P 500 filers	FY2023-24%	FY2024-25%	FY2025-26%
Consumer Staples	34	70.6%	85.3%	100%
Financials	76	82.9%	98.7%	100%
Information Technology	74	85.1%	95.9%	100%
Consumer Discretionary	47	70.2%	91.5%	97.9%
Real Estate	31	51.6%	77.4%	96.8%
Industrials	81	51.9%	75.3%	95.1%
Communication Services	20	90%	90%	95%
Health Care	59	64.4%	89.8%	93.2%
Utilities	31	48.4%	80.6%	90.3%
Energy	21	33.3%	66.7%	81%
Materials	26	38.5%	61.5%	76.9%

 

No AI Risk?

A company with no confirmed AI-related language in its Item 1A Risk Factors is now the exception within the S&P 500.

The 23 S&P 500 companies still silent on this in the Item 1A risk factors concentrate in a few sectors. Materials accounts for 6 of them, Energy and Health Care each account for 4 more, and Industrials accounts for 3; together, those four sectors hold 17 of the 23 remaining holdouts. All four of those sectors also posted some of the largest percentage-point gains of any sector over the three periods, so the companies left look more like late movers than firms with a settled reason to stay quiet.

In April 2026 the Cybersecurity and Infrastructure Security Agency (CISA) and the FBI jointly warned that Iran-affiliated hacking groups were using AI-assisted scripting to attack internet-exposed programmable logic controllers across US energy, water, and wastewater systems, the same class of infrastructure operated by several holdouts. None of them names AI as an Item 1A risk, even as federal regulators are actively warning their sector about AI-enabled attacks on the specific equipment they run.

Sector of the 23 S&P 500 companies with no confirmed AI-related Item 1A hit in the most recent TTM

Seven of those 23 already discuss AI somewhere in the filing, just not inside Item 1A. Several place it in Item 1C Cybersecurity instead, a few in the Item 1 Business narrative, and one in the MD&A discussion of
data-center power demand.

Either way, the benchmark has moved. Three years ago, an S&P 500 company could reasonably treat this language as optional. Today, staying quiet on it is the choice that stands out.

*SEC filings were searched for “Artificial Intelligence” OR “machine learning” OR “large language models” OR “LLM” OR “AI,” specifically within the Item 1A Risk Factors section.