BILL Holdings (BILL) risk factors, FY2026 10-K

BILL Holdings's FY2026 10-K, filed Aug 20, 2026, lists 65 risk factors in 5 groups. Against the prior year's 67: 5 new, 7 dropped, 20 substantially reworded.

Risk factors listed
655 groups
New this year
5vs 67 last year
Dropped
7since the prior 10-K
Substantially reworded
20of those kept
Section length
29k wordsItem 1A

What the changes say

  • Credit performance and funding risks now cover BILL Divvy Card warehouse facilities, invoice financing losses, and potentially inadequate credit models.
  • New operational risks address API access, card acceptance, workforce reductions, remote-first restructuring, and the cost of share repurchases.
  • The company increased its repurchase authorization from $300 million to $1.0 billion and now identifies AI, geopolitical, and computing-cost pressures.
  • Standalone risks were dropped for SBA spending, financial institution relationships, compliance acquisitions, cybersecurity insurance, takeover restrictions, and public-company management experience.

What changed since the prior 10-K

New

  • NewRisks Related to Our Business and Industry

    underperformance, of the account receivables participation interests that we own could have an adverse effect on our business

    Underperforming receivables participation interests could raise BILL Divvy Card financing costs, disrupt warehouse funding, and expose invoice financing and instant-transfer products to credit losses.

  • NewRisks Related to Our Business and Industry

    entry and provides the basis for managing cash-flow through an integrated solution for accounts payable, accounts receivable, spend and expense management, and payments

    Accounting and other software providers could change, restrict, or discontinue APIs, break integrations, or launch competing payment solutions that reduce the platform’s value and growth.

  • NewRisks Related to Our Business and Industry

    using our card products as a result of merchant policies, new surcharges or reduced attractiveness of rewards programs, our business, financial condition, and operating results could be adversely impacted

    Merchant policies, surcharges, card-network rules, compliance requirements, or fewer card-accepting suppliers could reduce BILL’s card usage and interchange revenue.

  • NewRisks Related to Our Business and Industry

    Our reductions in force, transition to a remote-first company, and restructuring efforts may result in unanticipated costs or consequences

    Multiple reductions in force, a remote-first transition, and reduced office space could create severance, retention, transition, restructuring, and other unexpected costs or disruption.

  • NewRisks Related to Ownership of Our Common Stock

    discussion about our share repurchase program activity during the period and shares available for future repurchases, refer to Note 10 to our consolidated financial statements included elsewhere in this Annual Report on Form 10-K

    The Inflation Reduction Act’s 1% excise tax could increase the cost of BILL’s share repurchases and reduce the number of shares bought.

Dropped

  • DroppedRisks Related to Our Business and Industry

    government spending, including in the U.S. Small Business Administration, may adversely impact the SMBs we serve

  • DroppedRisks Related to Our Business and Industry

    expensive or difficult. As a result of these and other factors, we may be unable to attract new customers or our related expenses may increase, which would have an adverse effect on our business, revenue, gross margins, and operating results

  • DroppedRisks Related to Our Business and Industry

    Our business depends, in part, on our business relationships with financial institutions

    Covered economic downturns and reduced government spending, including at the Small Business Administration, affecting SMB customers.

  • DroppedRisks Related to Our Business and Industry

    operations may not be fully compliant with all applicable law, including economic and trade sanctions and anti-money laundering, counter-terrorist financing, and privacy laws, subjecting us to potential liabilities and requiring us to spend considerable time, effort, and resources to address

  • DroppedRisks Related to Government Regulation and Privacy Matters

    We have heightened monitoring in the face of such risks, but cannot guarantee that our efforts, or the efforts of those upon whom we rely and partner with, will be successful in preventing any such information security incidents

  • DroppedRisks Related to Ownership of Our Common Stock

    brought to enforce any liability or duty created by the Exchange Act or Securities Act of 1933, as amended (Securities Act), or the rules and regulations thereunder in federal court

    Covered difficulty and expense attracting customers and increasing business spending on BILL charge cards.

  • DroppedRisks Related to Ownership of Our Common Stock

    Our management team has limited experience managing a public company

Reworded

  • 90% rewrittenRisks Related to Ownership of Our Common Stock

    The timing and amount of any repurchases of common stock by us are subject to a number of uncertainties

    The repurchase authorization increased from $300 million in 2025 to $1.0 billion in May 2026, including unused prior authorization.

  • 87% rewrittenRisks Related to Our Business and Industry

    If we do not or cannot maintain the compatibility of our platform with popular software solutions or offerings of our partners, our revenue and growth prospects will decline

    The compatibility risk remains focused on integrations with QuickBooks, NetSuite, Sage Intacct, Xero, and Microsoft Dynamics 365; the provided text shows no specific substantive change.

  • 71% rewrittenRisks Related to Our Business and Industry

    Our business depends, in part, on our relationships with accounting firms, financial institutions, software providers and other partners

    The discussion still emphasizes accounting-firm relationships but removes the prior reference to more than 9,000 accounting firm partners.

    Was: Our business depends, in part, on our relationships with accounting firms

  • 70% rewrittenRisks Related to Our Business and Industry

    A significant portion of our revenue comes from small and medium-sized businesses, which may have fewer financial resources to weather an economic downturn, and volatile or weakened economic conditions in the U.S. and globally may adversely affect our business and operating results

    The macroeconomic risk now adds AI adoption, geopolitical conflicts, supply-chain disruption, and rising memory, computing-power, and raw-material costs.

  • 60% rewrittenRisks Related to Our Business and Industry

    If we are unable to attract new customers or convert trial customers into paying customers or if our efforts to promote our charge card usage through marketing, promotion, and spending business rewards are unsuccessful, our revenue growth and operating results will be adversely affected

    The heading now specifically highlights converting trial users and promoting charge-card usage through marketing, promotions, and business rewards; the shown body is unchanged.

  • 56% rewrittenRisks Related to Our Business and Industry

    Future acquisitions, strategic investments, partnerships, collaborations, or alliances could be difficult to identify and integrate, divert the attention of management, disrupt our business, dilute stockholder value, and adversely affect our operating results and financial condition

    The acquisition and investment risk is substantively unchanged in the provided text, including the Finmark example and limited acquisition experience.

  • 46% rewrittenRisks Related to Our Business and Industry

    Our business could be negatively affected as a result of actions by or proposals from activist stockholders, and such activism could impact the trading value of our securities and harm our business, financial condition and results of operations

    Activist-stockholder risk shifted from hypothetical activity to activity that has occurred and may continue, adding adviser costs that could hurt financial results.

  • 44% rewrittenRisks Related to Our Business and Industry

    A substantial portion of our revenue is derived from interchange fees, which exposes us to potential variability in income and other risks

    The risk now specifically says major interchange-rate changes, including card-program modifications, could reduce revenue and card-product profitability.

  • 43% rewrittenRisks Related to Our Business and Industry

    Changes in our effective tax rate, tax assets or tax liabilities may adversely affect our operating results

    Was: Changes in our effective tax rate or tax liability may adversely affect our operating results

  • 43% rewrittenRisks Related to Our Business and Industry

    We use AI in our business, and any challenges with successfully developing and deploying new AI tools or properly managing the use of AI could result in reputational harm, competitive harm, legal liability, and regulatory compliance burdens, and adversely affect our results of operations

    Was: We use artificial intelligence in our business, and any challenges with successfully developing and deploying new AI tools or properly managing the use of AI could result in reputational harm, competitive harm, and legal liability, and adversely affect our results of operations

  • 37% rewrittenRisks Related to Our Business and Industry

    We have a history of operating losses and may not sustain or expand our profitability in the future

  • 35% rewrittenRisks Related to Our Business and Industry

    Our BILL Divvy Card offering exposes us to credit risk and other risks related to spending businesses' ability to pay the balances incurred on their BILL Divvy Cards. Certain of our other current and future product offerings, such as invoice financing, may also subject us to credit risk

  • 33% rewrittenRisks Related to Our Business and Industry

    The markets in which we participate are competitive, and if we do not compete effectively, our operating results could be harmed

  • 32% rewrittenRisks Related to Our Business and Industry

    If our estimates or judgments relating to our critical accounting policies prove to be incorrect, or if changes to such policies are not well-understood, our operating results could be adversely affected and the trading price of our common stock could decline

    Was: If our estimates or judgments relating to our critical accounting policies prove to be incorrect, our operating results could be adversely affected

  • 32% rewrittenRisks Related to Our Business and Industry

    Our ability to use our net operating losses to offset future taxable income may be subject to certain limitations

  • 29% rewrittenRisks Related to Our Business and Industry

    If we fail to maintain an effective system of disclosure controls and internal control over financial reporting, our ability to produce timely and accurate financial statements or comply with applicable laws and regulations could be impaired

  • 27% rewrittenRisks Related to Our Business and Industry

    If we cannot maintain our company culture as we grow, our success and our business may be harmed

  • 26% rewrittenRisks Related to Our Business and Industry

    Interruptions or delays in the services provided by AWS or other third-party data centers or internet service providers could impair the delivery of our platform and our business could suffer

  • 22% rewrittenRisks Related to Our Business and Industry

    Our recent growth may not be indicative of our future growth, and there is no assurance that we will be able to scale our platform and infrastructure, and manage our growth effectively

  • 22% rewrittenRisks Related to Our Business and Industry

    We earn revenue from interest earned on customer funds held in trust while payments are clearing, which is subject to market conditions and may decrease as customers’ adoption of electronic payments and technology continues to evolve

All 65 risk factors

Headings as the filing states them, in filing order.

Risks Related to Our Business and Industry

  1. 01We have a history of operating losses and may not sustain or expand our profitability in the future37% rewritten
  2. 02A significant portion of our revenue comes from small and medium-sized businesses, which may have fewer financial resources to weather an economic downturn, and volatile or weakened economic conditions in the U.S. and globally may adversely affect our business and operating results70% rewritten
  3. 03We expect fluctuations in our financial results, making it difficult to project future results, and if we fail to meet the expectations of securities analysts or investors with respect to our operating results, our stock price and the value of your investment could decline
  4. 04If we are unable to attract new customers or convert trial customers into paying customers or if our efforts to promote our charge card usage through marketing, promotion, and spending business rewards are unsuccessful, our revenue growth and operating results will be adversely affected60% rewritten
  5. 05If we are unable to retain our current customers, increase customer adoption of our products, sell additional services to our customers, or develop and launch new payment products, our business and growth will be adversely affected
  6. 06Our BILL Divvy Card offering exposes us to credit risk and other risks related to spending businesses' ability to pay the balances incurred on their BILL Divvy Cards. Certain of our other current and future product offerings, such as invoice financing, may also subject us to credit risk35% rewritten
  7. 07underperformance, of the account receivables participation interests that we own could have an adverse effect on our businessNew
  8. 08Our risk management efforts may not be effective to prevent fraudulent activities by our customers, subscribers, spending businesses, or their counterparties, or other third parties which, potentially augmented by AI, could expose us to material financial losses and liabilities and otherwise harm our business
  9. 09The markets in which we participate are competitive, and if we do not compete effectively, our operating results could be harmed33% rewritten
  10. 10We transfer large sums of customer funds daily, and are subject to numerous associated risks which could result in financial losses, damage to our reputation, or loss of trust in our brand, which would harm our business and financial results
  11. 11Funds that we hold for the benefit of our customers are subject to market, interest rate, credit, foreign exchange, and liquidity risks, as well as general political and economic conditions. The loss of any of these funds could adversely affect our business, operating results and financial condition
  12. 12We earn revenue from interest earned on customer funds held in trust while payments are clearing, which is subject to market conditions and may decrease as customers’ adoption of electronic payments and technology continues to evolve22% rewritten
  13. 13Our business depends, in part, on our relationships with accounting firms, financial institutions, software providers and other partners71% rewritten
  14. 14Our recent growth may not be indicative of our future growth, and there is no assurance that we will be able to scale our platform and infrastructure, and manage our growth effectively22% rewritten
  15. 15Certain credit products, including our BILL Divvy Card, are dependent on our relationship with the Issuing Banks
  16. 16If we do not or cannot maintain the compatibility of our platform with popular software solutions or offerings of our partners, our revenue and growth prospects will decline87% rewritten
  17. 17entry and provides the basis for managing cash-flow through an integrated solution for accounts payable, accounts receivable, spend and expense management, and paymentsNew
  18. 18We use AI in our business, and any challenges with successfully developing and deploying new AI tools or properly managing the use of AI could result in reputational harm, competitive harm, legal liability, and regulatory compliance burdens, and adversely affect our results of operations43% rewritten
  19. 19If we lose our founder or key members of our management team or are unable to attract and retain executives and employees we need to support our operations and growth, our business may be harmed
  20. 20Future acquisitions, strategic investments, partnerships, collaborations, or alliances could be difficult to identify and integrate, divert the attention of management, disrupt our business, dilute stockholder value, and adversely affect our operating results and financial condition56% rewritten
  21. 21If we fail to offer high-quality customer support, or if our support is more expensive than anticipated, our business and reputation could suffer
  22. 22If we fail to adapt and respond effectively to rapidly changing technology, evolving industry standards, changing regulations, and changing business needs, requirements, or preferences, our products may become less competitive
  23. 23If the prices we charge for our services are unacceptable to our customers, our operating results will be harmed
  24. 24Interruptions or delays in the services provided by AWS or other third-party data centers or internet service providers could impair the delivery of our platform and our business could suffer26% rewritten
  25. 25Failure to effectively develop and expand our sales and marketing capabilities could harm our ability to increase our customer base and achieve broader market acceptance of our products
  26. 26We currently handle cross-border payments and plan to expand our payments offerings to new customers and to make payments to new countries, creating a variety of operational challenges
  27. 27A substantial portion of our revenue is derived from interchange fees, which exposes us to potential variability in income and other risks44% rewritten
  28. 28using our card products as a result of merchant policies, new surcharges or reduced attractiveness of rewards programs, our business, financial condition, and operating results could be adversely impactedNew
  29. 29If we fail to maintain and enhance our brands, our ability to expand our customer base will be impaired and our business, operating results, and financial condition may suffer
  30. 30Changes to payment card networks rules or fees could harm our business
  31. 31Our reductions in force, transition to a remote-first company, and restructuring efforts may result in unanticipated costs or consequencesNew
  32. 32We may require additional capital to support the growth of our business, and this capital might not be available on acceptable terms, if at all
  33. 33Our ability to use our net operating losses to offset future taxable income may be subject to certain limitations32% rewritten
  34. 34We could be required to collect additional sales taxes or be subject to other tax liabilities that may increase the costs our customers would have to pay for our offering and adversely affect our operating results
  35. 35Changes in our effective tax rate, tax assets or tax liabilities may adversely affect our operating results43% rewritten
  36. 36Natural catastrophic events, pandemics, and man-made problems such as power-disruptions, computer viruses, data security breaches, war, and terrorism may disrupt our business
  37. 37If we fail to maintain an effective system of disclosure controls and internal control over financial reporting, our ability to produce timely and accurate financial statements or comply with applicable laws and regulations could be impaired29% rewritten
  38. 38Our reported financial results may be adversely affected by changes in accounting principles generally accepted in the U.S
  39. 39If our estimates or judgments relating to our critical accounting policies prove to be incorrect, or if changes to such policies are not well-understood, our operating results could be adversely affected and the trading price of our common stock could decline32% rewritten
  40. 40Our estimates of market opportunity and forecasts of market growth may prove to be inaccurate, and even if the market in which we compete achieves the forecasted growth, our business could fail to grow at similar rates, if at all
  41. 41We rely on assumptions and estimates to calculate certain of our performance metrics, and real or perceived inaccuracies in such metrics may harm our reputation and negatively affect our business
  42. 42Any future litigation against us could be costly and time-consuming to defend
  43. 43If we cannot maintain our company culture as we grow, our success and our business may be harmed27% rewritten
  44. 44We are exposed to foreign currency exchange risk relating to our Canadian operations
  45. 45Our business could be negatively affected as a result of actions by or proposals from activist stockholders, and such activism could impact the trading value of our securities and harm our business, financial condition and results of operations46% rewritten

Risks Related to Government Regulation and Privacy Matters

  1. 46Payments and other financial services-related regulations and oversight are material to our business. Our failure to comply could materially harm our business
  2. 47Our business is subject to extensive government regulation and oversight. Our failure to comply with extensive, complex, overlapping, and frequently changing rules, regulations, and legal interpretations could materially harm our business
  3. 48We are subject to governmental laws and requirements regarding economic and trade sanctions, anti-money laundering, and counter-terror financing that could impair our ability to compete in international markets or subject us to criminal or civil liability if we violate them
  4. 49We are subject to anti-corruption, anti-bribery, and similar laws, and non-compliance with such laws can subject us to criminal or civil liability and harm our business
  5. 50We cannot assure you that all of our employees and agents will not take actions in violation of our policies and applicable law, for which we may be ultimately held responsible. As we increase our international business, our risks under these laws may increase

Risks Related to Our Intellectual Property

  1. 51If we fail to adequately protect our proprietary rights, our competitive position could be impaired and we may lose valuable assets, generate less revenue, and incur costly litigation to protect our rights
  2. 52We have been in the past, and may in the future be, subject to intellectual property disputes, which are costly and may subject us to significant liability and increased costs of doing business
  3. 53Indemnity provisions in various agreements potentially expose us to substantial liability for intellectual property infringement, data protection, and other losses
  4. 54We use open source software in our products, which could subject us to litigation or other actions

Risks Related to Our Indebtedness

  1. 55Our debt service obligations, including the Notes, may adversely affect our financial condition and results of operations
  2. 56We may not have the ability to raise the funds necessary for cash settlement upon conversion of the Notes or to repurchase the Notes for cash upon a fundamental change, and our future debt may contain limitations on our ability to pay cash upon conversion of the Notes or to repurchase the Notes
  3. 57The conditional conversion feature of the Notes, when triggered, may adversely affect our financial condition and operating results
  4. 58The Capped Calls may affect the value of our Notes and our common stock
  5. 59We are subject to counterparty risk with respect to the Capped Calls

Risks Related to Ownership of Our Common Stock

  1. 60The stock price of our common stock has been, and will likely continue to be volatile, and you may lose part or all of your investment
  2. 61Anti-takeover provisions in our charter documents and under Delaware law could make an acquisition of our company more difficult, limit attempts by our stockholders to replace or remove our current management, and affect the market price of our common stock
  3. 62We do not intend to pay dividends for the foreseeable future
  4. 63If securities or industry analysts do not publish research or publish unfavorable or inaccurate research about our business, our stock price and trading volume could decline
  5. 64The timing and amount of any repurchases of common stock by us are subject to a number of uncertainties90% rewritten
  6. 65discussion about our share repurchase program activity during the period and shares available for future repurchases, refer to Note 10 to our consolidated financial statements included elsewhere in this Annual Report on Form 10-KNew

Other BILL Holdings 10-Ks

  • FY2025 10-K risk factors
    67 risks

    The company relies heavily on small and medium-sized businesses and card transaction fees. Credit products like the BILL Divvy Card expose the company to potential default and fraud losses. Interest income on customer funds and relationships with key issuing banks are critical to revenue.

    Filed Aug 28, 2025

About this page

The headings are the filing's own. The one-line readings and the overview are automated and can be wrong: read Item 1A of the 10-K for the exact wording.