What the changes say
- Regulatory scrutiny and compliance costs remain central to global operations across US, UK, and EU jurisdictions.
- Clearing house governance battles and credit risk exposure from daily settlements dominate financial risk.
- Emerging risks include artificial intelligence adoption, digital asset regulations, and sports event-based contracts litigation.
What changed since the prior 10-K
New
- NewRISKS RELATING TO OUR INDUSTRY
We are primarily subject to the jurisdiction of the regulatory agencies in the U.S., UK and EU. As a result of our global operations, we are also subject to the rules and regulations of other local jurisdictions in which we conduct business and offer our products and services, as appropriate
We face increasing regulatory scrutiny, compliance costs, and potential structural changes across U.S., U.K., EU, and local jurisdictions.
- NewRISKS RELATING TO OUR INDUSTRY
Legislation regarding the regulatory market structure applicable to the trading and clearing of spot digital assets is currently being considered in Congress. It is not yet certain whether the legislation will be signed into law or whether it will have any impact on listed derivatives regulation
Congress is considering legislation for spot digital assets, while litigation challenges the legal status of event-based contracts like sports.
- NewRISKS RELATING TO OUR INDUSTRY
for positions established on our exchanges or to freely move open positions among clearing houses in order to take advantage of our liquidity. Even if they are not successful, these factors may cause them to limit the use of our markets
Clearing firms are seeking legislative or regulatory changes to move futures and options positions away from our exchange-owned clearing house.
- NewRISKS RELATING TO OUR BUSINESS
performance, availability, resilience, capacity, security, and speed demanded by our customers, our ability to successfully compete, along with our revenues and profits, will be adversely affected
Our new initiatives and trading volumes may be compromised if customers and their third-party service providers lack adequate back office infrastructure.
- NewRISKS RELATING TO OUR BUSINESS
Our business is subject to the impact of financial markets volatility, which is caused by conditions that are beyond our control
A sustained period of price stability would lower trading volumes, and our fixed cost structure would prevent offsetting revenue declines.
- NewRISKS RELATING TO OUR BUSINESS
management from the operation of our derivatives clearing house, the operation of a securities clearing house is new to our business
Expanding into securities clearing is new to us, and we maintain a $98.0 million fund for qualified agricultural participants if clearing firms become insolvent.
- NewRISKS RELATING TO OUR BUSINESS
Our use of artificial intelligence in our business may be unsuccessful and may give rise to various risks, which could adversely affect our business, reputation or operating results
Our use of artificial intelligence introduces risks regarding accuracy, bias, intellectual property infringement, data privacy, and cybersecurity.
Dropped
- DroppedRISKS RELATING TO OUR BUSINESS
System failure or degradation could lead our customers to file formal complaints with industry regulatory organizations, to file lawsuits against us or to cease doing business with us or could lead our regulators to initiate inquiries or proceedings for failure to comply with applicable laws and regulations
- DroppedRISKS RELATING TO OUR BUSINESS
trading activities in our markets could affect our brand and reputation and reduce the number of participants trading in our markets. If that should occur, we could face a corresponding decline in trading volume and revenue
Reworded
- 92% rewrittenRISKS RELATING TO OUR INDUSTRY
Please see "Item 1A - Risk Factors - Risks Relating To Our Business" beginning on page 20 for additional information
Cross-references were updated to point to Item 1A for additional information on regulatory risks.
- 79% rewrittenRISKS RELATING TO OUR INDUSTRY
Please see "Item 1 - Business - Regulatory Matters" beginning on page 12 for additional information on our areas of regulatory focus
Cross-references were updated to point to Item 1 for regulatory matters regarding clearing house ownership.
- 63% rewrittenRISKS RELATING TO OUR BUSINESS
Our business exposes us to substantial credit risk of our clearing firms and other counterparties and, consequently, a decrease in their financial resources could adversely affect us
Added a figure stating the clearing house transferred an average of approximately $6.7 billion a day during 2025.
- 60% rewrittenRISKS RELATING TO OUR BUSINESS
If we experience system failures or capacity constraints, our ability to conduct our operations and execute our business strategy could be materially harmed, and we could be subject to significant costs and liabilities
Added that the critical IT, communications, and business systems are provided by third parties.
Was: If we experience systems failures or capacity constraints, our ability to conduct our operations and execute our business strategy could be materially harmed, and we could be subject to significant costs and liabilities
- 50% rewrittenRISKS RELATING TO OUR BUSINESS
We could be harmed by misconduct or errors that are difficult to detect and deter
Retained existing text on employee misconduct and artificial intelligence risks without substantive textual changes.
- 50% rewrittenRISKS RELATING TO OUR BUSINESS
The success of our markets depends on our ability to complete development of, successfully implement and maintain electronic trading and clearing systems that have the functionality, performance, availability, resilience, capacity, security and speed required by our customers
Updated the electronic trading volume statistic on the CME Globex platform from 92% in 2024 to 93% in 2025.
Was: The success of our markets depends on our ability to complete development of, successfully implement and maintain electronic trading and clearing systems that have the functionality, performance, availability and resilience, capacity, security and speed required by our customers
- 20% rewrittenRISKS RELATING TO OUR INDUSTRY
We face intense competition from other companies. If we are not able to successfully compete, our business, financial condition and operating results will be materially harmed
Expanded the list of competitors to include crypto and prediction market platforms alongside existing entities.
All 30 risk factors
Headings as the filing states them, in filing order.
RISKS RELATING TO OUR INDUSTRY
- 01Our business is subject to the impact of global market, economic and political conditions that are beyond our control and that could significantly impact our business and make our financial results more volatile
- 02Please see "Item 1A - Risk Factors - Risks Relating To Our Business" beginning on page 20 for additional information92% rewritten
- 03We are primarily subject to the jurisdiction of the regulatory agencies in the U.S., UK and EU. As a result of our global operations, we are also subject to the rules and regulations of other local jurisdictions in which we conduct business and offer our products and services, as appropriateNew
- 04Legislation regarding the regulatory market structure applicable to the trading and clearing of spot digital assets is currently being considered in Congress. It is not yet certain whether the legislation will be signed into law or whether it will have any impact on listed derivatives regulationNew
- 05Please see "Item 1 - Business - Regulatory Matters" beginning on page 12 for additional information on our areas of regulatory focus79% rewritten
- 06for positions established on our exchanges or to freely move open positions among clearing houses in order to take advantage of our liquidity. Even if they are not successful, these factors may cause them to limit the use of our marketsNew
- 07We face intense competition from other companies. If we are not able to successfully compete, our business, financial condition and operating results will be materially harmed20% rewritten
- 08Our trading volume, and consequently our revenues and profits, would be adversely affected if we are unable to retain our current customers at substantially similar trading levels or attract new customers
- 09Additionally, from time to time, certain customers may represent a significant portion of the open interest in our individual product lines or contracts, and a substantial decrease in their trading activity could have a negative impact on the liquidity of the particular product line or contract
- 10As a financial services provider, we are subject to significant litigation risk and regulatory liability and penalties
- 11We may be at greater risk from terrorism, which poses physical security risks and cybersecurity risks, than other companies
RISKS RELATING TO OUR BUSINESS
- 12Damage to our reputation or brand could harm our business
- 13The success of our markets depends on our ability to complete development of, successfully implement and maintain electronic trading and clearing systems that have the functionality, performance, availability, resilience, capacity, security and speed required by our customers50% rewritten
- 14performance, availability, resilience, capacity, security, and speed demanded by our customers, our ability to successfully compete, along with our revenues and profits, will be adversely affectedNew
- 15Our business is subject to the impact of financial markets volatility, which is caused by conditions that are beyond our controlNew
- 16If we experience system failures or capacity constraints, our ability to conduct our operations and execute our business strategy could be materially harmed, and we could be subject to significant costs and liabilities60% rewritten
- 17Our business exposes us to substantial credit risk of our clearing firms and other counterparties and, consequently, a decrease in their financial resources could adversely affect us63% rewritten
- 18management from the operation of our derivatives clearing house, the operation of a securities clearing house is new to our businessNew
- 19Our market data revenues may be reduced by decreased demand, poor overall economic conditions, regulatory changes or a significant change in how market participants trade and use market data
- 20We may have difficulty executing our growth strategy and maintaining our growth effectively
- 21The expansion of our global operations is complex and subjects us to increased business and economic risks that could adversely affect our financial results
- 22Our risk management, compliance and monitoring programs might not be effective and may result in outcomes that could adversely affect our reputation, financial condition and operating results
- 23We could be harmed by misconduct or errors that are difficult to detect and deter50% rewritten
- 24A failure to protect our intellectual property rights, or allegations that we have infringed the intellectual property rights of others, could adversely affect our business
- 25Our use of artificial intelligence in our business may be unsuccessful and may give rise to various risks, which could adversely affect our business, reputation or operating resultsNew
RISKS RELATING TO AN INVESTMENT IN OUR CLASS A COMMON STOCK
- 26Our indebtedness could adversely affect our financial condition and operations and prevent us from fulfilling our debt service obligations. We might still be able to incur more debt, intensifying these risks
- 27As of December 31, 2025, we had approximately $3.4 billion of total indebtedness and we had excess borrowing capacity for general corporate purposes under our existing facilities of approximately $2.3 billion
- 28Any reduction in our credit rating could increase the cost of our funding from the capital markets
- 29Our average rate per contract for our derivatives business is subject to fluctuation due to a number of factors. As a result, our average rate per contract in any particular period may not be a reliable indication of our future average rate per contract
- 30Our members have been granted special rights, which protect their trading privileges and require that we maintain open outcry for options products still meeting certain volume thresholds and, in the case of our Class B shareholders, provide them with special board representation
Other CME Group 10-Ks
- FY2024 10-K risk factors25 risks
CME Group faces heavy global market competition, intense regulatory scrutiny, and technology infrastructure dependencies as a major derivatives clearinghouse.
Filed Feb 27, 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.