VISA INC. (V) – SEC staff letter

2026-03-31 · Re: Form 10-K for Fiscal Year Ended September 30, 2025 · Accession 0000000000-26-003272 · 1 staff comment(s) issued

Company response(s): 2026-04-13

Non-GAAP: Equal Prominence Non-GAAP: Reconciliation & Usefulness MD&A: Results & Known Trends KPIs, Metrics & Earnings Calls

2026-03-31 · Form 10-K for Fiscal Year Ended September 30, 2025 · Comment 1 · Non-GAAP financial results, page 41 Awaiting / response not in dataset

Staff comment: To avoid giving undue prominence to your non-GAAP results, please revise to present and discuss your non-GAAP results after your discussion and analysis of GAAP results. Refer to Item 10(e)(1)(i)(A) of Regulation S-K and Corporation Finance Interpretations 102.10(a). Results of Operations Net revenue, page 45 2. Increases in each component of net revenue appear to be primarily volume related. This factor appears to recur annually as the primary factor impacting your net revenue. Please discuss to the extent identifiable factors, such as macro-economic conditions and others, are the cause for the increased volume. To the extent there are known trends in the factors that materially impact… letter →

Non-GAAP: Equal Prominence Non-GAAP: Reconciliation & Usefulness MD&A: Results & Known Trends KPIs, Metrics & Earnings Calls

Full letter on EDGAR → · Filing index · All VISA INC. (V) correspondence

Non-GAAP: Equal Prominence – what to check: In earnings releases and MD&A, present the GAAP measure first and with at least equal emphasis, including headlines, bullets and tables.

Non-GAAP: Reconciliation & Usefulness – what to check: Reconcile every non-GAAP measure (including segment-level measures presented outside the ASC 280 note) to the most directly comparable GAAP measure, and explain why it is useful.

MD&A: Results & Known Trends – what to check: Quantify drivers of changes (price vs. volume), discuss known trends and uncertainties, and avoid repeating the financial statements.

KPIs, Metrics & Earnings Calls – what to check:

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