COSTCO WHOLESALE CORP /NEW (COST) – Company response
2026-03-23 · Re: Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 · Accession 0000909832-26-000037 · Agreed to revise
Responds to staff letter of 2026-03-04.
Segment Reporting (ASC 280)MD&A: Results & Known TrendsLiquidity & Capital ResourcesStatement of Cash Flows (ASC 230)
2026-03-04 · Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 · Comment 1 · Cash Flows from Operating Activities, page 29 Agreed to revise
Staff comment: Please provide a period to period comparative analysis and discussion of changes in cash flows from operating activities, including changes in working capital components, in your annual and interim period reports. In doing so, explain the underlying business reasons and implications of material changes between periods to provide investors with an understanding of variability and potential trends in cash flows. Ensure your discussion and analysis is not merely a recitation of changes evident from the consolidated statements of cash flows. Refer to Item 303(a) and (b) of Regulation S-K and SEC Release No. 33-8350.
letter → Company response: We respectfully acknowledge the Staff’s comments and will expand our disclosures to include a comparative analysis and discussion of changes in cash flows from operating activities in future filings. The following is an example of the future disclosure: Cash Flows from Operating Activities Our cash flow provided by operations is primarily from net sales and membership fees. Cash flow used in operations generally consists of payments to merchandise suppliers, warehouse operating costs, including wages and employee benefits, utilities, credit and debit card processing fees, and operating leases. Cash used in operations also includes payments for income taxes. Changes in our net investment in…
response letter → 2026-03-04 · Costco Wholesale Corporation Form 10-K for Fiscal Year Ended August 31, 2025 · Comment 2 · Note 11 - Segment Reporting, page 62 Agreed to revise
Staff comment: You disclose the CODM utilizes operating income in evaluating performance and allocating resources but not how the measure is used for these purposes. Refer to ASC 280-10-50-29(f) and ASC 280-10-55-47(bb). Please revise as appropriate.
letter → Company response: We will revise our disclosure in our future filings to include how the CODM utilizes operating income as described below: The CODM uses the metrics outlined in the table below, along with internal management reports, to evaluate performance, monitor actual results versus budget and prior year results, and make strategic and operational resource allocation decisions. Please contact me
response letter → Full letter on EDGAR → · Filing index · All COSTCO WHOLESALE CORP /NEW (COST) correspondence
Segment Reporting (ASC 280) – what to check: Check ASU 2023-07 significant segment expense disclosure, CODM identification, and that MD&A segment discussion matches the ASC 280 note.
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.
Liquidity & Capital Resources – what to check: Explain the drivers of operating cash flow changes (not just the line items), material cash requirements, and known trends affecting liquidity.
Statement of Cash Flows (ASC 230) – what to check:
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