SRSEC Reporting Desk

ROCKWELL AUTOMATION, INC (ROK) – Company response

2026-04-13 · Re: . Form 10-K filed November 12, 2025 · Accession 0001024478-26-000011 · Agreed to revise

Responds to staff letter of 2026-03-18.

Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessSegment Reporting (ASC 280)

2026-03-18 · 10-K filed November 12, 2025 · Comment 1 · Total segment operating earnings, page 24 Agreed to revise
Staff comment: We note your presentation of total segment operating earnings. When this measure is presented outside of the ASC 280 disclosures in the notes to the financial statements, it must comply with all non-GAAP guidance. In this regard, please address the following: • This measure excludes corporate and other costs. As such, it appears to exclude normal, recurring, cash operating expenses and, as such, does not comply with Rule 100(b) of Regulation G and Item 10(e) of Regulation S-K. Refer also to Question 100.01 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations on Non-GAAP Financial Measures. • This measure excludes purchase accounting depreciation and amortization,… letter →
Company response: The Company respectfully acknowledges the Staff’s comment. We understand that Return on Invested Capital (ROIC) and Adjusted EBITDA are non-GAAP financial measures and, as such, are subject to the requirements of Regulation G and Item 10(e)(1)(i)(A) of Regulation S-K. In particular, we recognize that the most directly comparable GAAP measures must be presented with equal or greater prominence than the corresponding non-GAAP measures, as clarified in Question 102.10 of the Division of Corporation Finance’s Compliance & Disclosure Interpretations. We confirm that, in future filings, we will update the Supplemental Information to present the most comparable GAAP measures with equal or greater… response letter →
Non-GAAP: Adjustments & LabelsNon-GAAP: Reconciliation & UsefulnessSegment Reporting (ASC 280)

Full letter on EDGAR → · Filing index · All ROCKWELL AUTOMATION, INC (ROK) correspondence

Non-GAAP: Adjustments & Labels – what to check: Do not exclude normal, recurring cash operating expenses or use individually tailored recognition methods; label measures clearly (C&DI 100.01–100.04).

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.

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.

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