NDAQ · CIK 0001120193
What Nasdaq, Inc. told the SEC could break it.
Nasdaq's disclosures reflect what it is — operator of globally distributed financial-market infrastructure — and split along two lines. The operational side carries the geography: currency exposure across the Euro, Swedish Krona, and Canadian dollar from running businesses in many countries, plus a concentration of operations in a few hubs (the U.S. east coast, Stockholm, Vilnius, and St. John) where its prominence also makes it a likelier target for disruption. The regulatory and counterparty side is denser: a November 2025 European Commission antitrust investigation into its derivatives conduct, its exposure as a clearinghouse to member defaults (a power of assessment reaching 230% of a member's default-fund contribution), and a court ruling that vacated the Consolidated Audit Trail funding model, putting a $99 million receivable at risk.
5 self-disclosed vulnerabilities, pulled from its own filings, each in the company’s words, with the source. This is the risk register almost nobody reads.
In its own words
What could break it.
Currency (FX)
- Euro, Swedish Krona, Canadian dollar exposuremedium
With operations in the U.S., Nordic/Baltic countries, Canada, the U.K., Australia, and elsewhere, Nasdaq has significant exposure to exchange-rate movements between the Euro, Swedish Krona, Canadian dollar, and other currencies against the U.S. dollar.
“Because we have operations in numerous countries, we are exposed to currency risk. We have operations in the U.S., the Nordic and Baltic countries, Canada, the United Kingdom, Australia and many other foreign countries. We therefore have significant exposure to exchange rate movements between the Euro, Swedish Krona, the Canadian dollar and other foreign currencies against the U.S. dollar.”
SEC filing →As of 2026
Geographic concentration
- operational concentration (US east coast, Stockholm, Vilnius, St. John) + disruption-target riskmedium
Nasdaq's operations are heavily concentrated in the U.S. east coast, Stockholm, Vilnius, and St. John, Canada, and its prominence makes it a likelier target for malicious disruption or physical attacks; an event hitting those areas could impair operations.
“In addition, our business operations are heavily concentrated in the east coast of the U.S.; Stockholm, Sweden; Vilnius, Lithuania; and St. John, Canada, among other locations. Any event that impacts either of those geographic areas could potentially affect our ability to operate our businesses.”
SEC filing →As of 2026
Litigation
- EC antitrust investigation (Nasdaq & Deutsche Börse, EU derivatives)medium
In November 2025 the European Commission opened a formal antitrust investigation into whether Nasdaq and Deutsche Börse coordinated conduct in EEA listing, trading and clearing of financial derivatives; duration, outcome, and potential fines are uncertain.
“In November 2025, the EC opened a formal antitrust investigation to assess whether Nasdaq and Deutsche Borse had breached European Union competition rules by coordinating their conduct in the sector for listing, trading and clearing of financial derivatives in the European Economic Area. We have been cooperating with the EC but are uncertain about the duration or ultimate outcome of its review, or to the extent there is any finding against us, the amount of any fines or other remedies.”
SEC filing →As of 2026
Other disclosures
- clearinghouse clearing-member default risk (power of assessment 230%)medium
As a central counterparty, Nasdaq Clearing is exposed to clearing-member defaults; its power of assessment to cover a defaulter's remaining obligations corresponds to 230% of the member's aggregate default-fund contribution under the liability waterfall.
“to cover a defaulting member's remaining obligations up to the limits established under the terms of the clearinghouse rules. The power of assessment corresponds to 230 % of the clearing member's aggregate contribution to the financial and commodities markets' default funds.”
SEC filing →As of 2026
Regulatory & policy
- Consolidated Audit Trail (CAT) funding model vacated — $99M receivable at riskmedium
A July 2025 Court of Appeals decision vacated the CAT funding model (stay expired end of November 2025), so Nasdaq may face delay or inability to recover CAT-related expenses, with a $99 million net receivable outstanding.
“As a result, we may be subject to a delay in recovering expenses or be unable to recover those expenses. The SROs have yet to seek reimbursement for a portion of their expenses related to delivery of certain technology. If the SEC determines that we failed to timely or properly deliver the technology, we may forfeit recovery of an undetermined portion of those expenses. As of December 31, 2025, we have an outstanding net receivable of $99 million in connection with our portion of expenses related to the CAT implementation.”
SEC filing →As of 2026
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