ESCO TECHNOLOGIES INC (ESE) – SEC staff letter
2026-02-24 · Re: Form 10-K for the Fiscal Year Ended September 30, 2025 Filed December 1, 2025 · Accession 0000000000-26-001902 · 2 staff comment(s) issued
Company response(s): 2026-03-03
Segment Reporting (ASC 280)MD&A: Results & Known TrendsGoodwill & Asset ImpairmentFair Value & Investments
2026-02-24 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed December 1, 2025 · Comment 1 · Goodwill and Other Long-Lived Assets, page 27 Agreed to revise
Staff comment: We note the disclosure in your financial statement footnotes that you performed a quantitative impairment analysis related to certain reporting units and a qualitative impairment analysis related to other reporting units and concluded no goodwill was impaired. Given the significance of your goodwill balance, please revise your Critical Accounting Estimates in future filings to clarify whether any of your reporting units are at risk of failing the goodwill impairment test. A reporting unit is at risk of failing the impairment test if it has a fair value that is not substantially in excess of carrying value. If no reporting units are at risk based on your most recent impairment test, please…
letter → Company response: Refer to Item 303(b)(3) of Regulation S-K and Section V of SEC Release No. 33-8350 for guidance . Company Response In future filings, to the extent applicable, we will include as part of our critical accounting estimate disclosures the fact that no reporting units are at risk of failing the impairment test as they have a fair value that is substantially in excess of carrying value. Our proposed revised wording for this critical accounting estimate is below (changes underlined for emphasis). Proposed wording in future Form 10-K filings: Goodwill and Other Long-Lived Assets Our Management annually reviews goodwill and other long-lived assets for impairment or whenever events or changes in…
response letter → 2026-02-24 · Form 10-K for the Fiscal Year Ended September 30, 2025 Filed December 1, 2025 · Comment 2 · Note 10. Business Segment Information, page F-28 Agreed to revise
Staff comment: We note that your tabular disclosures of segment information beginning on page F-29 include separate columns for each of the reportable segments, a subtotal column for the reportable segments titled Segment Total, as well as a column for Corporate which is added to arrive at a Total column. It does not appear that your Corporate column qualifies as an operating and reportable segment under ASC 280. As such, the current disclosure appears to result in the presentation of certain amounts that are not required by ASC 280. Please revise your footnote as follows: • Reconcile the total of the reportable segments’ measures of segment profit or loss to consolidated income before taxes as required…
letter → Company response: , or explain to us why no revision is needed to comply with ASC 280. Company Response As noted in our footnote 10, Business Segment Information, we stated that Corporate is not a reportable segment, but it is included for reconciliation purposes. This is to help the reader reconcile our segment disclosures back to our consolidated statements of operations and balance sheets. In future filings, we will present the segment information in a different manner to reconcile to the consolidated totals, as outlined in Exhibit 1.
response letter → Full letter on EDGAR → · Filing index · All ESCO TECHNOLOGIES INC (ESE) 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.
Goodwill & Asset Impairment – what to check: Disclose reporting units at risk, headroom, key assumptions and triggering-event analysis, especially if market cap is below book value.
Fair Value & Investments – what to check: Disclose Level 3 valuation techniques and significant unobservable inputs, and support equity-method vs. fair value elections.
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