COTY INC. (COTY) – Company response
2026-03-10 · Re: Form 10-K for the Fiscal Year Ended June 30, 2025 Form 10-Q for the Period Ended December 31, 2025 · Accession 0001024305-26-000018 · Agreed to revise
Responds to staff letter of 2026-02-26.
Goodwill & Asset ImpairmentCapitalization, Equity & Escrow
2026-02-26 · Form 10-K for the Year Ended June 30, 2025 Form 10-Q for the Period Ended December 31, 2025 · Comment 1 · Critical Accounting Policies, page 60 Agreed to revise
Staff comment: You disclose, “there have been no material changes to the items disclosed as critical accounting policies and estimates,” including goodwill, since the disclosure in the Form 10-K. Please expand your disclosure to address the subsequent substantial decrease in market capitalization and the impact on your assessment of the likelihood of future material goodwill impairment charges. Tell us and disclose your consideration of ASC 350-20-35-30 and the need to perform a more recent impairment test. letter →
Company response: The Company acknowledges the Staff’s comment. We will enhance our future disclosures to address our consideration of the Company’s market capitalization, including any declines in market capitalization, if applicable, in our goodwill impairment assessment. We propose to include enhanced disclosure within the Critical Accounting Policies section of our Management’s Discussion and Analysis of Financial Condition and Results of Operations (“MD&A”), beginning with our Form 10-Q for the Fiscal Quarter Ended March 31, 2026. The following is an illustration of the disclosure updates (underscored language indicates new disclosure) based on page 60 of our Form 10-Q filed on February 5, 2026.… response letter →
Full letter on EDGAR → · Filing index · All COTY INC. (COTY) correspondence
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.
Capitalization, Equity & Escrow – what to check:
Templates & resources
- AICPA & CIMA – SEC reporting resources (AICPA & CIMA · Professional body · Free / member)
- BDO Accounting, Reporting & Compliance Hub (ARCH) (BDO · Firm guide · Free)
- Deloitte DART – Roadmap Series (Deloitte · Firm guide · Free)
- Deloitte Roadmap: SEC Comment Letter Considerations (Deloitte · Firm guide · Free)
- KPMG Financial Reporting View (KPMG · Firm guide · Free)
- PwC Viewpoint (PwC · Firm guide · Free / paid)
- RSM Financial Reporting Resource Center (RSM · Firm guide · Free)
- SEC – EDGAR Full Text Search (SEC · Regulator · Free)