3 unchanged sentences
In designing and evaluating the disclosure controls and procedures, our management recognizes that any controls and procedures, no matter how well designed and operated, can provide only reasonable assurance of achieving the desired control objectives.
−Removed: In addition, the design of disclosure controls and
−Removed: procedures must reflect the fact that there are resource constraints and that our management is required to apply its judgment in evaluating the benefits of possible controls and procedures relative to their costs.
+Added: In addition, the design of disclosure controls and procedures must reflect the fact that there are resource constraints and that our management is required to apply its judgment in evaluating the benefits of possible controls and procedures relative to their costs.
Based on this evaluation, our Chief Executive Officer and our Chief Financial Officer concluded that, as of December 31, 2025, our disclosure controls and procedures were designed at a reasonable assurance level and were effective to provide reasonable assurance that the information we are required to disclose in reports that we file or submit under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the SEC rules and forms, and that such information is accumulated and communicated to our management, including our Chief Executive Officer and our Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosures.
10 unchanged sentences
Other Information
−Removed: On December 11, 2024 , Chenming Hu , a member of the Board of Directors of ACM Research , adopted a Rule 10b5-1 trading arrangement (the “Hu Plan”) that is intended to satisfy the affirmative defense of Rule 10b5-1(c) of the Exchange Act.
−Removed: The Hu Plan allows for the contemporaneous exercise of options and sale of up to 326,310 shares of Class A Common Stock, at specific market prices, commencing on March 17, 2025, and continuing until (i) all such options are exercised and the underlying shares are sold, (ii) December 11, 2026 , or (iii) such date that the Hu Plan is otherwise terminated according to its terms, whichever comes first.
−Removed: On November 29, 2024 , David Wang , President, Chief Executive Officer and a member of the Board of Directors of ACM Research , adopted a Rule 10b5-1 trading arrangement (the “Wang Plan”) that is intended to satisfy the affirmative defense of Rule 10b5-1(c) of the Exchange Act.
−Removed: The Wang Plan allows for the contemporaneous exercise of options and sale of up to 600,002 shares of Class A Common Stock, at specific market prices, commencing on May 21, 2025, and continuing until (i) all such options are exercised and the underlying shares are sold, (ii) November 27, 2026 , or (iii) such date that the Wang Plan is otherwise terminated according to its terms, whichever comes first.
+Added: On November 20, 2025 , Charles Pappis , a member of the Board of Directors of ACM Research , adopted a Rule 10b5-1 trading arrangement (the “Pappis Plan”) that is intended to satisfy the affirmative defense of Rule 10b5-1(c) of the Exchange Act.
+Added: The Pappis Plan allows for the contemporaneous exercise of options and sale of up to 10,000 shares of Class A Common Stock, at specific market prices, commencing on March 3, 2026, and continuing until (i) all such options are exercised and the underlying shares are sold, (ii) March 3, 2027 , or (iii) such date that the Pappis Plan is otherwise terminated according to its terms, whichever comes first.
+Added: Table of C ontents
+Added: On December 2, 2025 , Lisa Feng , Chief Financial Officer of ACM Shanghai , t, adopted a Rule 10b5-1 trading arrangement (the “Feng Plan”) that is intended to satisfy the affirmative defense of Ru le 10b5-1(c) of the Exchange Act.
+Added: The Feng Plan allows for the contemporaneous exercise of options and sale of up to 30,000 shares of Class A Common Stock, at specific market prices, commencing on March 5, 2026, and continuing until (i) all such options are exercised and the underlying shares are sold, (ii) March 4, 2027 , or (iii) such date that the Feng Plan is otherwise terminated according to its terms, whichever comes first.
+Added: On December 4, 2025 , Tracy Liu , a member of the Board of Directors of ACM Research , adopted a Rule 10b5-1 trading arrangement (the “Liu Plan”) that is intended to satisfy the affirmative defense of Rule 10b5-1(c) of the Exchange Act.
+Added: The Liu Plan allows for the contemporaneous exercise of options and sale of up to 60,000 shares of Class A Common Stock, at specific market prices, commencing on March 10, 2026, and continuing until (i) all such options are exercised and the underlying shares are sold, (ii) December 15, 2026 , or (iii) such date that the Liu Plan is otherwise terminated according to its terms, whichever comes first.
Disclosure Regarding Foreign Jurisdictions that Prevent Inspections
13 unchanged sentences
Information responsive to this item is incorporated herein by reference to our definitive proxy statement with respect to our 2025 Annual Meeting of Stockholders to be filed with the SEC within 120 days after the end of the fiscal year covered by this report.
+Added: Table of C ontents
Exhibits and Financial Statement Schedules
45 unchanged sentences
and certain Investors (incorporated herein by reference to Exhibit 10.02 to the Quarterly Report on Form 10-Q filed on August 12, 2019)
+Added: Table of C ontents
Schedule identifying agreements substantially identical to the form of Agreement filed as Exhibit 10.13 hereto (incorporated herein by reference to Exhibit 10.02(a) to the Quarterly Report on Form 10-Q filed on August 12, 2019)
−Removed: Partnership Agreement of Hefei Shixi Chanheng Integrated Circuit Industry Venture Capital Fund Partnership (LP) dated September 5, 2019 by and among Infotech National Emerging Industry Venture Investment Guidance Fund (LP), Hefei Guozheng Asset Management Co, Ltd., Hefei Economic and Technological Development Zone Industrial Investment Guidance Fund Co., Ltd., ACM Research (Shanghai), Inc., Hefei Tongyi Equity Investment Partnership (LP), Shenzen Waitan Technology Development Co., Ltd., and Beijing Shixi Qingliu Investment Co., Ltd.
+Added: Partnership Agreement of Hefei Shixi Chanheng Integrated Circuit Industry Venture Capital Fund Partnership (LP) dated September 5, 2019 by and among Infotech National Emerging Industry Venture Investment Guidance Fund (LP), Hefei Guozheng Asset Management Co, Ltd., Hefei Economic and Technological Development Zone Industrial Investment Guidance Fund Co., Ltd., ACM Research (Shanghai), Inc., Hefei Tongyi Equity Investment Partnership (LP), Shenzhen Waitan Technology Development Co., Ltd., and Beijing Shixi Qingliu Investment Co., Ltd.
(incorporated herein by reference to Exhibit 10.03 to the Quarterly Report on Form 10-Q filed on November 13, 2019)
26 unchanged sentences
(incorporated herein by reference to Exhibit 10.06 to the Current Report on Form 8-K filed on June 1, 2020)
+Added: Table of C ontents
Commitment Letter Regarding Unfulfilled Commitment on Binding Measures, effective as of May 26, 2020, of ACM Research, Inc.
32 unchanged sentences
(incorporated herein by reference to Exhibit 10.02 to the Quarterly Report on Form 10-Q filed on August 7, 2023)
−Removed: Letter from Armanino LLP dated September 26, 2023 to the Securities and Exchange Commission (incorporated herein by reference to Exhibit 16.1 to the Current Report on Form 8-K filed on September 26, 2023)
+Added: Unofficial English Translation of RMB Working Capital Loan Contract, entered into in January 2025, between ACM Research, Inc.
+Added: and China CITIC Bank
Insider Trading Policy reference in 2025 Proxy Statement
List of Subsidiaries of ACM Research, Inc.
+Added: Table of C ontents
Consent of Ernst & Young Hua Ming LLP
−Removed: Consent of Armanino LLP
Certification of Principal Executive Officer Pursuant to Rules 13a-14(a) and 15d-14(a) under the Securities Exchange Act of 1934, as Adopted Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002
18 unchanged sentences
Form 10-K Summary
+Added: Table of C ontents
Pursuant to the requirements of Section 13 or 15(d) of the Securities Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized, as of March 2, 2026.
9 unchanged sentences
Haiping Dun Director
−Removed: /s/ Chenming Hu
−Removed: Chenming Hu Director
+Added: /s/ Charlie Pappis
+Added: Charlie Pappis
/s/ Tracy Liu
1 unchanged sentence
Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.