What changed in this filing

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Item 1. Business

2025-08-28 compared with 2024-08-28 · 70 added, 90 removed, 384 unchanged (29% of the section changed)

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We believe that by using modern technology, strong engineering talent, and a mission-driven approach, we can reinvent payments and commerce.

Our solutions, which are built on trust and transparency, are designed to make it easier for consumers to spend responsibly and with confidence, easier for merchants and commerce platforms to convert sales and grow, and easier for commerce to thrive.

Our solutions, which are built on trust and transparency, are designed to make it easier for consumers to spend and save responsibly and with confidence, easier for merchants and commerce platforms to convert sales and grow, and easier for commerce to thrive.

Legacy payment options, archaic systems, and traditional risk and credit underwriting models can be harmful, deceptive, and restrictive to both consumers and merchants.

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Our models have been built on extensive data points, including data from approximately 343 million loans.

Furthermore, our risk management models are designed to continuously improve over time, becoming more precise and efficient with each transaction powered by our platform.

What this means for consumers is increased purchasing power with more control and flexibility.

Furthermore, our risk management models are designed to continuously improve over time, becoming more precise and efficient with each transaction.

This translates into increased purchasing power with more control and flexibility for consumers.

By utilizing our unique risk model predicated on sophisticated machine learning algorithms, proprietary data, and product-level underwriting, we can serve consumers across the credit spectrum and price risk across transaction types.

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Our platform is explicitly designed and engineered to integrate with a wide range of merchants.

This is a point of differentiation for us, as we can accommodate and partner with merchants to serve their payment needs across a wide variety of industries, size, average order value (“AOV”), or consumer profile.

This is a point of differentiation for us, as we can accommodate and partner with merchants to serve their payment needs across a wide variety of industries, transactions, average order values (“AOV”), and consumer profiles.

As of June 30, 2025, we had approximately 377 thousand active merchants, ranging from small businesses to large enterprises, direct-to-consumer brands, brick-and-mortar stores, and companies with an omni-channel presence.

As used herein, “merchants” may reference merchants and/or e-commerce platforms.

Our merchants span a diverse range of industries, including sporting goods and outdoors, home and lifestyle, travel and ticketing, electronics, fashion and beauty, equipment and auto, and general merchandise.

Our merchants span a diverse range of industries, including electronics, equipment and auto, fashion and beauty, general merchandise, home and lifestyle, sporting goods and outdoors, and travel and ticketing.

We have three main loan product offerings:

Pay-in-4, 0% annual percentage rate (“APR”) monthly installment loans and interest-bearing monthly installment loans.

Pay-in-4 is a short-term payment plan with four biweekly 0% APR installments.

Pay-in-X, 0% annual percentage rate (“APR”) monthly installment loans and interest-bearing monthly installment loans.

Pay-in-X primarily consists of short-term payment plans with one to four 0% APR installments.

Our business model is designed to align with the interests of both consumers and merchants.

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we generally earn larger merchant fees on 0% APR financing products.

For fiscal year ended June 30, 2024 , Pay-in-4 and 0% APR installment loans represented 15% and 11% , respectively, of total gross merchandise volume (“GMV”) facilitated through our platform.

For fiscal year ended June 30, 2023, Pay-in-4 and 0% APR installment loans represented 19% and 13%, respectively, of total GMV facilitated through our platform.

For fiscal year ended June 30, 2025 , Pay-in-X and 0% APR installment loans represented 14% and 13%, respectively, of total gross merchandise volume (“GMV”) facilitated through our platform.

For fiscal year ended June 30, 2024, Pay-in-X and 0% APR installment loans represented 15% and 11%, respectively, of total GMV facilitated through our platform.

This revenue model incentivizes us to help our merchants convert sales and increase AOV through the commerce and technology solutions offered by our platform.

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Interest rates charged to our consumers vary depending on several factors including transaction risk, creditworthiness of the consumer, the repayment term selected by the consumer, the amount of the loan, and the individual arrangement with a merchant.

The interest-bearing transactions we facilitate only include simple interest.

Because consumers are not charged deferred or compounding interest or late fees, we are not incentivized to profit from our consumers’ mistakes or misfortunes.

For the fiscal years ended June 30, 2025 and 2024 , interest-bearing monthly installment loans represented 72% and 74% , respectively, of total GMV.

We also facilitate the issuance of virtual cards directly to consumers through our App, allowing them to shop with merchants that are not integrated with Affirm.

Similarly, we also facilitate the issuance of the Affirm Card, a debit card that can be used physically or virtually and which allows consumers to link a bank account to pay in full, or apply to pay over time for their purchase through the Affirm App.

We also facilitate the issuance of the Affirm Card, a debit card that can be used physically or virtually and which allows consumers to link a bank account to pay in full, or apply to pay over time for their purchase through the Affirm App.

Similarly, we also facilitate the issuance of one-time-use virtual cards directly to consumers through our App, allowing them to shop with merchants that are not integrated with Affirm.

Merchants may also elect to use the virtual card as a method to facilitate the offering of installment loans to allow their customers to pay over time.

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• Affirm at Checkout.

When purchasing from one of our partner merchants, consumers can choose Affirm as a payment method, giving them the option to pay over time with terms ranging from weeks to months.

When purchasing from one of our partner merchants, consumers can choose Affirm as a payment method, giving them the option to pay over time with terms ranging from weeks to years.

We monitor merchants’ creditworthiness, consumer complaints and dispute rates, changes in consumer repayment behavior, and other data to give consumers the confidence that merchants integrated with Affirm are committed to delivering honest and delightful experiences.

• Consumer-first borrowing.

Our products make it easy for consumers to apply for a loan and be approved instantaneously.

Consumers receive either 0% APR bi-weekly or monthly installments, where they pay no interest, or interest-bearing monthly installment loans, where they pay fixed amounts of interest that do not compound.

Our products make it easy for consumers to apply for a loan and complete a quick, real-time eligibility check.

If approved, consumers receive either monthly or one to four 0% APR installments, where they pay no interest, or interest-bearing monthly installment loans, where they pay fixed amounts of interest that do not compound.

We underwrite each transaction individually and do not charge late fees.

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Our Affirm App and website provide tailored and exclusive offers from merchants based on consumers’ preferences.

Consumers can apply at affirm.com or via the Affirm App and, upon approval, receive a single-use virtual card to use online or in-store.

Consumers can apply at affirm.com or via the Affirm App and, upon approval, receive a one-time-use virtual card to use online or in-store.

During the fiscal year ended June 30, 2025, 24% of our transactions occurred on the Affirm marketplace.

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Affirm Card allows consumers to link a bank account to pay in full, or apply to pay over time through the Affirm App.

Users can take advantage of an in-app post-purchase feature that allows them to instantly apply to convert any eligible debit transaction into an installment loan.

Users can take advantage of an in-app post-purchase feature that allows them to instantly apply for an installment loan for any eligible debit transaction.

Consumers can also apply for a pre-purchase installment loan via the Affirm App and, upon approval, use the Affirm Card online or in-store to complete their purchase.

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• Affirm at Checkout .

Through our direct application programming interface (“API”), designed for use by developers, merchants can easily incorporate Affirm into their payment and product pages, enabling merchants to achieve incremental sales, expand their target markets and increase customer conversion and loyalty by solving affordability for consumers.

We are also able to help merchants increase demand for higher net AOV items.

Our direct Application Programming Interface (API) provides a simple and compliant solution that allows merchants to easily incorporate Affirm into their payment and product pages with minimal investment.

The integration process is supported by extensive developer documentation and a dedicated team to assist with any issues.

Once integrated, merchants can achieve incremental sales, expand their target markets, and increase customer conversion, while Affirm handles the regulatory aspects of the loans facilitated through our platform.

• Flexible offerings that address a wider range of transactions.

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We also partner with merchants to reach consumers with other promotional strategies and offers.

• Merchant dashboard.

Our merchant dashboard provides a robust user interface through which each merchant can view transaction data, manage charges, access API keys, and manage and configure the merchant’s Affirm account.

We provide merchants with insightful analytics that help them understand how their various products are performing and other key insights to optimize conversion and consumer acquisition costs.

• Client success support.

Our high-touch client success team partners with our merchants to analyze performance and provides custom recommendations to optimize AOVs and conversion rates.

• Merchant dashboard and analytics.

Our merchant dashboard provides a robust user interface through which each merchant can view transaction data, manage charges, and manage their merchant account, while also offering insightful analytics and a client success team to help them understand product performance and optimize conversion and consumer acquisition costs.

• Affirm App and marketplace.

Merchants also have access to Affirm’s app, which provides a marketplace that allows them to efficiently reach consumers through featured placements and personalized advertisements.

• Affirm website and developer documentation.

Our website contains extensive and engaging developer documentation designed to make it easy for any developer to integrate via our direct API or other integrations, and to maximize the benefit of all that Affirm offers to both merchants and consumers.

Merchants also have access to the Affirm App, which provides a marketplace that allows them to efficiently reach consumers through featured placements and personalized advertisements.

• Affirm prequalification.

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Prequalification also personalizes the shopping experience for consumers, once they are prequalified they may receive customized offers based on their approval amount.

• Simple and compliant solution.

Our direct API, designed for use by developers, allows for site integration with minimal merchant investment.

Merchants can easily incorporate our platform into payment and product pages, and we provide a dedicated integration team to assist with issue resolution.

Once a merchant has integrated our API, we handle the regulatory aspect of the loans facilitated through our platform, irrespective of state, province, or jurisdiction.

Our Competitive Advantages

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We use data to inform our analysis and decision-making, including risk assessment, in a way that empowers consumers and generates value for our merchants and funding sources.

Our technology is built to handle the immense scale of our data-driven operations — we are capable of processing thousands of checkouts per minute.

Our machine learning-based risk models are currently calibrated and validated on an extensive amount of data points, based on a complex set of variables, and are custom built to effectively detect fraud, price risk, and provide customized recommendations.

We consider data beyond traditional credit scores, such as transaction history and credit usage, to predict repayment ability, and leverage this with real-time response data.

In some cases, we also are able to access and leverage SKU-level data to assess and underwrite risk for individual transactions before extending access to credit.

Our technology is built to handle the immense scale of our data-driven operations — we are capable of processing thousands of checkouts per minute, often relaying underwriting decisions within seconds.

Our machine learning-based risk models are calibrated and validated on an extensive amount of data from over 343 million loans, and are custom built to effectively detect fraud, price risk, and provide customized recommendations.

data beyond traditional credit scores, such as transaction history and credit usage, and our own repayment history, to predict repayment ability, and leverage this with real-time response data.

Better outcomes generated by our proprietary risk models

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As data from new transactions are incorporated into our risk algorithms, we are able to more effectively assess a given credit profile.

This process is further enhanced by a constant feedback loop that allows us to monitor performance against our predictions and quickly adjust risk, as needed.

Our ability to quickly assess, price, and manage risk enables us to generate high quality assets that attract funding sources and generate predictable servicing and interest income as consumers repay over time.

Our risk model is designed to comply with our originating bank partners’ credit policies and underwriting procedures and has been proven to lead to lower fraud rates and higher approval rates compared to traditional credit underwriting models.

Our risk model is designed to comply with our originating bank partners’ credit policies and underwriting procedures and is designed to support lower fraud rates and higher approval rates compared to traditional credit underwriting models.

For more information on how our risk model automates the underwriting process for our originating bank partners, see “— Regulatory Environment — State and provincial licensing requirements and regulation.”

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We believe our capital management strategy is a key competitive differentiator, enabling us to effectively scale our network, support GMV growth across our ecosystem, and efficiently recycle equity capital.

Our durable funding model consists of three primary channels — warehouse credit facilities, programmatic issuance of term and revolving securitization transactions, and forward flow commitments.

Our diverse and durable funding model consists of four primary channels — warehouse credit facilities, programmatic issuance of term and revolving securitization transactions (including revolving securitizations via Affirm’s master trust), pass-through loan sales, and forward flow loan sale arrangements.

Within each channel, we endeavor to maximize our financial flexibility by partnering with a broad spectrum of counterparty profiles including depository institutions, investment banks, strategic investment funds, pension funds, asset managers, and insurance companies.

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Additionally, some merchants are increasingly offering proprietary pay-over-time options to customers, and in some cases, these are presented parallel to our offerings at checkout.

We believe that we compete favorably based on our competitive advantages and are well-positioned to succeed in the market.

We believe that our competitive advantages position us favorably to succeed in the market.

However, many of our competitors are substantially larger than we are, which may give those competitors advantages we do not have at present, such as a more diversified product offering, a larger consumer and merchant base, the ability to reach more consumers and potential consumers, operational efficiencies, the ability to cross-subsidize their offerings through their other business lines, more versatile technology platforms, broad-based local distribution capabilities, and lower-cost funding.

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• Innovate on new consumer product solutions .

We plan to continue to innovate and bring new financial products to market for consumers.

To expand consumers' purchasing power, deliver personalized benefits through AdaptAI (Affirm’s AI-powered personalized promotion platform), and help them discover the best offers, we are delivering a new generation of financial products and experiences designed to meet their evolving needs.

• Increase merchant feature functionality.

As we continue to help merchants increase conversion rates, AOVs, and customer satisfaction, we plan to build new tools to help them optimize their customer acquisition strategies and achieve even greater results.

To help merchants improve their conversion rates, AOVs, and customer satisfaction, we are delivering new tools, experiences, and channels designed to strengthen their customer acquisition strategies.

Increase Consumer Transaction Frequency and In-store Usage

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Expand to new markets

Our platform is broadly available to merchants and eligible consumers in the United States and Canada.

We will continue to evaluate expanding our platform to new markets, including the United Kingdom (“U.K.”) where we expect to begin facilitating loans by the end of fiscal 2025.

Merchants and consumers anywhere can benefit from a more transparent, fair, and honest way to engage in commerce, and we see an opportunity to generate value in many new markets around the world through our platform.

Our platform is broadly available to merchants and eligible consumers in the United States, Canada and the United Kingdom (“U.K.”), and we expect to continue expanding internationally in both western Europe and Australia.

We believe merchants and consumers anywhere can benefit from a more transparent, fair, and honest way to engage in commerce, and we see an opportunity to generate value in many new markets around the world through our platform.

Our Technology

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We are focused on the effectiveness of sales and marketing spending.

We also utilize dedicated sales teams to grow our merchant base in the United States and Canada, and leverage strategic partnerships with other platforms to expand our merchant and consumer base.

We also utilize dedicated sales teams to grow our merchant base and leverage strategic partnerships with other platforms to expand our merchant and consumer base.

We experience seasonal fluctuations in our business as a result of consumer spending patterns, including Affirm Card, which we expect to mimic the seasonality of our general business in the near term.

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This means that we do not and will not take advantage of our consumers.

Unlike much of the industry, we do not capitalize on consumer misfortunes through practices such as late fees and deferred or compounding interest.

Unlike much of the consumer lending industry, we do not capitalize on consumer misfortunes through practices such as late fees and deferred or compounding interest.

Our success is aligned with our consumers’ success.

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These values have helped us to attract, inspire, and harness the collective talent of exceptional technologists and business people.

Diversity, equity, and inclusion

We believe that diversity, equity, and inclusion (“DEI”) are important as we scale and build our high-performing team.

In service of our high performance culture, we strive to attract and retain employees with a broad range of backgrounds, experiences, and skills, which we believe are important as we scale our business and strengthen Affirm's culture.

Our Diversity and Inclusion Steering Committee (“DISC”) is an internal committee made up of senior leaders from across Affirm.

DISC’s overarching purpose is to partner with the DEI team, to advance the DEI mission and strengthen Affirm’s culture.

This entails creating an environment where individuals from all backgrounds can thrive.

We annually publish our DEI Report, which discloses certain demographic information relating to our team and outlines our DEI goals, our progress toward them, our areas for improvement, and where we expect to focus our efforts.

The 2024 report is available at:

www.affirm.com/diversity-inclusion.

This website has been provided for convenience only, and the contents of the report and information found on, or accessible through, our website are not a part of, and are not incorporated into, this Annual Report on Form 10-K.

DISC’s overarching purpose is to advance belonging and inclusion in order to create an environment where individuals from all backgrounds can thrive and everyone has an equal opportunity to succeed.

Our board of directors’ role in human capital resource management

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We pride ourselves on a culture that respects co-workers and values concern for others.

Management regularly reports to our board of directors on human capital management topics, including corporate culture, safety, diversity and inclusion, employee development, and compensation and benefits.

Management regularly reports to our board of directors on human capital management topics, including corporate culture, safety, employee development, and compensation and benefits.

Our board of directors provides input on important decisions, including with respect to safety, talent retention and development.

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We operate in a rapidly evolving regulatory environment and are subject to extensive regulation, both directly and indirectly, by way of our partnership with our originating bank partners, under U.S.

federal law, the laws of Canada, and the United Kingdom, and the laws of the states and provinces in which we operate, among others.

federal law, the laws of Canada and the U.K., and the laws of the states and provinces in which we operate, among others.

These laws cover all aspects of our business and include privacy laws, consumer protection laws, and contractual obligations.

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Our policies and practices approach these requirements with the goal of managing the long-term viability and flexibility of our business model.

As such, we have established a business model pursuant to which we may originate loans directly through our platform under our lending, servicing, and brokering licenses across various

jurisdictions in the U.S., Canada, and U.K., and we may also purchase loans originated by our originating bank partners through our platform.

As such, we have established a business model pursuant to which we may originate loans directly through our platform under our lending, servicing, and brokering licenses across various jurisdictions in the U.S., Canada, and U.K., and we may also purchase loans originated by our originating bank partners through our platform.

Substantially all of the loans facilitated through our platform in the U.S.

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The OCC issued a similar rule on May 29, 2020 with respect to loans originated by national banks.

State attorneys general of the states of California, New York and Illinois have filed a lawsuit against the OCC alleging that the OCC had no statutory authority to issue its May 29, 2020 rule regarding the permissibility of interest rates on loans purchased from a national bank and failed to follow required procedures in promulgating the rule.

the permissibility of interest rates on loans purchased from a national bank and failed to follow required procedures in promulgating the rule.

State attorneys general of the states of California, Illinois, Massachusetts, Minnesota, New Jersey, New York, and North Carolina, together with the District of Columbia, filed a similar lawsuit against the FDIC regarding the FDIC Federal Interest Rate Authority Rule.

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Further, it is unclear whether these rules will be given effect by courts and regulators in a manner that actually mitigates risks relating to state interest rate limits and related risks to us, our originating bank partners, any other program participant, or the loans facilitated through our platform.

While most enforcement and litigation has

historically targeted high-interest rate programs (i.e.

While most enforcement and litigation has historically targeted high-interest rate programs (i.e.

> 100% APR), which we consider to be inconsistent with our company mission and values, we nonetheless could be subject to litigation, whether private or governmental, or administrative action regarding the above claims.

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Any of the aforementioned scenarios could impose substantial costs and or harm our business.

United Kingdom regulatory oversight

regulatory oversight

In addition to the U.S.

and Canada, we intend to provide a similar service in the U.K.

and Canada, we provide a similar lending service in the U.K.

through our U.K.

subsidiary, Affirm U.K.

Limited (f.k.a.

Skytech Capital Ltd).

Limited is authorized and regulated by the U.K.

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financial system, and (c) promoting effective competition in the interests of consumers.

The FCA regulates and supervises some or all of Affirm U.K.

The FCA regulates and supervises Affirm U.K.

Limited’s consumer credit activities.

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The FCA has a range of supervisory tools available to it, including (but not limited to) meetings with management, desk-based reviews, making recommendations and on-site inspections.

The laws and regulations applicable to the industry are subject to interpretation and change and we continue to monitor this on an ongoing basis.

The laws and regulations applicable to consumer credit activities are subject to interpretation and change and we continue to monitor this on an ongoing basis.

federal consumer protection requirements

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• the Equal Credit Opportunity Act (the “ECOA”) and Regulation B promulgated thereunder, which prohibit creditors from discriminating against credit applicants on the basis of race, color, sex, age, religion, national origin, marital status, the fact that all or part of the applicant’s income derives from any public assistance program, or the fact that the applicant has in good faith exercised any right under the Federal Consumer Credit Protection Act or any applicable state law.

In addition to acts of intentional discrimination, the ECOA has been interpreted by federal regulators and courts to prohibit creditors from maintaining policies

and practices that, while facially neutral, result in a disproportionate, adverse impact on applicants or consumers in protected groups.

In addition to acts of intentional discrimination, the ECOA has been interpreted by federal regulators and courts to prohibit creditors from maintaining policies and practices that, while facially neutral, result in a disproportionate, adverse impact on applicants or consumers in protected groups.

For this reason, a loan decisioning or credit scoring model must not use any variable that may be deemed a proxy for a protected characteristic such as race, ethnicity, or sex.

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We are also subject to regulation by the Consumer Financial Protection Bureau (“CFPB”) under the Dodd-Frank Act and other acts described herein, and we are subject to the CFPB’s supervision and enforcement authority with respect to our compliance with these requirements as a facilitator, servicer, acquirer, or originator of consumer credit.

As such, the CFPB has in the past requested reports concerning our organization, business conduct, markets, and activities, and we expect that the CFPB will continue to do so from time to time in the future.

Additionally, the

CFPB’s supervision of us enables it, among other things, to conduct comprehensive and rigorous examinations to assess our compliance with consumer financial protection laws, which could result in investigations, enforcement actions, regulatory fines and mandated changes to our business products, policies and procedures.

As such, the CFPB has in the past requested reports concerning our organization, business conduct, markets, and activities, and the CFPB may continue to do so from time to time in the future.

Additionally, the CFPB’s supervision of us enables it, among other things, to conduct comprehensive and rigorous examinations to assess our compliance with consumer financial protection laws, which could result in investigations, enforcement actions, regulatory fines and mandated changes to our business products, policies and procedures.

The CFPB, through its supervision and enforcement authority, could increase our compliance costs, potentially hinder our ability to respond to marketplace changes, impose requirements to alter products and services that would make them less attractive to consumers and impair our ability to offer products and services profitably.

The CFPB is authorized to pursue administrative proceedings or litigation for violations of federal consumer financial laws.

In these proceedings, the CFPB can obtain cease and desist orders (which can include orders for restitution or rescission of contracts, as well as other kinds of affirmative relief) and monetary penalties which, for 2022, range from $6,323 per day for minor violations of federal consumer financial laws (including the CFPB’s own rules) to $31,616 per day for reckless violations and $1,264,622 per day for knowing violations.

The CFPB monetary penalty amounts are adjusted annually for inflation.

Also, where a company has violated Title X of the Dodd-Frank Act or CFPB regulations under Title X, the Dodd-Frank Act empowers state attorneys general and state regulators to bring civil actions for the kind of cease and desist orders available to the CFPB (but not for civil penalties).

In May 2022, the CFPB issued an Interpretive Rule to clarify the authority of states to enforce federal consumer financial protections laws under the Consumer Financial Protection Act of 2010 (“CFPA”).

Specifically, the CFPB confirmed that (1) states can enforce the CFPA, including the provision making it unlawful for covered persons or service providers to violate any provision of federal consumer financial protection law;

(2) the enforcement authority of states under section 1042 of the CFPA is generally not subject to certain limits applicable to the CFPB’s enforcement authority, such that States may be able to bring actions against a broader cross-section of companies than the CFPB;

and (3) state attorneys general and regulators may bring (or continue to pursue) actions under their CFPA authority even if the CFPB is pursuing a concurrent action against the same entity.

If the CFPB or one or more state officials find that we have violated the foregoing laws, they could exercise their enforcement powers in ways that would have a material adverse effect on our business.

In addition, the Biden Administration has brought an increased focus on enforcement of federal consumer protection laws and appointed consumer-oriented regulators at federal agencies such as the CFPB, the OCC and the FDIC.

It is possible that such regulators could promulgate rulemakings and bring enforcement actions that materially impact our business and the business of our originating bank partners.

These regulators may augment requirements that apply to loans facilitated by our platform, or impose new programs and restrictions and could otherwise revise or create new regulatory requirements that apply to us (or our bank partners), impacting our business, operations, and profitability.

In May 2022, the CFPB issued an Interpretive Rule to clarify the authority of states to enforce federal consumer financial protections laws under the Consumer Financial Protection Act of 2010.

However, on May 15, 2025, the CFPB rescinded this interpretive rule.

It is possible that federal regulators could promulgate rulemakings and bring enforcement actions that materially impact our business and the business of our originating bank partners.

These regulators may augment requirements that apply to loans facilitated by our platform, or impose new programs and restrictions and could

otherwise revise or create new regulatory requirements that apply to us (or our bank partners), impacting our business, operations, and profitability.

On May 22, 2024, the CFPB issued an Interpretive Rule, “Truth in Lending (Regulation Z);

Use of Digital User Accounts to Access Buy Now, Pay Later Loans,” under the Truth in Lending Act (the “Interpretive Rule”) that extended to Buy Now, Pay Later (BNPL) providers certain dispute and refund requirements applicable to credit card providers.

The Interpretive Rule is an interpretation of existing law that “does not impose any new or revise any existing recordkeeping, reporting, or disclosure requirements,” thereby applying to past operations.

The Interpretive Rule may result in operational and compliance challenges and new litigation risks and scrutiny by federal and state regulators.

The Interpretive Rule was effective on July 30, 2024.

The CFPB has not provided any additional guidance since the Interpretive Rule was issued.

However, on June 2, 2025, the CFPB subsequently confirmed retraction of the Interpretive Rule in its status report to the Court in the case brought by the trade group challenging the interpretive rule.

Consumer Fin.

1:24-cv-2966-ACR, Status Report (D.D.C.

June 2, 2025).

The CFPB also previously announced in a blog post that it would “not prioritize enforcement actions taken on the basis of the [Interpretive Rule].” Consumer Fin.

Bureau, CFPB Announcement Regarding Enforcement Actions Related to Buy Now, Pay Later Loans (May 6, 2025).

The federal regulatory framework applicable to online marketplaces such as our platform is evolving and uncertain, and additional requirements may apply to our business in the future.

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We collect, store, use, disclose, transfer, and otherwise process a wide variety of information, including personal information, for various purposes in our business, including to help provide for the integrity of our services and to provide features and functionality to our consumers and merchants.

This aspect of our business, including the collection, storage, use, disclosure, transfer, processing, and protection of the information, including personal information, we acquire in connection with our consumers’ and merchants’ use of our services, is subject to numerous privacy, cybersecurity, and other laws and regulations in the U.S.

numerous privacy, cybersecurity, and other laws and regulations in the U.S.

and foreign jurisdictions, including the GLBA and its implementing regulations.

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The CCPA gives residents of California expanded rights to access and delete their personal information, opt out of certain personal information sharing, and receive detailed information about how their personal information is used, and also provides for civil penalties for violations and a private right of action for data breaches.

with fines for noncompliance of up to the greater of 20 million euros or up to 4% of the annual global revenue of the noncompliant company.

Meanwhile, the GDPR provides data subjects with greater control over the collection and use of their personal information (such as the “right to be forgotten”) and has specific requirements relating to cross-border transfers of personal information to certain jurisdictions, including to the U.S., with fines for noncompliance of up to the greater of 20 million euros or up to 4% of the annual global revenue of the noncompliant company.

In addition, on November 3, 2020, California voters approved a new privacy law, the California Privacy Rights Act (“CPRA”), which significantly modifies the CCPA, including by expanding consumers’ rights with respect to certain personal information and creating a new state agency to oversee implementation and enforcement efforts.

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Intellectual property and proprietary rights are important to the success of our business.

We rely on a combination of patent, copyright, trademark, and trade secret laws in the United States and other jurisdictions, as well as license agreements, confidentiality procedures, non-disclosure agreements, and other contractual protections, to establish and protect our intellectual property and proprietary rights, including our proprietary technology, software, know-how, and brand.

We rely on a combination of patent, copyright, trademark, and trade secret laws in the United States and other jurisdictions, as

well as license agreements, confidentiality procedures, non-disclosure agreements, and other contractual protections, to establish and protect our intellectual property and proprietary rights, including our proprietary technology, software, know-how, and brand.

However, these laws, agreements, and procedures provide only limited protection.

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Information found on, or accessible through, our website is not a part of, and is not incorporated into, this Annual Report on Form 10-K.

Copies of our annual reports on Form 10-K, quarterly reports on Form 10-Q, current reports on Form 8-K, and amendments to these reports filed or furnished

pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended, are available, free of charge, on our website as soon as reasonably practicable after we file such material electronically with, or furnish it to, the SEC.

Copies of our annual reports on Form 10-K, quarterly reports on Form 10-Q, current reports on Form 8-K, and amendments to these reports filed or furnished pursuant to Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended, are available, free of charge, on our website as soon as reasonably practicable after we file such material electronically with, or furnish it to, the SEC.

The SEC also maintains a website that contains our SEC filings.

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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.

What changed 10-K

Item 1. Business