Peabody is a leading producer of metallurgical and thermal coal.
−Removed: At December 31, 2024, the Company owned interests in 17 active coal mining operations located in the United States (U.S.) and Australia, including a 50% equity interest in Middlemount Coal Pty Ltd.
+Added: The Company owned interests in 16 active coal mining operations located in the United States (U.S.) and Australia at December 31, 2025.
+Added: Included in that count is Peabody’s 50% equity interest in Middlemount Coal Pty Ltd.
(Middlemount).
−Removed: On November 21, 2024, Peabody entered into a partnership with RWE, a renewable energy company, to advance renewable energy projects by repurposing reclaimed land previously used for mining, including certain reclaimed mining land held by the Company.
−Removed: On November 25, 2024, Peabody entered into definitive agreements with Anglo American plc, a United Kingdom public limited company (Anglo), to acquire a portion of the assets and businesses associated with Anglo’s metallurgical coal portfolio in Australia.
−Removed: The acquisition is expected to close in the second quarter of 2025, subject to regulatory approvals, completion of preemptive rights processes and satisfaction of other customary closing conditions.
−Removed: During 2024, Peabody continued to advance the development of the Centurion Mine, an underground longwall metallurgical coal mine in Queensland, Australia, as planned.
−Removed: Development coal was produced and sold during the year, and commencement of longwall production is targeted for the first quarter of 2026.
+Added: During 2025, Peabody continued to advance the development of the Centurion Mine, an underground longwall metallurgical coal mine in Queensland, Australia.
+Added: Full-scale longwall production commenced in February 2026.
+Added: The mine is expected to enhance both the quantity and quality of the Company’s production from the Seaborne Metallurgical reportable segment.
+Added: As part of Peabody’s ongoing asset optimization program, whereby its coal reserves, coal resources and surface properties are regularly reviewed for various commercial opportunities, various workstreams were advanced during 2025.
+Added: These workstreams related to projects such as the evaluation of rare earth element (REE) and critical mineral (CM) potential;
+Added: power generation from coal mine gas;
+Added: and continued development of renewable energy projects on certain reclaimed mining lands held by the Company.
Segment and Geographic Information
As of December 31, 2025, Peabody reports its results of operations primarily through the following reportable segments:
−Removed: Seaborne Thermal, Seaborne Metallurgical, Powder River Basin, Other U.S.
−Removed: Thermal and Corporate and Other.
+Added: Seaborne Thermal, Seaborne Metallurgical, Powder River Basin and Other U.S.
Refer to Part II, Item 7.
6 unchanged sentences
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Australian Locations
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
The table below summarizes information regarding the operating characteristics of each of the Company’s mines in the U.S.
and Australia.
−Removed: The mines are listed within their respective reporting segment in descending order, as determined by tons produced in 2024.
+Added: The mines are listed within their respective reportable segment in descending order, as determined by tons produced in 2025.
Segment/Mining Complex Location Mine Type Mining Method Coal Type Primary Transport Method Processing
8 unchanged sentences
Seaborne Metallurgical
+Added: Coppabella (3)
+Added: Queensland S DL, D, T/S P R, EV Yes 2.0 1.7 2.2
Shoal Creek (4)
1 unchanged sentence
Metropolitan New South Wales U LW C, P, T R, EV Yes 1.7 1.8 2.2
−Removed: Coppabella (4)
−Removed: Queensland S DL, D, T/S P R, EV Yes 1.7 2.2 2.4
Queensland S D, T/S C, P, T R, EV Yes 1.2 1.5 2.2
8 unchanged sentences
Bear Run Indiana S DL, D, T/S T Tr, R, EV Yes 4.7 5.0 5.5
−Removed: El Segundo/Lee Ranch New Mexico S DL, D, T/S T R No 2.4 3.4 3.7
−Removed: Gateway North Illinois U CM T Tr, R, R/B, T/B, EV Yes 2.1 2.5 2.4
Wild Boar Indiana S HW, DL, D, T/S T Tr, R, R/B, T/B Yes 2.1 1.8 1.9
−Removed: Francisco Underground Indiana U CM T R Yes 1.6 2.0 1.8
+Added: Gateway North Illinois U CM T Tr, R, R/B, T/B, EV Yes 2.0 2.1 2.5
+Added: El Segundo/Lee Ranch New Mexico S DL, D, T/S T R No 1.8 2.4 3.4
Twentymile Colorado U LW T R, Tr, EV Yes 1.8 1.0 1.3
+Added: Francisco Underground Indiana U CM T R Yes 1.3 1.6 2.0
S Surface Mine B Barge
11 unchanged sentences
(2) Majority-owned mine in which there is an outside non-controlling ownership interest.
−Removed: (3) The mine experienced a fire in March 2023 and restarted production in June 2023.
+Added: Mine ceased production in September 2025.
(3) Peabody owns a 73.3% undivided interest in an unincorporated joint venture that owns the Coppabella and Moorvale mines.
The tons shown reflect its share.
−Removed: (5) The mine has been undergoing development since 2023.
+Added: (4) The mine experienced a fire in March 2023 and restarted production in June 2023.
+Added: (5) Development of the mine began in 2023.
The first development coal was produced in June 2024.
−Removed: Longwall mining is expected to commence in the first quarter of 2026.
+Added: Longwall mining commenced in February 2026.
(6) Peabody owns a 50% equity interest in Middlemount, which owns the Middlemount Mine.
3 unchanged sentences
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Coal Supply Agreements
7 unchanged sentences
Peabody’s sales backlog, which includes coal supply agreements subject to price reopener and/or extension provisions, was approximately 238 million and 153 million tons of coal as of January 1, 2026 and 2025, respectively.
−Removed: Contracts in backlog have remaining terms ranging from one to seven years and represent slightly more than one year of production based on the Company’s 2024 production volume of 118.1 million tons.
+Added: Contracts in backlog have remaining terms ranging from one to seven years and represent approximately two years of production based on the Company’s 2025 production volume of 120.3 million tons.
Approximately 64% of its backlog is expected to be filled beyond 2026.
Seaborne Operations.
−Removed: Revenue from Peabody’s Seaborne Thermal and Seaborne Metallurgical segments represented approximately 55%, 56% and 59% of the Company’s total revenue from coal supply agreements for the years ended December 31, 2024, 2023 and 2022, respectively, during which periods the coal mining activities of those segments contributed approximately 20%, 18% and 18% of the Company’s sales volumes from mining operations, respectively.
+Added: Revenue from Peabody’s Seaborne Thermal and Seaborne Metallurgical reportable segments represented approximately 51%, 55% and 56% of the Company’s total revenue from coal supply agreements for the years ended December 31, 2025, 2024 and 2023, respectively, during which periods the coal mining activities of those segments contributed approximately 20%, 20% and 18% of the Company’s sales volumes from mining operations, respectively.
Production from these segments is primarily sold into the seaborne thermal and metallurgical markets.
4 unchanged sentences
Revenue from Peabody’s Powder River Basin and Other U.S.
−Removed: Thermal segments, in aggregate, represented approximately 45%, 44% and 41% of the Company’s revenue from coal supply agreements for the years ended December 31, 2024, 2023 and 2022, respectively, during which periods the coal mining activities of those segments contributed approximately 80%, 82% and 82% of the Company’s sales volumes from mining operations, respectively.
+Added: Thermal reportable segments, in aggregate, represented approximately 49%, 45% and 44% of the Company’s revenue from coal supply agreements for the years ended December 31, 2025, 2024 and 2023, respectively, during which periods the coal mining activities of those segments contributed approximately 80%, 80% and 82% of the Company’s sales volumes from mining operations, respectively.
The Company expects to continue selling a significant portion of coal production from its U.S.
−Removed: thermal operating segments under existing long-term supply agreements.
+Added: thermal reportable segments under existing long-term supply agreements.
Certain customers utilize long-term sales agreements in recognition of the importance of reliability, service and predictable coal prices to their operations.
13 unchanged sentences
In each case, the Company usually pays transportation costs from the mine to the port, including any demurrage costs (fees paid to third-party shipping companies for loading time that exceeded the stipulated time).
+Added: Peabody Energy Corporation 2025 Form 10-K
The Company believes it has good relationships with U.S.
and Australian rail carriers and port and barge companies due, in part, to its modern coal-loading facilities and the experience of its transportation coordinators.
−Removed: During 2024, lock outages along the Black Warrior River in Alabama, U.S.A.
+Added: During 2024, lock outages along the Black Warrior River in Alabama, U.S.
negatively impacted Peabody’s sales volume and transportation costs at the Shoal Creek Mine.
−Removed: The lock outages have largely been resolved during the second half of 2024, and Peabody anticipates improved sales volume and lower transportation costs at the Shoal Creek Mine in 2025.
+Added: The lock outages were largely resolved during the second half of 2024;
+Added: however, there are several planned outages in 2026 for maintenance to permanently repair the locks.
+Added: As the timing and duration of these outages is generally known, Peabody is planning to manage its inventories accordingly so that coal will be available during the times when the locks are open.
Refer to the table in the foregoing “Mining Locations” section for a summary of transportation methods by mine.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
Export Facilities.
4 unchanged sentences
Peabody has secured its ability to transport coal from its Shoal Creek Mine under barge and port contracts;
−Removed: the primary port is the McDuffie Terminal in Mobile, Alabama, which the Company utilizes without a take-or-pay arrangement.
−Removed: Peabody’s U.S.
−Removed: thermal operations exported less than 1% of their annual tons sold during the year ended December 31, 2022.
−Removed: No tons were exported during the years ended December 31, 2024 and 2023.
−Removed: The primary port used for U.S.
−Removed: thermal exports is the Kinder Morgan Terminal near Houston, Texas.
+Added: the primary port is the McDuffie Terminal in Mobile, Alabama.
+Added: No tons were exported from U.S.
+Added: thermal operations during the years ended December 31, 2025, 2024 and 2023.
+Added: Peabody routinely assesses the export market for its U.S.
+Added: thermal coal, including options along both the Gulf Coast and the West Coast.
Mining Supplies and Equipment .
3 unchanged sentences
This approach also enables fleet standardization for mining equipment, improving asset utilization, streamlining maintenance practices across global operations and optimizing inventory management, which reduces working capital.
−Removed: In 2024, lead times for parts and components required for surface and underground mining equipment showed notable improvement.
−Removed: Peabody continues to leverage its global purchasing power and comprehensive planning strategies to maintain a reliable supply chain that effectively supports the needs of its active mines.
+Added: In 2025, lead times for parts and components required for surface and underground mining equipment remained at normal levels.
+Added: While tariff impacts have not been significant, ongoing engagement with the supply base focuses on assessing potential future tariff implications and identifying mitigation strategies.
+Added: Peabody continues to leverage its global purchasing power and comprehensive planning to maintain a reliable supply chain that effectively supports the needs of its active mines.
In addition to goods, Peabody also contracts services for its mine sites, such as maintenance for mining equipment, construction, temporary labor, explosives use and other requirements.
The Company does not perceive any undue operational or financial risk from reliance on individual service providers.
−Removed: In 2024, inflationary pressures stabilized, returning to more normal levels, and supply chain constraints eased.
−Removed: This resulted in improved access to materials and supplies necessary to support mining operations.
Demand for coal and the prices that the Company will be able to obtain for its coal are highly competitive and influenced by factors beyond the Company’s control, including but not limited to global economic conditions;
7 unchanged sentences
Thermal Coal.
−Removed: Demand for Peabody’s thermal coal products is impacted by economic conditions;
−Removed: demand for electricity, which is impacted by energy efficient products;
+Added: Demand for Peabody’s thermal coal products is impacted by economic conditions demand for electricity;
and the cost of electricity generation from coal and alternative forms of generation.
3 unchanged sentences
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
In the U.S., natural gas is highly competitive (along with other alternative fuel sources) with thermal coal for electricity generation.
5 unchanged sentences
coal power capacity was retired, and since 2010, U.S.
−Removed: coal power capacity has fallen by approximately forty-two percent.
+Added: coal power capacity has fallen by approximately forty-six percent.
Conversely, emerging technologies, including data centers, artificial intelligence and cryptocurrency, are expected to drive U.S.
3 unchanged sentences
Internationally, thermal coal also competes with alternative forms of electricity generation.
−Removed: The competitiveness and availability of natural gas, liquefied natural gas, oil, nuclear, hydro, wind, solar and biomass varies by country and region.
+Added: The competitiveness and availability of natural gas, liquefied natural gas, oil, nuclear, hydro, wind, solar and biomass vary by country and region.
Seaborne thermal coal consumption is also impacted by the competitiveness of delivered seaborne thermal coal supply from key exporting countries such as Indonesia, Australia, Colombia, the U.S., Russia and South Africa, among others.
In addition, seaborne thermal coal import demand can be significantly impacted by the availability of domestic coal production, particularly in the two leading coal import countries, China and India, among others.
−Removed: Global thermal coal markets were turbulent during 2022 and 2023, due in part to the Russian-Ukrainian conflict and the subsequent ban of Russian coal by European countries.
+Added: Global thermal coal markets were turbulent during 2023, due in part to the Russian-Ukrainian conflict and the subsequent ban of Russian coal by European countries.
Economic sanctions have continued to influence trade flows of thermal coal in 2025.
3 unchanged sentences
Core Natural Resources, Inc.;
−Removed: Eagle Specialty Materials LLC;
+Added: Eagle Summit;
Foresight Energy;
15 unchanged sentences
Seaborne metallurgical coal import demand can be significantly impacted by the availability of domestic coal production, particularly in leading metallurgical coal import countries such as China, among others, and the competitiveness of seaborne metallurgical coal supply from leading metallurgical coal exporting countries of Australia, the U.S., Russia, Canada, Mongolia and Mozambique, among others.
−Removed: Trade flow disruptions occurred during 2022 and 2023 related to sanctions imposed on Russian coal imports.
+Added: In 2025 global metallurgical coal trade flows were influenced by sanctions imposed on Russian coal imports.
Major international direct competitors (listed alphabetically) include Anglo American;
12 unchanged sentences
and Australia, while the remaining are based out of its global headquarters in St.
−Removed: Louis or its business offices in Brisbane and Beijing.
+Added: Louis or its business office in Brisbane.
Peabody strives to create a strong, united workforce with a commitment to safety as a way of life.
−Removed: In 2024, the Company achieved a global safety incidence rate of 0.81 incidents per 200,000 hours worked, which was 73% better than the 2023 U.S.
−Removed: industry average incidence rate of 2.98 incidents per 200,000 hours worked per the Mine Safety and Health Administration (MSHA).
+Added: In 2025, the Company achieved a global safety incidence rate of 0.71 incidents per 200,000 hours worked, which set an all-time record for the lowest incidence rate in Peabody’s history for the second consecutive year after achieving a global safety incidence rate of 0.81 in 2024.
+Added: In comparison to the 2024 U.S.
+Added: industry average, the Company’s 2025 incidence rate was 76% better than the industry average rate of 2.96 incidents per 200,000 hours worked per the Mine Safety and Health Administration (MSHA).
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Peabody strives to offer a work environment that recognizes and develops employees.
15 unchanged sentences
Jarboe 52 Chief Administrative Officer and Corporate Secretary
−Removed: Forkin III 66 Chief Development Officer
−Removed: Malcolm Roberts 51 Chief Marketing Officer
+Added: Forkin III 67 Executive Vice President, Global Strategy and Peabody Development
+Added: Malcolm Roberts 52 Executive Vice President and Chief Commercial Officer
(1) As of February 13, 2026.
5 unchanged sentences
Grech brings a strong operational, commercial and financial background in both mining and other energy business operations and has extensive utilities and capital markets experience.
−Removed: He serves as a director of Blue Danube.
+Added: He is a board member of America's Power, the National Mining Association and Blue Danube Incorporated, and also is a member of the Coal Industry Advisory Board of the International Energy Agency.
+Added: He is an appointed member on the Surface Transportation Board Rail Energy Transportation Advisory Committee.
+Added: In January 2026, Mr.
+Added: Grech was appointed Chair of the National Coal Council.
Grech holds a Bachelor of Science in Electrical Engineering from Lawrence Technological University and an MBA from the University of Michigan.
−Removed: Spurbeck was named Peabody’s Executive Vice President and Chief Financial Officer in June 2020, after serving in an interim capacity from January 2020 through June 2020.
−Removed: He oversees finance, treasury, tax, internal audit, financial reporting, financial planning, risk and mine finance, corporate accounting functions, investor relations and corporate communications, information technology and shared services.
+Added: Spurbeck was named Peabody’s Executive Vice President and Chief Financial Officer in June 2020, after serving in an interim capacity from January 2020.
+Added: He has executive responsibility for finance, treasury, tax, internal audit, financial reporting, financial planning, risk and mine finance, corporate accounting functions, investor relations and corporate communications, information technology and shared services.
Spurbeck has more than 25 years of accounting and financial experience, most recently serving as the Company’s Senior Vice President and Chief Accounting Officer from early 2018 to January 2020.
4 unchanged sentences
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Yeates was named Peabody’s Executive Vice President and Chief Operating Officer in October 2020.
−Removed: He has executive responsibility for global operations including health, safety and environment, mine operations, technical, procurement, and sales and marketing.
+Added: He has executive responsibility for global operations including health, safety and environment, mine operations, technical and procurement.
Yeates has over 40 years of mining industry experience.
14 unchanged sentences
Jarboe holds a Bachelor of Arts Degree from the University of Kansas, a Master’s Degree from the University of Missouri – Kansas City and a Juris Doctor degree from Washington University School of Law.
−Removed: Forkin III was named Chief Development Officer in July 2022 after serving as Senior Vice President - Corporate Development and Strategy since November 2017.
−Removed: He leads global strategy, mergers and acquisitions, portfolio management and renewable energy development.
+Added: Forkin III was named Executive Vice President, Global Strategy and Peabody Development in September 2025, after serving as Chief Development Officer since July 2022.
+Added: He has executive responsibility for global strategy and all non-coal mining related commercial activities including gas generation, rare earth elements, coal generation opportunities and renewable energy development.
Forkin joined Peabody in 2010 and has served in a variety of roles.
2 unchanged sentences
Forkin was in senior leadership roles at a U.S.
−Removed: solar development company and investment banking firms specializing in renewable and conventional energy.
+Added: solar development company and investment banking firms specializing in conventional and renewable energy.
He spent the first nine years of his career at Deloitte LLP.
Forkin holds a Bachelor of Science degree in Accountancy from the University of Illinois at Urbana-Champaign and is a Certified Public Accountant (inactive).
−Removed: Malcolm Roberts was named Chief Marketing Officer in May 2023.
−Removed: He has responsibility for all Peabody sales, marketing and logistics.
+Added: Malcolm Roberts was named Executive Vice President and Chief Commercial Officer in September 2025 after serving as Chief Marketing Officer since May 2023.
+Added: He has responsibility for global commercial strategy including sales, marketing and corporate development.
Roberts joined Peabody in 2021 as Executive General Manager - Sales & Marketing.
18 unchanged sentences
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Mine Safety and Health
13 unchanged sentences
The trust fund has been funded by an excise tax on U.S.
−Removed: From January 1, 2022 through September 30, 2022 the excise tax rates were set at 2% of the gross sales price not to exceed $0.50 per ton of underground coal and $0.25 per ton of surface coal.
−Removed: Effective October 1, 2022, the excise tax rates were set at 4.4% of the gross sales price not to exceed $1.10 per ton of underground coal and $0.55 per ton of surface coal due to the enactment of the Inflation Reduction Act of 2022.
+Added: The current excise tax rates are set at 4.4% of the gross sales price not to exceed $1.10 per ton of underground coal and $0.55 per ton of surface coal.
Peabody recognized expense related to the tax of $54.6 million, $52.2 million and $57.4 million for the years ended December 31, 2025, 2024 and 2023, respectively.
1 unchanged sentence
The Black Lung Benefits Act requires each coal mine operator to secure the payment of its potential benefits liability by either qualifying as a self-insurer or by purchasing and maintaining a commercial insurance contract.
−Removed: The Department of Labor’s (DOL) Office of Workers’ Compensation Programs (OWCP) is responsible for authorizing coal mine operators to self-insure and for setting the security amounts.
+Added: The Department of Labor’s Office of Workers’ Compensation Programs (OWCP) is responsible for authorizing coal mine operators to self-insure and for setting the security amounts.
As part of its ongoing efforts to reform the self-insurance program to ensure that operators are adequately securing their liabilities, the OWCP finalized a rule on December 12, 2024 to update its regulations for authorizing operators to self-insure and for determining appropriate security amounts.
−Removed: The changed requirements for security posted to self-insure black lung liabilities could result in the Company being required to post additional security for its obligations.
+Added: During February 2025, the Trump Administration issued letters to impacted companies that the 60-day deadline to provide information was no longer applicable and that no additional information was required at this time.
+Added: They also announced that the OWCP would provide additional guidance in due course.
+Added: The changed requirements for security posted to self-insure black lung liabilities could result in the Company being required to post additional security of approximately $40 million for its obligations.
Environmental Laws and Regulations
2 unchanged sentences
The Company is also affected by various other federal, state, local and tribal environmental laws and regulations that impact its customers.
+Added: Recent Announcement by the U.S.
+Added: Environmental Protection Agency (EPA).
+Added: In response to an executive order issued by President Trump requiring agencies to identify regulations for regulatory roll back, the EPA announced on March 12, 2025, that it will reconsider several EPA actions, including:
+Added: • Regulation of greenhouse gas (GHG) emissions from new and existing fossil fuel-fired electric generating units (EGUs);
+Added: • National Ambient Air Quality Standards for fine particulate matter (PM);
+Added: • Cross State Air Pollution Rule (CSAPR);
+Added: • Mercury and Air Toxic Standards (MATS);
+Added: • Implementation of the Regional Haze Program;
+Added: • Final September 2023 rule clarifying the scope of federal regulatory authority over wetland and non-navigable waters;
+Added: • Final rule regarding effluent limitations guidelines for the steam electric power generating industry;
+Added: • Rules for disposal of coal combustion residuals.
+Added: Peabody Energy Corporation 2025 Form 10-K
+Added: Peabody will continue to monitor these items, as changes could have significant impact on the U.S.
+Added: coal mining industry, Peabody’s mining operations and its customers.
Surface Mining Control and Reclamation Act .
4 unchanged sentences
In Arizona, where Peabody performs reclamation work on tribal lands, the Company is regulated by OSMRE because the tribes do not have SMCRA authorization.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
SMCRA provides for three categories of bonds:
24 unchanged sentences
The fee amount can change periodically based on changes in federal legislation.
−Removed: Pursuant to the Abandoned Mine Land Reclamation Amendments of 2021, which Congress enacted on November 15, 2021 as part of the Infrastructure Investment and Jobs Act, from October 1, 2021 through September 30, 2034, the fee is $0.224 and $0.096 per ton of surface-mined and underground-mine coal, respectively.
+Added: Pursuant to the Abandoned Mine Land Reclamation Amendments of 2021, which Congress enacted on November 15, 2021 as part of the Infrastructure Investment and Jobs Act, from October 1, 2021 through September 30, 2034, the fee is $0.224 and $0.096 per ton of surface-mined and underground-mined coal, respectively.
The Company recognized expense related to the fees of $21.4 million, $20.4 million and $22.2 million for the years ended December 31, 2025, 2024 and 2023, respectively.
2 unchanged sentences
coal mining operations both directly and indirectly.
+Added: Peabody Energy Corporation 2025 Form 10-K
National Ambient Air Quality Standards (NAAQS) .
−Removed: The CAA requires the United States Environmental Protection Agency (EPA) to review national ambient air quality standards every five years to determine whether revisions to current standards are appropriate.
+Added: The CAA requires the EPA to review national ambient air quality standards every five years to determine whether revisions to current standards are appropriate.
On March 6, 2024, the EPA revised the level of the primary standard for fine particulate matter (PM 2.5), lowering the annual standard from 12.0 µg/m 3 to 9.0 µg/m 3 .
−Removed: States are now required to take several actions to implement the standards which could require fossil fuel electric generating units (EGUs) and non-EGUs to install additional emission control technologies or operate in a different manner.
+Added: States are now required to take several actions to implement the standards which could require fossil fuel-fired EGUs and non-EGUs to install additional emission control technologies or operate in a different manner.
Such actions could potentially increase the cost of utilizing fossil fuels for electric generation and industrial uses.
2 unchanged sentences
Circuit) in Kentucky v.
+Added: Concurrently, per its March 12, 2025 announcement, the EPA continues to reconsider the 2024 standard.
The EPA is also in the process of reviewing the current ozone NAAQS.
2 unchanged sentences
The EPA promulgated a final rule to limit carbon dioxide (CO 2 ) from new, modified and reconstructed fossil fuel-fired EGUs under Section 111(b) of the CAA on August 3, 2015, and published it in the Federal Register on October 23, 2015.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
The rule requires that newly-constructed fossil fuel-fired steam generating units achieve an emission standard for CO 2 (known as the Best System of Emission Reduction (BSER)) which is based on the performance of a supercritical pulverized coal boiler implementing partial carbon capture, utilization and storage (CCUS).
7 unchanged sentences
Notice of final action denying petitions for reconsideration.” Pursuant to an order of the court, these cases remain in abeyance, subject to requirements for the EPA to file 90-day status reports.
−Removed: EPA Regulation of Greenhouse Gas Emissions from New and Existing Fossil Fuel-Fired EGUs .
+Added: EPA Regulation of GHG Emissions from New and Existing Fossil Fuel-Fired EGUs .
On May 9, 2024, the EPA published a final rule for new, modified and reconstructed fossil fuel-fired EGUs in the Federal Register.
13 unchanged sentences
In addition, the final rule includes several “reliability” mechanisms to allow states to provide alternative emission limitations or compliance date extensions in order to maintain adequate electric generation resources and grid reliability.
+Added: Peabody Energy Corporation 2025 Form 10-K
Finally, as part of the final rule, any newly constructed stationary combustion turbine (SCT), where construction or reconstruction of the unit was commenced after May 23, 2023, will be subject to CO 2 emission limits based on whether it is considered to be a low load, intermediate load or base load EGU.
3 unchanged sentences
Circuit in West Virginia v.
−Removed: Petitioners filed an emergency application for a stay of the rule with the U.S.
−Removed: Supreme Court which was denied in an order issued by the U.S.
−Removed: Supreme Court on October 16, 2024.
If the rule is ultimately affirmed and implemented by the EPA and states, it could have a substantial impact on the use of coal and natural gas for the generation of electricity.
A companion rule that addresses how states may implement CO 2 emission limits for existing power plants has also been challenged in West Virginia v.
+Added: On June 17, 2025, in accordance with the agency’s earlier March 12, 2025 announcement, the EPA proposed to repeal all GHG emissions standards for new and existing fossil fuel-fired power plants and, in the alternative, to repeal emission guidelines for existing fossil fuel-fired power plants and requirements for modified coal-fired steam generating to use CCS technology.
+Added: Relatedly, on August 1, 2025, the EPA published a proposed rule to reconsider a 2009 endangerment finding regarding the regulation of GHGs under the CAA.
+Added: In the 2009 action, the EPA found that current and projected atmospheric concentrations of six GHGs were reasonably anticipated to endanger public health and welfare and that GHG emissions from new motor vehicles contributed to air pollution that threatened public health and welfare.
+Added: These determinations formed the basis for subsequent regulation of GHGs from new motor vehicles under section 202 of the CAA.
+Added: On February 12, 2026, the EPA finalized its rescission of the 2009 endangerment finding and also finalized the repeal of all subsequent GHG emission standards.
EPA’s Permitting Regulations for Major Emission Sources .
3 unchanged sentences
In general, most permits are issued by state environmental agencies that either implement EPA permitting programs or have an EPA-approved state program.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
−Removed: Cross State Air Pollution Rule (CSAPR) and CSAPR Update Rule .
+Added: CSAPR and CSAPR Update Rule .
The CSAPR and related updates require numerous U.S.
14 unchanged sentences
Circuit thereafter issued a partial remand of the rule to allow the EPA to respond to comments regarding the severability of the rule’s provisions, which the EPA subsequently did on December 10, 2024.
−Removed: Mercury and Air Toxic Standards (MATS) .
+Added: Per the March 12, 2025 announcement, this rule remains under review by the EPA.
+Added: Mercury and Air Toxic Standards .
In 2012, the EPA published the final MATS rule, which revised the NSPS for NO x , sulfur dioxide and PM for new and modified coal-fueled electricity generating plants, and imposed maximum achievable control technology (MACT) emission limits on hazardous air pollutants (HAPs) from new and existing coal-fueled and oil-fueled electric generating plants.
MACT standards limit emissions of mercury, acid gas HAPs, non-mercury HAP metals and organic HAPs.
+Added: Peabody Energy Corporation 2025 Form 10-K
On March 6, 2023, the EPA issued a final rule which reaffirmed its determination to regulate coal- and oil-fired EGUs under CAA section 112, including the regulation of HAPs from EGUs after considering cost.
On April 24, 2023, the EPA proposed to amend the 2012 MATS rule and require an additional two-thirds reduction in the filterable PM emission of non-mercury HAP metals from existing coal-fired power plants and to reduce the mercury standard for lignite plants by 70%.
−Removed: On May 7, 2024, the EPA finalized a MATS rule which significantly tightens the filterable particulate matter (fPM) emissions limit for existing coal-fired EGU’s, lowering the standard from 0.030 lb/MMBtu to 0.010 lb/MMBtu for all coal-fired power plants.
+Added: On May 7, 2024, the EPA finalized a MATS rule which significantly tightens the filterable PM emissions limit for existing coal-fired EGU’s, lowering the standard from 0.030 lb/MMBtu to 0.010 lb/MMBtu for all coal-fired power plants.
This rule was challenged in the D.C.
Circuit in North Dakota v.
+Added: Per its March 12, 2025 announcement, the EPA proposed on June 17, 2025 to repeal parts of the final 2024 MATS rule regarding filterable PM standards and revise the mercury standard for existing lignite-fired EGUs.
Regional Haze .
4 unchanged sentences
District Court for the District of Columbia which was granted.
−Removed: On December 31, 2024, EPA proposed to revise the due date for plans (for the third regional haze implementation period) from July 31, 2028 to July 31, 2031.
+Added: On December 31, 2024, the EPA proposed to revise the due date for plans (for the third regional haze implementation period) from July 31, 2028 to July 31, 2031.
+Added: As noted above, on March 12, 2025, the EPA announced plans to “restructure” the regional haze program.
+Added: On September 29, 2025, the EPA issued an Advance Notice of Proposed Rulemaking to “streamlining regulatory requirements impacting states’ visibility improvement obligations under the Clean Air Act.”
New Source Review (NSR).
3 unchanged sentences
These rules and guidance may affect the construction, reconstruction and modification of sources and the level of pollution control requirements that will be necessary on a case-by-case basis.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
Federal Coal Leasing Moratorium .
3 unchanged sentences
Montana and Wyoming challenged those decisions in a federal district court on December 11, 2024.
+Added: In response to executive orders aimed at reinvigorating the coal industry and increasing domestic mineral production and the passage of the One Big Beautiful Bill Act, the Bureau of Land Management announced on September 29, 2025, that is making up to 13.1 million acres of federal coal available for lease, lowering royalty rates and streamlining approvals for projects in Montana, Wyoming, Tennessee and beyond.
+Added: Earlier in the year, the Department of the Interior announced it was officially ending its moratorium on federal coal leasing, and the Interior Secretary issued Order 3418 directing actions to review and revise resource management plans restricting coal leasing.
Clean Water Act (CWA) .
4 unchanged sentences
Section 404 of the CWA requires mining companies to obtain permits from the Corps to place dredged or fill material in or mine through jurisdictional waters of the U.S.
+Added: Peabody Energy Corporation 2025 Form 10-K
States are empowered to develop and apply water quality standards.
12 unchanged sentences
Pending litigation over the January 2023 definition has resumed and is ongoing, as the September 2023 final rule did not address many of the claims at issue in those cases.
+Added: On November 20, 2025, the EPA and the Corps proposed additional revisions to the regulatory definition to further align the regulations with Sackett.
+Added: The agencies took comments on the proposed revisions through January 5, 2026, and they plan to take final action later in 2026.
CWA Water Quality Certification Rule .
4 unchanged sentences
District Court for the Western District of Louisiana.
+Added: On July 1, 2025, the EPA published a notice in the Federal Register inviting stakeholder feedback on the 2023 rule.
+Added: The agency is currently working on proposed revisions to the 2023 rule and plans to propose and finalize changes in 2026.
Effluent Limitations Guidelines for the Steam Electric Power Generating Industry .
4 unchanged sentences
In addition, the recently finalized final rule allows EGUs that commit to ceasing coal combustion by December 31, 2034, to comply with less stringent wastewater discharge requirements during the interim.
−Removed: The final rule is subject to numerous legal challenges that have been consolidated in the Eighth Circuit.
+Added: The final rule is subject to numerous legal challenges that have been consolidated in the U.S.
+Added: Court of Appeals for the Eighth Circuit (Eighth Circuit).
If the Eighth Circuit affirms the final rule, it could influence fuel switching or additional coal generating unit retirements by the end of 2034.
+Added: On December 31, 2025, the EPA published a final Deadline Extensions Rule that extends seven compliance deadlines in the 2024 rule.
+Added: The EPA is allowing EGUs six additional years (until December 31, 2031) to determine whether to submit a notice of planned participation for the permanent cessation of coal combustion.
+Added: The EPA further extended the deadlines by five years (to December 31, 2034) for direct discharging EGUs to comply with zero-discharge limitations for flue gas desulfurization wastewater, bottom ash transport water, and combustion residual leachate.
+Added: Finally, the EPA is allowing EGUs that discharge to wastewater treatment plants an additional year-and-a-half to seven-and-a-half years to comply with zero-discharge limitations for those same wastestreams.
+Added: The EPA also issued a No Action Assurance memorandum announcing it will not pursue enforcement actions for certain permit violations by EGUs not yet in compliance with permit requirements related to the 2020 and 2024 rules, if those EGUs satisfy certain conditions.
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
−Removed: National Environmental Policy Act .
+Added: National Environmental Policy Act (NEPA) .
NEPA, signed into law in 1970, requires federal agencies to review the environmental impacts of their decisions and issue either an environmental assessment or an environmental impact statement.
1 unchanged sentence
The NEPA process involves public participation and can involve lengthy timeframes.
−Removed: The White House Council on Environmental Quality (CEQ) issued a final rule comprehensively updating and modernizing its longstanding NEPA regulations on July 16, 2020.
−Removed: That final rule sought to reduce unnecessary paperwork, burdens and delays, promote better coordination among agency decision makers, and clarify scope of NEPA reviews, among other things.
−Removed: States and environmental groups have filed several lawsuits challenging the final rule.
−Removed: On April 20, 2022, however, the CEQ published the final Phase 1 rule that partially amended the 2020 rule by restoring key provisions of the pre-2020 NEPA regulations.
−Removed: The CEQ proposed a Phase 2 rule on July 31, 2023 that makes broader changes to the 2020 rule, and it finalized the Phase 2 rule on May 1, 2024.
−Removed: Separately, the CEQ published NEPA Guidance on Consideration of Greenhouse Gas Emissions and Climate Change on January 9, 2023.
−Removed: The interim guidance was effective immediately, though the agency accepted comments on the guidance.
−Removed: CEQ expected to issue final guidance in April 2024, but it withdrew the guidance from the regulatory review process on November 19, 2024.
−Removed: Finally, on November 12, 2024, a divided panel of the D.C.
−Removed: Circuit held that the CEQ lacks authority to issue legally binding regulations implementing NEPA in Marin Audubon Society v.
−Removed: Federal Aviation Administration , No.
−Removed: Although the federal government and environmental groups have sought rehearing of that decision, litigants in other pending NEPA cases are citing it for the holding that CEQ regulations are not binding.
+Added: Since July 2020, the White House Council on Environmental Quality (CEQ) has revised its longstanding NEPA regulations on several occasions.
+Added: On January 20, 2025, President Trump issued Executive Order 14154, which directed the CEQ to propose rescinding its NEPA regulations and to provide guidance to federal agencies on implementing NEPA and to coordinate the revision of the agencies’ own implementing regulations.
+Added: On February 25, 2025, the CEQ published an Interim Final Rule removing all CEQ NEPA regulations from the Code of Federal Regulations, and the CEQ adopted that rule as final on January 8, 2026.
+Added: The CEQ has clarified that individual agencies are free to continue following or to amend their own NEPA implementation procedures, which largely conformed to the CEQ’s regulations.
+Added: On May 28, 2025, the CEQ withdrew its January 9, 2023 interim guidance on consideration of GHG emissions and climate change when conducting environmental reviews pursuant to NEPA.
+Added: On September 29, 2025, the CEQ issued guidance requiring all heads of federal departments and agencies to revise (or to establish) NEPA implementation procedures consistent with Executive Order 14154, the 2023 and 2025 statutory amendments to NEPA and the U.S.
+Added: Supreme Court’s May 29, 2025 decision in Seven County Infrastructure Coalition v.
+Added: Eagle County, Colorado .
+Added: The CEQ emphasized the need for agencies to streamline procedures and ensure that the NEPA process does not go on for too long in time or in volume.
Resource Conservation and Recovery Act (RCRA) .
13 unchanged sentences
Circuit’s 2018 decision holding that certain provisions of that rule were not sufficiently protective.
+Added: On November 28, 2025, the EPA proposed to extend, by three years, the compliance deadline in the 2020 amendments for owners and operators to complete closure of unlined impoundments larger than 40 acres.
On May 8, 2024, the EPA published a final rule containing additional amendments to the 2015 CCR rule that further address aspects of the D.C.
11 unchanged sentences
The agencies issued proposed rules on June 22, 2023, and they published three final revised rules on April 5, 2024.
+Added: On November 21, 2025, the agencies published four proposed rules to restore the ESA regulations to their 2019 and 2020 framework.
+Added: The agencies accepted comments on the proposed rules through December 22, 2025.
Use of Explosives .
5 unchanged sentences
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Federal Report on Climate Change .
4 unchanged sentences
SEC Climate-Related Disclosures .
−Removed: On March 6, 2024, the SEC adopted final rules it expects will enhance and standardize climate-related disclosures by public companies and in public offerings.
−Removed: Specifically, the final rules will require disclosure of, among other things, climate-related risks that have had or are reasonably likely to have a material impact on a public company’s business strategy, results of operations or financial condition;
−Removed: certain greenhouse gas (GHG) emissions associated with a public company along with, in many cases, an attestation report by a GHG emissions attestation provider;
+Added: On March 6, 2024, the SEC adopted final rules intended to enhance and standardize climate-related disclosures by public companies and in public offerings.
+Added: Specifically, the final rules required disclosure of, among other things, climate-related risks that have had or are reasonably likely to have a material impact on a public company’s business strategy, results of operations or financial condition;
+Added: certain GHG emissions associated with a public company along with, in many cases, an attestation report by a GHG emissions attestation provider;
and certain climate-related financial metrics to be included in a company’s audited financial statements.
1 unchanged sentence
On April 4, 2024, the SEC voluntarily stayed implementation of the final rules pending such judicial review.
−Removed: The Company is assessing the potential impact of the final rules.
−Removed: State Climate Change Legislation.
−Removed: On May 30, 2024, Vermont’s S259, referred to as the Climate Superfund Act, became law and on December 26, 2024, the governor of New York signed S02129, known as the Climate Change Superfund Act (collectively, the Climate Change Laws).
−Removed: The Climate Change Laws aim to require payments from entities deemed “responsible parties” to fund infrastructure projects meant to address climate change in New York.
−Removed: The New York law defines a “responsible party” as an entity that “engaged in the trade or business of extracting fossil fuel or refining crude oil” from January 1, 2000 to December 31, 2018 and that is determined to be accountable for more than 1 billion metric tons of certain greenhouse gas emissions.
−Removed: Responsible party does not include any person lacking “sufficient connection with the state to satisfy the nexus” of the U.S.
−Removed: Constitution.
−Removed: The Vermont law contains a similar definition of a responsible party, except that Vermont’s covered period extends from 1995 to 2024.
−Removed: Both states have stated that they will enact future regulations to carry out the provisions of the law.
−Removed: On December 30, 2024, the U.S.
−Removed: Chamber of Commerce and American Petroleum Institute filed a lawsuit in the District of Vermont challenging the state’s Climate Superfund Act arguing that the law violates constitutional principles, including federal preemption, interstate commerce and due process, while also imposing excessive fines and an unconstitutional taking.
−Removed: Additionally, on February 6, 2025, a group of 22 states, led by West Virginia, filed a lawsuit against New York State over its Climate Change Superfund Act, arguing that the law’s $75 billion penalty on fossil fuel producers unfairly shifts costs onto out-of-state energy producers and consumers and violates multiple constitutional protections.
−Removed: The plaintiffs also claim that New York is overstepping its jurisdiction by imposing retroactive fines and discriminatory sanctions, potentially threatening U.S.
−Removed: energy independence.
−Removed: The Company expects the Climate Change Laws will continue to be challenged.
−Removed: The impacts of these laws are currently being assessed.
+Added: On March 27, 2025, the SEC announced that it would end its defense of the final rules.
+Added: On April 24, 2025, the Eighth Circuit directed the SEC to provide a status update in the ongoing litigation concerning the final rules.
+Added: On July 23, 2025, the SEC indicated that it does not intend to review or reconsider the final rules but requested that the Eighth Circuit proceed with the litigation and decide the case.
+Added: In September 2025, the Court declined to issue a ruling and is instead keeping the litigation on hold, noting that it is the SEC’s “responsibility to determine whether its Final Rules will be rescinded, repealed, modified, or defended in litigation.”
+Added: One Big Beautiful Bill Act of 2025 (OBBBA).
+Added: The OBBBA was signed into law on July 4, 2025.
+Added: Several provisions of the legislation affect the Company’s consolidated operations, financial condition or cash flows, including a reduction to the federal royalty rate on coal production and the addition of metallurgical coal which is suitable for use in the production of steel to the list of critical minerals eligible for the Section 45X tax credit through 2029 at a rate of 2.5% of production costs.
+Added: Peabody realized benefits of approximately $19 million during the year ended December 31, 2025 related to the federal royalty reduction provisions of the legislation.
+Added: Peabody estimates an annual benefit of approximately $5 million related to the Section 45X tax credit which will be recognized against applicable production costs in the consolidated statements of operations.
+Added: The Company will continue to evaluate the effect of the OBBBA as more guidance is issued.
+Added: Complaints Filed Against “Climate Superfund Laws” and Announced State Actions .
+Added: On April 30 and May 1, 2025, respectively, the U.S.
+Added: Department of Justice filed complaints for declaratory and injunctive relief against the states of Michigan and Hawaii regarding alleged liability of fossil fuel companies for past GHG emissions and against New York and Vermont for “climate superfund” laws.
+Added: These complaints allege that existing litigation and state laws interfere with federal law, including the CAA, and with interstate and foreign commerce.
+Added: The Company will monitor this litigation and its potential impact on the U.S.
+Added: coal mining industry, its mining operations and customers.
Regulatory Matters — Australia
10 unchanged sentences
Environmental approval processes involve complex issues that, on occasion, require lengthy studies and documentation and are subject to legal challenge.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
There are bilateral agreements in place between the Federal Government and the Queensland and New South Wales State Governments that allow the environmental assessment process at the State level to be relied upon for a decision under the EPBC Act.
+Added: Peabody Energy Corporation 2025 Form 10-K
In Queensland and New South Wales, the development of a mine requires both the grant of a right to extract the resource and an approval which authorizes the environmental impact.
4 unchanged sentences
The Clean Energy Regulator administers the NGER Act.
−Removed: The federal Department of Environment and Energy is responsible for NGER Act-related policy developments and review.
−Removed: In May 2023, the Australian Parliament passed reforms to the National Greenhouse and Energy Reporting (Safeguard Mechanism) Rule 2015 .
−Removed: The reforms commenced on July 1, 2023 and prescribed site specific baseline emissions for heavy emitting facilities as benchmarks for year-on-year improvement (proposed to be 4.9% each year to 2030) before transitioning to industry average emissions benchmarks by 2030.
−Removed: Proponents will earn tradeable credits (Safeguard Mechanism Credits) when emissions are below their baselines or can purchase credits to offset emissions.
−Removed: Access to existing Australian Carbon Credit Units will continue unchanged albeit with a price ceiling of $75 Australian dollars per tonne of CO 2 in 2023-2024, increasing with the Consumer Price Index plus 2% each year.
+Added: The federal Department of Climate Change, Energy, the Environment and Water (DCCEEW) is responsible for NGER Act-related policy developments and review, including with respect to Australia’s key emissions reductions policy, the Safeguard Mechanism (enacted through the NGER Act and other legislation).
+Added: Under the Safeguard Mechanism, site-specific baseline emissions for heavy emitting facilities are prescribed as benchmarks for year-on-year improvement (4.9% each year to 2030, following which the decline rates from July 1, 2030 will be set for each year in five-year blocks by the DCCEEW), as well as a weighted integration of the industry average emission baseline.
+Added: Proponents earn tradeable credits (Safeguard Mechanism Credits) when emissions are below their baselines or can purchase credits (Safeguard Mechanism Credits or Australian Carbon Credit Units (an Australian Government incentive)) to offset emissions.
+Added: A ceiling for the price of Australian Carbon Credit Units of $75 Australian dollars per tonne of CO 2 equivalent was fixed in 2023-2024, with that ceiling increasing with the Consumer Price Index plus 2% each year (the price ceiling being $79.20 Australian dollars per tonne of CO 2 equivalent for 2024-2025).
+Added: The Safeguard Mechanism also includes additional emission reduction measures including a cap on overall net emissions from facilities covered by the scheme through 2030, a cap of net zero tonnes CO 2 for any financial year beginning after June 30, 2049, and a requirement that where the Minister for Environment and Water grants an approval under the EPBC Act to a new or expanded facility covered by the scheme, they are required to give an estimate of the facility's Scope 1 emissions to the Minister for Climate Change, the Climate Change Secretary and the Climate Change Authority for assessment against scheme targets.
In June 2024 amendments to the NGER Act came into effect requiring open-cut mines covered by the Safeguard Mechanism that currently report fugitive methane emissions using a basic method with minimal data inputs (Method 1) to transition over a two-year period to a more complex method requiring site-level sampling and analysis (Methods 2 or 3).
This change in reporting methods is expected to increase the Safeguard Mechanism liability position of open-cut mining operations in Queensland.
−Removed: The impacts of this change are currently being assessed.
−Removed: On March 27, 2023, the Australian federal government announced several additional emission reduction measures in the Safeguard Mechanism (Crediting) Amendments Bill 2023 passed by the federal Parliament on March 30, 2023.
−Removed: The legislation introduced a cap on overall net emissions from facilities covered by the scheme through 2030.
−Removed: The legislation also set a cap of net zero tonnes carbon dioxide equivalent for any financial year beginning after June 30, 2049.
−Removed: In addition, if the Minister for Environment and Water grants an approval under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) to a new or expanded facility covered by the scheme, the Minister will be required to give an estimate of the facility's Scope 1 emissions to the Minister for Climate Change, the Climate Change Secretary and the Climate Change Authority for assessment against scheme targets.
−Removed: The legislation became effective on July 1, 2023.
+Added: Development of the model to comply with the updated act is underway (utilizing guidance from the Australian coal industry’s research association (ACARP)) to ensure Peabody will meet its future reporting obligations for the reporting of fugitive emissions.
+Added: As the modelling is not yet complete, Peabody expects to have further understanding of the financial impacts resulting from the change in reporting methodology later in 2026.
+Added: Along with the development of the model and change to reporting obligations, the National Greenhouse and Energy Reporting (Safeguard Mechanism) Rule 2015 includes language giving the Clean Energy Regulator discretion to vary a facility’s emission intensity determination in instances where the transition to a higher order reporting methodology results in a material change to the facility’s determination.
+Added: This consideration is undertaken at or near the time of reporting under the NGER Act, due October 31 annually, and may further influence impacts of the revised NGER Act on open-cut coal mines.
Industrial Relations Laws.
−Removed: A national industrial relations system, the Fair Work Act and National Employment Standards, applies to all employers and employees.
−Removed: The matters regulated under the national system include general employment conditions, unfair dismissal, enterprise bargaining, bullying claims, industrial action and resolution of workplace disputes.
−Removed: Most of the hourly workers employed in the Company’s mines are also covered by the Black Coal Mining Industry Award and company specific enterprise agreements approved under the national system.
−Removed: In December 2022, the federal government passed The Fair Work Legislation Amendment (Secure Jobs, Better Pay) Act 2022, which amends the Fair Work Act.
−Removed: The legislation introduced several changes to workplace laws in Australia including changes to enterprise agreement making and termination;
−Removed: when industrial action can be taken;
−Removed: and access to multi-employer bargaining or single interest employer authorizations.
−Removed: Following this amendment, the Wambo Underground Mine and four other mines in New South Wales were served with an application for a single interest employer authorization which was granted by the Fair Work Commission against three employers including Peabody.
−Removed: The three employers have appealed the authorization with the hearing currently scheduled for March 2025.
+Added: A national industrial relations system, the Fair Work Act and National Employment Standards, applies to all private sector employers and employees where the employer is a corporation.
+Added: The matters regulated under the national system include general employment conditions, unfair dismissal, enterprise bargaining, bullying claims, industrial action and resolution of workplace disputes as well as other matters affecting the employment relationship.
+Added: Most of the hourly workers employed in the Company’s mines are also covered by the Black Coal Mining Industry Award and company specific enterprise agreements approved under the national system, which set terms and conditions of employment.
On December 7, 2023, the Fair Work Legislation Amendment (Closing Loopholes) Bill 2023 was passed by the Australian Federal Parliament.
−Removed: The bill allows unions and/or employees to make application to the Fair Work Commission for a ‘regulated labour hire arrangement order’ that, if successful, requires employers to provide similar wages and conditions to regulated workers as those provided to permanent employees, unless the Fair Work Commission is satisfied that it is not fair and reasonable to do so.
−Removed: Various union applications for regulated labor hire arrangements to apply at Australian coal mining operations are currently being considered by Australia’s Fair Work Commission.
+Added: The legislation allows unions, employees and/or hosts to make application to the Fair Work Commission (the Commission) for a ‘regulated labour hire arrangement order’ that, if successful, requires labor hire employers to provide similar wages and conditions to regulated workers as those provided to employees of the host.
+Added: Orders have been made in relation to labor hire employers who provide labor to Peabody Energy Australia PCI Mine Management Pty Ltd (now a regulated host) at its Coppabella Mine and to Helensburgh Coal Pty Ltd (now a regulated host) at the Metropolitan Mine, increasing Peabody’s operating cost.
+Added: Industrial relations laws are generally enforceable by Court action, and penalties can apply for breach.
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
Native Title and Cultural Heritage Laws.
4 unchanged sentences
There is also federal and state legislation to prevent damage to Aboriginal cultural heritage and archaeological sites.
−Removed: Aboriginal and Torres Strait Islander Heritage Protection Act 1984.
−Removed: On August 16, 2024, Australia’s Minister for the Environment and Water made a declaration under Section 10 of the Aboriginal and Torres Strait Islander Heritage Protection Act 1984 over a riverine area in NSW that is a proposed tailings dam site for a gold mining project.
−Removed: The declaration prohibits any mining or related development activity in the area despite the project having previously obtained all necessary environmental and planning approvals under state and federal government laws.
+Added: Both New South Wales (NSW) and Queensland have additional state-specific legislation in place that enables Aboriginal people to claim freehold title to available land currently owned by the state government.
+Added: If and when title to any claimable land is transferred to the relevant Aboriginal people, then ongoing consultation and compensation arrangements will need to be in place with the new landowner.
+Added: There is claimable land within proximity to all Company operations in NSW and Queensland and accordingly, as and when any claims are processed by the respective state government, the Company will need to progress consultation and compensation arrangements to ensure that its access rights are maintained.
+Added: The Company continues to monitor the progress of any claims that have the potential to impact its operations.
+Added: Aboriginal and Torres Strait Islander Heritage Protection Act 1984 (ATSIHP).
+Added: The purpose of the ATSIHP Act is to ensure the preservation and protection from harm or desecration of areas and objects in Australia and in Australian waters, that are of particular significance to Aboriginal people.
+Added: Under the ATSIHP Act, the Commonwealth Minister for Indigenous Australians can make declarations in relation to areas or objects for the purposes of protecting Aboriginal and Torres Strait Islander heritage.
+Added: Declarations are made in response to applications made by an Aboriginal person or group showing that the area or object is significant with respect to Aboriginal culture and is under threat of injury or desecration.
+Added: Such a declaration may prevent any development being carried out on the relevant area of land.
+Added: In 2024, the Commonwealth Minister made a declaration under the ATSIHP Act over an area that had been approved under state and federal environmental and planning laws for a gold mining project in NSW.
The project proponent has indicated that the decision renders the mine project unviable and has initiated Federal Court proceedings seeking a judicial review of the decision-making process.
−Removed: The first hearing is scheduled for March 4, 2025.
+Added: Hearings into the matter commenced December 2025, and the case remains before the Federal Court.
+Added: The Company will monitor any legal precedents set in this case that have the potential to impact its operations.
Australian Mine Rehabilitation (Reclamation) Laws.
12 unchanged sentences
New South Wales Government
−Removed: In New South Wales, laws and regulations related to mining include, but are not limited to, the Mining Act 1992, Work Health and Safety (Mines and Petroleum Sites) Act 2013, Coal Mine Subsidence Compensation Act 2017, Environmental Planning and Assessment Act 1979 (EPA Act), Environmental Planning and Assessment Regulation 2021, Protection of the Environment Operations Act 1997, Contaminated Land Management Act 1997, Explosives Act 2003, Water Management Act 2000, Water Act 1912, Biodiversity Conservation Act 2016 (BC Act), Heritage Act 1977, Aboriginal Land Rights Act 1983, Crown Land Management Act 2016, Dangerous Goods (Road and Rail Transport) Act 2008, Fisheries Management Act 1994, Native Title (New South Wales) Act 1994, Biosecurity Act 2015, Roads Act 1993 and National Parks and Wildlife Act 1974.
+Added: In New South Wales, laws and regulations related to mining include, but are not limited to, the Mining Act 1992, Work Health and Safety (Mines and Petroleum Sites) Act 2013, Coal Mine Subsidence Compensation Act 2017, Environmental Planning and Assessment Act 1979 (EPA Act), Protection of the Environment Operations Act 1997, Contaminated Land Management Act 1997, Explosives Act 2003, Water Management Act 2000, Water Act 1912, Biodiversity Conservation Act 2016 (BC Act), Heritage Act 1977, Aboriginal Land Rights Act 1983, Crown Land Management Act 2016, Dangerous Goods (Road and Rail Transport) Act 2008, Fisheries Management Act 1994, Native Title (New South Wales) Act 1994, Biosecurity Act 2015, Roads Act 1993 and National Parks and Wildlife Act 1974.
+Added: Peabody Energy Corporation 2025 Form 10-K
NSW Environmental Laws.
2 unchanged sentences
Any modification to an existing planning consent must be substantially the same as the approved development, otherwise a new consent is required.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
In December 2023, the Climate Change (Net Zero Future) Act 2023 commenced, which legislates NSW Government’s target to achieve net zero GHG emissions by 2050 and interim targets of a 50% reduction on 2005 levels by 2030 and a 70% reduction by 2035.
In June 2024, the New South Wales Minister for Planning and Public Spaces requested the New South Wales Independent Planning Commission to consider the NSW Government’s emissions reduction targets and the act’s guiding principles in its assessment of new planning applications.
−Removed: The NSW Environment Protection Authority (EPA) released its final NSW Guide for Large Emitters in January 2025, which applies to new applications or significant modifications for large emitting premises, such as mining operations.
+Added: The NSW EPA released its final NSW Guide for Large Emitters in January 2025, which applies to new applications or significant modifications for large emitting premises, such as mining operations.
The NSW Guide for Large Emitters sets out the assessment requirements including a need to implement reasonable and feasible emissions reduction technologies, set long-term and interim emission goals for the project and describe any greenhouse gas offset strategies.
+Added: The NSW EPA has proposed additional reforms that may result in additional prescriptive climate change mitigation requirements for high-emitting facilities including coal mines.
+Added: These proposals include the phasing in of new climate mitigation requirements into existing environmental protection licenses (EPLs) for mining operations that emit more than 25,000 tonnes of CO 2 equivalent (scope 1 and scope 2) per year;
+Added: new reporting obligations for mining operations that may include an obligation to report annual climate change emissions and prepare three-yearly Climate Change Mitigation and Adaptation Plans;
+Added: and prescriptive mitigation measures requiring coal mine operators to address fugitive methane emissions and reduce emissions from diesel combustion.
+Added: Peabody will monitor the passage of these reforms and assess potential impacts on its operations.
The Biodiversity Conservation Act 2016 (BC Act) regulates biodiversity assessment and offsetting requirements for mining projects in New South Wales.
Biodiversity offsets can be provided through security of land-based offsets, purchase of offset credits through a market system, or payment into a government-administered Biodiversity Conservation Fund.
−Removed: In December 2024, the Biodiversity Conservation Amendment (Biodiversity Offsets Scheme) Bill 2024 passed New South Wales Parliament.
−Removed: This Bill legislates a transition of the biodiversity offset scheme to “net positive biodiversity outcomes”.
+Added: In March 2025, the Biodiversity Conservation Amendment (Biodiversity Offsets Scheme) Act 2024 commenced.
+Added: This amendment act implements a transition of the biodiversity offset scheme to “net positive biodiversity outcomes”.
It also requires proponents of projects to take all reasonable measures to firstly avoid, and then minimize, impacts on biodiversity values.
−Removed: The recent changes to the biodiversity offset laws will affect approval processes and timeframes for future NSW mining projects.
+Added: The changes to the biodiversity offset laws have affected approval processes and timeframes for NSW mining projects.
NSW Reclamation Laws.
6 unchanged sentences
NSW Strategic Statement on Coal Exploration and Mining.
−Removed: The New South Wales (NSW) Government released a Strategic Statement on Coal Exploration and Mining in June 2020 which provides a high level framework for the government's policy approach to the future of the coal sector.
−Removed: The NSW Government has committed to a review of the Statement this year, however no specific date has been set for commencement of the review.
+Added: The NSW Government released a Strategic Statement on Coal Exploration and Mining in June 2020 which provides a high level framework for the government's policy approach to the future of the coal sector.
+Added: The NSW Government is currently reviewing the statement;
+Added: however, no date has been set for the release of an updated statement.
NSW Coal Royalty Laws .
1 unchanged sentence
This is equal to 8.8% for deep underground mines (coal extracted at depths greater than 400 meters below ground surface), 9.8% for underground mines and 10.8% for open-cut mines.
−Removed: As part of its 2023-2024 state budget the newly elected New South Wales government announced that from July 1, 2024 it would be increasing each of these rates by 2.6% to 8.8% for deep underground mines, 9.8% for underground mines and 10.8% for open-cut mines.
−Removed: The future impacts of this royalty rate rise on Peabody’s NSW mining operations is being assessed.
−Removed: NSW Coal Directions.
−Removed: The State of New South Wales (NSW) enacted the Energy and Utilities Administration Amendment Act 2022 granting the State Premier and Minister for Energy the ability to issue directions in the event of a coal market price emergency (among other powers).
−Removed: On December 22, 2022, the State Premier declared such an emergency, intended to control coal and electricity pricing.
−Removed: Subsequently, directions were issued to Peabody Energy Australia Pty Ltd and other coal producers with operations in NSW, which were amended at various dates.
−Removed: The most recent directions required Peabody Energy Australia Pty Ltd to reserve a portion of coal produced by Wambo Coal Pty Ltd and Wilpinjong Coal Pty Ltd for sale to NSW power generators at a capped price until June 30, 2024 and imposed additional reporting obligations to demonstrate compliance.
−Removed: The Australian Energy Regulator has confirmed that the directions have ended, and the last report was submitted on July 12, 2024.
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
NSW Industrial Manslaughter Laws .
−Removed: On June 20, 2024, the Work Health and Safety Amendment (Industrial Manslaughter) Bill 2024 (Bill) passed the NSW Parliament.
−Removed: The Bill amends the Work Health and Safety Act 2011 to include the offense of industrial manslaughter.
−Removed: The offense will apply to a person conducting a business or undertaking (PCBU) or an officer of a PCBU who engages in conduct that constitutes a failure to comply with the person’s health and safety duty and causes the death of a worker or another individual to whom the duty is owed;
+Added: The Work Health and Safety Act 2011 include the offense of industrial manslaughter.
+Added: The offense applies to a person conducting a business or undertaking (PCBU) or an officer of a PCBU who engages in conduct that constitutes a failure to comply with the person’s health and safety duty and causes the death of a worker or another individual to whom the duty is owed;
and the person engages in conduct with gross negligence.
The maximum penalty is $20 million Australian dollars for a body corporate or 25 years imprisonment for an individual.
−Removed: The Bill also provides for an alternative finding of guilt.
−Removed: That is, where a person is charged with industrial manslaughter, and on trial the court or jury is not satisfied that the person is guilty but is satisfied that the person is guilty of an offense against section 31 (Gross negligence or reckless conduct— Category 1) of the NSW WHS Act, the person may be found guilty and liable to punishment for that offense.
+Added: The act allows an alternative finding of guilt:
+Added: if a person is charged with industrial manslaughter is not found guilty of that offense, but the court is satisfied they committed an offense under section 31 (Gross negligence or reckless conduct— Category 1) of the NSW Work Health Safety Act, they may instead be guilty and liable to punishment for that offense.
NSW Workplace Safety Laws.
3 unchanged sentences
Underground coal mine operators must also develop and implement safety management systems and procedures to minimize worker exposures to carbon dioxide, ensuring no worker is exposed to an 8-hour time-weighted average atmospheric concentration of carbon dioxide that is greater than 30,000 parts per million for short-term exposure or 12,500 parts per million otherwise.
−Removed: Metropolitan Mine Stormwater Discharge.
−Removed: Significantly high rainfall in New South Wales, including unprecedented rain totals at the Metropolitan Mine site resulted in stormwater being discharged from the mine site on several occasions in 2021 and 2022.
−Removed: On September 6, 2023, the NSW Environment Protection Authority commenced a prosecution for five breaches of the Protection of the Environment Operations Act 1997 relating to the stormwater discharges.
−Removed: On March 15, 2024, the Company pled guilty to two of the charges related to water pollution and two charges related to a failure to adequately maintain plant and equipment were consolidated into one charge to which the Company also pled guilty.
−Removed: The remaining charge was discontinued.
−Removed: A sentencing hearing was held in November 2024 and the judgment has been reserved.
−Removed: The judgment is expected in the second quarter of 2025.
Queensland Government
−Removed: In Queensland, laws and regulations related to mining include, but are not limited to, the Mineral Resources Act 1989, Environmental Protection Act 1994 (EP Act), Environmental Protection Regulation 2008, Planning Act 2016, Coal Mining Safety and Health Act 1999, Minerals and Energy Resources (Common Provisions) Act 2014, Explosives Act 1999, Aboriginal Cultural Heritage Act 2003, Water Act 2000, State Development and Public Works Organisation Act 1971, Queensland Heritage Act 1992, Transport Infrastructure Act 1994, Nature Conservation Act 1992, Vegetation Management Act 1999, Biosecurity Act 2014, Land Act 1994, Regional Planning Interests Act 2014, Fisheries Act 1994 and Forestry Act 1959.
−Removed: A guideline has been issued that provides more certainty to the industry on the circumstances in which an EPO may be issued.
+Added: In Queensland, laws and regulations related to mining include, but are not limited to, the Mineral Resources Act 1989, Environmental Protection Act 1994 (EP Act), Planning Act 2016, Coal Mining Safety and Health Act 1999, Minerals and Energy Resources (Common Provisions) Act 2014, Explosives Act 1999, Aboriginal Cultural Heritage Act 2003, Water Act 2000, State Development and Public Works Organisation Act 1971, Queensland Heritage Act 1992, Transport Infrastructure Act 1994, Nature Conservation Act 1992, Vegetation Management Act 1999, Biosecurity Act 2014, Land Act 1994, Regional Planning Interests Act 2014, Fisheries Act 1994 and Forestry Act 1959.
+Added: A guideline has been issued that provides more certainty to the industry on the circumstances in which an environmental protection order (EPO) may be issued.
Queensland Environmental and Rehabilitation (Reclamation) Laws.
3 unchanged sentences
Mines must submit an annual return reporting on their EA compliance.
−Removed: In November 2016, amendments to the EP Act and the Water Act 2000 provided for regulatory scrutiny of the environmental impacts of underground water extraction during the operational phase of resource projects for all tenements yet to commence mineral extraction.
−Removed: The ‘chain of responsibility’ provisions of the EP Act, which became effective in April 2016, allow the regulator to issue an environmental protection order (EPO) to a related person of a company in two circumstances:
+Added: The EP Act and the Water Act 2000 provide for regulatory scrutiny of the environmental impacts of underground water extraction during the operational phase of resource projects for all tenements yet to commence mineral extraction.
+Added: The ‘chain of responsibility’ provisions of the EP Act allow the regulator to issue an EPO to a related person of a company in two circumstances:
(a) if an EPO has been issued to the company, an EPO can also be issued to a related person of the company (at the same time or later);
or (b) if the company is a high risk company (as defined in the EP Act), an EPO can be issued to a related person of the company (whether or not an EPO has also been issued to the company).
−Removed: In November 2018, the Queensland government passed the Mineral and Energy Resources (Financial Provisioning) Act 2018 which introduced an updated financial assurance (FA) framework and progressive rehabilitation requirements.
−Removed: The new FA framework created a pooled fund covering most mines and most of the total industry liability, plus other options for providing FA if not part of the pooled fund (for example, allowing insurance bonds or cash).
+Added: The Mineral and Energy Resources (Financial Provisioning) Act 2018 contains financial assurance (FA) framework and progressive rehabilitation requirements.
+Added: The FA framework provides for a pooled fund covering most mines and most of the total industry liability, plus other options for providing FA if not part of the pooled fund (for example, allowing insurance bonds or cash).
The percentage rate of the total rehabilitation cost payable into the pooled fund takes into account the financial strength of the holder of the EA for the mine and the project strength of the mine.
The total rehabilitation cost is determined using an updated rehabilitation cost calculator, which does not provide for discounting.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
−Removed: The new progressive rehabilitation requirements, which commenced on November 1, 2019, require each mine to establish a schedule of rehabilitation milestones covering the life of the mine, and any significant changes to the timing of rehabilitation require regulatory approval.
+Added: Progressive rehabilitation requirements require each mine to establish a schedule of rehabilitation milestones covering the life of the mine, and any significant changes to the timing of rehabilitation require regulatory approval.
If there is to remain an area within the mine that does not have a post-mining land use (referred to as a non-use management area or NUMA) then each such NUMA will need to pass a public interest evaluation test as part of the approval process.
1 unchanged sentence
Under the legislation, an existing mine was exempt from the requirement to justify its NUMAs to the extent that its existing approvals provided for such areas.
+Added: Peabody Energy Corporation 2025 Form 10-K
Queensland Residual Risk Laws.
−Removed: On August 20, 2020, the Environmental Protection and Other Legislation Amendment Act (Queensland) 2020 (EPOLA Act) became law, amending the residual risk framework that aims to ensure that any remaining risks on former resource sites are appropriately identified, costed and managed.
+Added: Queensland’s residual risk framework under the EP Act and Mineral and Energy Resources (Financial Provisioning) Act 2018 aims to ensure that any remaining risks on former resource sites are appropriately identified, costed and managed.
On completion of all mining activities, the holder of the EA for the mine can apply to surrender the EA once all conditions, requirements and rehabilitation obligations have been met.
5 unchanged sentences
The Mineral Resources Act 1989 is the principal legislation that regulates mining exploration, extraction and processing in Queensland, including coal mining.
−Removed: The Act was amended in 2016 to include significant changes to the management of overlapping coal and coal seam gas tenements, and the coordination of activities and access to private and public land.
+Added: The act includes the management of overlapping coal and coal seam gas tenements, and the coordination of activities and access to private and public land.
Queensland Occupational Health and Safety Laws.
5 unchanged sentences
Queensland Mine Safety Laws .
−Removed: On July 1, 2020, the Resources Safety and Health Queensland Act 2020 became effective.
−Removed: It establishes Resources Safety and Health Queensland (RSHQ) as a statutory body designed to ensure independence of the mining safety and health regulator.
−Removed: RSHQ includes inspectorates for coal mines, mineral mines and quarries, explosives and petroleum and gas.
−Removed: The new law seeks to enhance the role of advisory committees to identify, quantify and prioritize safety and health issues in the mining and quarrying industries.
−Removed: It also provides for an independent Work Health and Safety Prosecutor to prosecute serious offenses under resources safety legislation.
+Added: Resources Safety and Health Queensland (RSHQ) administers the Coal Mining Safety and Health Act 1999 and other safety legislation covering inspectorates for coal and mineral mines, quarries, explosives, and petroleum and gas.
+Added: The act also establishes an independent Work Health and Safety Prosecutor for serious offenses.
+Added: In early 2025, Queensland appointed its first Mining and Resources Coroner, responsible for investigating fatalities and issuing safety recommendations, with mandatory inquests for deaths in the industry.
+Added: Further, on November 19, 2025, the Queensland Minister for Natural Resources and Mines introduced the Independent Review of RSHQ Report.
+Added: Additional reforms and restructuring of RSHQ are expected as the government responds to the Report’s recommendations.
Queensland Industrial Manslaughter Laws .
−Removed: On May 20, 2020, the Queensland Parliament passed laws that introduced the criminal offense of ‘industrial manslaughter’ for executive officers, individuals who are senior officers and companies in the mining industry.
−Removed: Individuals face a maximum prison sentence of 20 years and companies can be fined up to $13 million Australian dollars.
−Removed: The bill also introduced the requirement for statutory role holders to be employees of the coal mine operator entity.
+Added: In Queensland, section 48D of the CMSH Act provides that a PCBU or a "senior officer" of an of an employer for a coal mine, commits an offense if their negligent conduct causes the death of a worker.
+Added: Industrial manslaughter attracts maximum penalties of 20 years imprisonment for an individual and $10 million for a body corporate.
+Added: The offense applies where a worker dies (or is injured and later dies) in the course of work, the senior officer’s conduct causes the death of the coal mine worker, and the senior officer is negligent about causing the death of the coal mine worker by the conduct.
+Added: A similar duty applies to an employer for a coal mine under section 48C of the CMSH Act.
+Added: "Senior officer” for this Queensland offense means an executive officer of the corporation, being a person who is concerned with, or takes part in, the corporation’s management, whether or not the person is a director or the person’s position is given the name of executive officer.
+Added: It is intended to capture those at the highest levels with authority to create and influence safety culture and resource allocation.
Queensland Coal Royalties.
−Removed: On and from July 1, 2022, the Queensland government introduced three new royalty tiers for coal produced and sold from the state.
+Added: In Queensland coal royalties are applied according to a progressive, tiered system where higher percentage rates are applied as coal prices rise.
+Added: On July 1, 2022, the former Labor administration in Queensland introduced three new royalty tiers for coal produced and sold from the state.
The new tier rates are 20% for the portion of prices above $175 Australian dollars per tonne;
1 unchanged sentence
and a 40% tier for the portion of prices above $300 Australian dollars per tonne.
+Added: The increased rates increased royalty costs for Peabody’s Queensland operations.
+Added: Despite advocacy by the coal sector, the current Liberal National Party administration has committed to maintaining the current system.
+Added: The Company will continue to advocate for royalty reductions and monitor the government’s actions on this issue.
+Added: Peabody Energy Corporation 2025 Form 10-K
Risks Related to Global Climate Change
−Removed: Peabody recognizes that climate change is occurring and that human activity, including the use of fossil fuels, contributes to GHG emissions.
+Added: Peabody will continue to balance a growing demand for energy and steel with initiatives to reduce GHG emissions that mitigate risk, align with its customers’ commitments and meet its regulatory obligations.
The Company’s largest contribution to GHG emissions occurs indirectly, through the coal used by its customers in the generation of electricity and the production of steel (Scope 3).
To a lesser extent, the Company directly and indirectly contributes to GHG emissions from various aspects of its mining operations, including from the use of electrical power and combustible fuels, as well as from the fugitive methane emissions associated with coal mines and stockpiles (Scopes 1 and 2).
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
Peabody’s Board of Directors and management believe that coal is essential to affordable, reliable energy and will continue to play a significant role in the global energy mix for the foreseeable future.
−Removed: Peabody views technology as vital to advancing global climate change solutions, and the Company supports advanced coal technologies to drive continuous improvement toward the ultimate goal of net-zero emissions from coal.
+Added: Peabody views technology as vital to advancing solutions for a global reduction of GHG emissions, and the Company supports advanced coal technologies to align with the commitments of its customers and mitigate regulatory risk.
The Board has ultimate oversight for climate-related risk and opportunity assessments, and has delegated certain aspects of these assessments to subject matter committees of the Board.
5 unchanged sentences
Such risks may involve financial, policy, legal, technological, reputational and other impacts as the Company meets various mitigation and adaptation requirements.
−Removed: The transition to a net-zero emissions economy is driven by many factors, including, but not limited to, legislative and regulatory rulemaking processes, campaigns undertaken by non-governmental organizations to minimize or eliminate the use of coal as a source of electricity generation, and the policies of financial institutions and other private companies as related to safety, sustainability, human capital and governance practices.
+Added: The transition to a net-zero emissions economy is driven by many factors, including, but not limited to, legislative and regulatory rulemaking processes, campaigns undertaken by non-governmental organizations to minimize or eliminate the use of coal in steelmaking and as a source of electricity generation, and the policies of financial institutions and other private companies as related to safety, sustainability, human capital and governance practices.
The Company has experienced, or may in the future experience, negative effects on its results of operations due to the following specific risks as a result of such factors:
9 unchanged sentences
With respect to the potential or actual physical impacts of climate change, the Company has identified the following specific risks:
+Added: • Disruptions to production resulting from increased, adverse weather events;
• Disruption to water supplies vital to mining operations;
2 unchanged sentences
• Electrical grid failures and power outages.
+Added: Peabody Energy Corporation 2025 Form 10-K
While the Company faces numerous risks associated with the transition to a net-zero emissions economy and the physical impacts of climate change, certain opportunities may also emerge, such as:
2 unchanged sentences
• The relative expense and reliability of renewable energy sources compared to coal may encourage support for balanced-source energy policies and regulations.
−Removed: Peabody Energy Corporation 2024 Form 10-K
−Removed: Tab le of Contents
−Removed: Global climate issues continue to attract public and scientific attention.
−Removed: Numerous reports, such as the Sixth Assessment Report of the Intergovernmental Panel on Climate Change, have also engendered concern about the impacts of human activity, especially fossil fuel combustion, on global climate issues.
−Removed: In turn, increasing government attention has been paid to global climate issues and to GHG emissions, including emissions of carbon dioxide from coal combustion by power plants.
+Added: Public and scientific attention to climate issues, including findings in reports such as the Sixth Assessment Report of the Intergovernmental Panel on Climate Change, has increased scrutiny of GHG emissions, particularly CO 2 emissions from coal-fueled power generation.
+Added: In turn, increasing attention from governments has been paid to global climate issues and to GHG emissions, including emissions of CO 2 from coal combustion by power plants.
There have been significant developments in federal and state legislation and regulation and international accords regarding climate change, and volatility in the regulatory space is likely to continue.
Such developments are described below in the section “Regulations Related to Global Climate Change” within this Item 1.
−Removed: The enactment of future laws or the passage of regulations regarding emissions from the use of coal by the U.S., some of its states or other countries, and ongoing actions to limit such emissions, such as carbon taxes, could result in electricity generators switching from coal to other fuel sources.
−Removed: Further, policies limiting available financing for the development of new coal-fueled power stations could adversely impact the global demand for coal in the future.
−Removed: The potential financial impact on Peabody of such future laws, regulations or other policies will depend upon the degree to which any such laws or regulations force electricity generators to diminish their reliance on coal as a fuel source.
−Removed: That, in turn, will depend on a number of factors, including the specific requirements imposed by any such laws, regulations or other policies, the time periods over which those laws, regulations or other policies would be phased in, the state of development and deployment of CCUS technologies as well as acceptance of CCUS technologies to meet regulations and the alternative uses for coal.
−Removed: Higher-efficiency coal-fired power plants may also be an option for meeting laws or regulations related to emissions from coal use.
−Removed: Several countries, including major coal users such as China, India and Japan, included using higher-efficiency coal-fueled power plants in their plans under the Paris Agreement.
+Added: Future legislation or regulations, such as carbon taxes or other emissions-reduction measures, could prompt electricity generators to shift from coal to other fuel sources.
+Added: Policies that limit financing for the development of new coal-fueled power plants could adversely impact long-term global demand.
+Added: The potential financial impact of these developments on Peabody will depend upon the degree to which any such laws or regulations reduce coal use, which in turn will be influenced by the specific requirements of any new laws or regulations, the timing of their implementation, the development and acceptance of CCUS technologies, and the availability of alternative uses for coal.
+Added: Higher-efficiency coal-fired power plants may also be an option for meeting emissions-related requirements, and several major coal-using countries, including China, India and Japan, have incorporated such technologies into their plans under the Paris Agreement.
The Company believes HELE and CCUS technologies should be part of the solution to achieve substantial reductions in GHG emissions and should be broadly supported and encouraged, including through eligibility for public funding from national and international sources.
In addition, CCUS merits targeted deployment incentives, like those provided to other low-emission sources of energy.
−Removed: From time to time, the Company’s Board of Directors and management attempt to analyze the potential impact on the Company of as-yet-unadopted, potential laws, regulations and policies.
+Added: The Company’s Board of Directors and management periodically attempt to analyze the potential impact on the Company of as-yet-unadopted, potential laws, regulations and policies.
Such analyses require significant assumptions as to the specific provisions of such potential laws, regulations and policies which sometimes show that if implemented in the manner assumed by the analyses, the potential laws, regulations and policies could result in material adverse impacts on the Company’s operations, financial condition or cash flows.
−Removed: Such analyses cannot be relied upon to reasonably predict the quantitative impact that future laws, regulations or other policies may have on the Company’s results of operations, financial condition or cash flows.
+Added: Such analyses cannot be relied upon to reasonably predict the quantitative impact that future laws, regulations or other policies may have on the Company’s results of operations, financial condition or cash flows but aid in assessing the strength of current mitigations implemented by the Company and resilience to identified risks.
Regulations Related to Global Climate Change
In the U.S., Congress has considered legislation addressing global climate issues and GHG emissions, but to date, no new comprehensive, regulatory legislation has been signed into law.
−Removed: Congress, however, has approved legislation, the Inflation Reduction Act of 2022, that will provide substantial tax incentives, grants and loan guarantees for energy infrastructure, solar panels, wind turbines, nuclear and geothermal energy, hydrogen projects and carbon capture and storage.
+Added: Congress, however, approved legislation, the Inflation Reduction Act of 2022, that provided substantial tax incentives, grants and loan guarantees for energy infrastructure, solar panels, wind turbines, nuclear and geothermal energy, hydrogen projects and carbon capture and storage.
While it is possible that the U.S.
will adopt additional climate legislation in the future, the timing and specific requirements of any such legislation are uncertain.
−Removed: The EPA has also undertaken several steps to regulate GHG emissions under existing law, primarily the CAA.
−Removed: In response to the 2007 U.S.
−Removed: Supreme Court ruling in Massachusetts v.
−Removed: EPA , the EPA commenced several rulemaking projects as described under “Regulatory Matters - U.S.” The EPA has indicated that it will continue these efforts and proceed with new regulations affecting GHG emissions from fossil fuel-fired electric generation, methane emissions from oil and gas production and carbon emissions from light and heavy-duty vehicles.
−Removed: At the same time, a number of states in the U.S.
+Added: The EPA also undertook several steps to regulate GHG emissions under existing law, primarily the CAA.
+Added: These efforts and subsequent actions during 2025 affecting these measures are described under “Regulatory Matters - U.S.” A number of states in the U.S.
have adopted programs to regulate GHG emissions.
−Removed: For example, 10 northeastern states (Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island and Vermont) entered into the Regional Greenhouse Gas Initiative (RGGI) in 2005, and Pennsylvania joined in 2022.
+Added: For example, 10 northeastern states (Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island and Vermont) entered into the Regional Greenhouse Gas Initiative (RGGI) in 2005.
RGGI is a mandatory cap-and-trade program to cap regional carbon dioxide emissions from power plants.
5 unchanged sentences
Peabody Energy Corporation 2025 Form 10-K
−Removed: Tab le of Contents
−Removed: Increasingly, both foreign and domestic banks, insurance companies and large investors are curtailing or ending their financial relationships with fossil fuel-related companies.
+Added: In recent years, both foreign and domestic banks, insurance companies and large investors have curtailed or ended their financial relationships with fossil fuel-related companies.
This has had adverse impacts on the liquidity and operations of coal producers.
12 unchanged sentences
reentered the Paris Agreement by accepting the agreement and all of its articles and clauses, after having announced its withdrawal from the agreement in November 2019.
+Added: On January 20, 2025, U.S.
+Added: President Donald Trump announced the withdrawal of the U.S.
+Added: from the Paris Agreement.
+Added: On January 7, 2026, U.S.
+Added: President Donald Trump directed executive departments and agencies of the U.S.
+Added: government to withdraw from a number of international organizations, including the UNFCCC.
In June 2022, the new Australian federal government announced plans to legislate for a 43% reduction in Australia’s GHG emissions by 2030 and to introduce changes by mid-2023 that will require heavy emitting companies producing more than 100,000 tonnes of carbon emissions annually to accelerate their emissions reduction activities.
12 unchanged sentences
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.