5 unchanged sentences
Business and Industry Risks
−Removed: • Any decrease in adoption or sales of our eSignature product, without corresponding increases in our other solutions in our IAM platform.
−Removed: • Any inability to attract new customers and retain and expand sales to existing customers.
+Added: • Any decrease in adoption or sales of our eSignature product, without corresponding adoption or sales of our other solutions in our IAM platform.
• Our IAM platform failing to achieve market acceptance or to meet our customers’ evolving needs.
+Added: • Disruptions to our business, strategy and demand for our solutions due to advances in, and uses of, AI and other technologies.
+Added: • Any inability to deliver excellent service and support to customers, retain and expand sales to existing customers, and attract new customers.
+Added: • Damage to our systems, data, reputation, brand and customer trust due to data breaches, cyberattacks, malicious activity, or failures of our (or third party cloud providers’) technical infrastructure.
• Our inability to compete in an evolving and highly competitive market.
−Removed: • Our systems and security measures being compromised or subject to data breaches, cyberattacks, or other malicious activity, and any harm to our business or reputation caused by malicious actors attempting to exploit our technology, platform or brand to defraud others.
• Any real or perceived improper use of, disclosure of, or access to sensitive customer data.
• An over-estimation of our market opportunity.
−Removed: • Any interruption or delay in performance from our technical infrastructure, including third-party cloud providers.
−Removed: • The implementation of AI in our business, and the legal, regulatory, reputational and business risks relating to its use.
• Any loss of highly skilled personnel, including our management team or other key employees, or inability to attract, integrate and retain such employees necessary to support our business.
23 unchanged sentences
Business and Industry Risks
−Removed: We derive a majority of our revenue from our eSignature product, and slower or declining adoption or sales of our eSignature product, without corresponding increases in the use of our other products and solutions in our IAM platform, could cause our operating results to suffer.
−Removed: Sales of subscriptions to our eSignature product account for substantially all of our subscription revenue and are the source of substantially all of our professional services revenue.
+Added: We derive a majority of our revenue from our eSignature product, and slower or declining adoption or sales of our eSignature product, without corresponding adoption or sales of our other products and solutions in our IAM platform, could cause our operating results to suffer.
+Added: Sales of subscriptions to our eSignature product account for the substantial majority of our subscription and professional services revenue.
Although we continue to add to our suite of other products and solutions in our IAM platform for automating the agreement process, we expect that we will be substantially dependent on our eSignature product to generate revenue for the foreseeable future.
8 unchanged sentences
▪ our inability to release enhanced versions of our eSignature product on a timely basis;
−Removed: ▪ macro- and micro-economic factors, including inflation, changes in interest rates or foreign exchange rates, increased debt and equity market volatility, tariffs and trade policy changes, geopolitical conflict or public health crises.
+Added: ▪ macro- and micro-economic factors, including inflation, changes in interest rates or foreign exchange rates, increased debt and equity market volatility, tariffs and changes in trade policies and practices, geopolitical conflict or public health crises.
We have experienced, and may continue to experience, declines and fluctuations in the demand for our eSignature product due to a number of factors, including changing patterns of customer adoption and retention, shifts in customer spending levels, a highly competitive market, and general economic and global market conditions.
1 unchanged sentence
If customer adoption and expansion of our eSignature product falls below our expectations, our business, financial condition, and operating results would be adversely affected.
−Removed: If we are unable to attract new customers and retain and expand sales to existing customers, our revenue growth will be adversely affected.
−Removed: To increase our revenue, we must continue to grow our customer base.
−Removed: As our market matures, product and service offerings evolve, and competitors introduce lower cost and/or differentiated products or solutions that compete or are perceived to compete with our products and solutions, our ability to attract new customers could be impaired.
−Removed: This may be especially challenging where organizations have already invested significantly in an existing solution.
−Removed: If our pricing is not competitive or we cannot attract new customers and subsequently maintain and expand those customer relationships, our business and operating results may be harmed.
−Removed: Our ability to increase our revenue also depends on our ability to expand the sales of our products and solutions to, and renew subscriptions with, existing customers and their organizations.
−Removed: Our existing customers, especially our enterprise customers, must increase their use of our products and solutions by purchasing new products, additional subscriptions and our enhanced products and solutions.
−Removed: We may also, from time to time, invest in products and functionalities to diversify our sales and marketing strategy.
−Removed: If these or other efforts to attract new customers or expand sales to our existing customers are not successful, our business, operating results and financial condition may suffer.
−Removed: Moreover, a majority of our subscription contracts are for one year.
−Removed: Our customers have no obligation to renew their subscriptions and we cannot guarantee that our customers will renew their subscriptions with us for a similar or greater contract period or on the same or more favorable terms.
−Removed: Our renewal and expansion rates may decline or fluctuate as a result of a number of factors, including customer spending levels, customer dissatisfaction, decreases in the number of users with our customers, changes in the type and size of our customers, pricing, competitive conditions, customer
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 14
−Removed: attrition and general economic and global market conditions, including as a result of inflation, changes in interest rates, increased debt and equity market volatility, tariffs and trade policy changes, geopolitical conflicts or public health crises.
−Removed: If our customers do not renew their subscriptions for our products and solutions or if they reduce their subscription amounts at the time of renewal, our revenue will decline, and our business will suffer.
If our IAM platform, products and solutions do not evolve to meet the needs of our customers or fail to achieve sufficient market acceptance, our financial results and competitive position will suffer.
3 unchanged sentences
When we develop or acquire new or enhanced products and solutions, we typically incur expenses and expend resources upfront to develop, market, promote and sell them.
−Removed: For example, in April 2024, we launched our new IAM platform.
+Added: For example, in April 2024, we launched our IAM platform.
When we introduce new or enhanced products and solutions, they must achieve high levels of market acceptance to justify the amount of our investment in developing or acquiring them and bringing them to market.
5 unchanged sentences
▪ delays in releasing our products and solutions to the market;
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 15
▪ negative customer perception of our IAM platform or new products and solutions;
1 unchanged sentence
▪ introduction or anticipated introduction of competing products by our competitors.
−Removed: For example, we have made, and intend to continue making, significant investments in our platform and developing products that incorporate AI, and while we believe that these investments will drive future growth of our business, the development of such new features involves significant risks and costs, and there is no guarantee that any such offerings will ultimately be successful.
If the release of these or other new and enhanced products, solutions or functionalities as part of our platform do not meet customer needs or if our customers do not accept them, our business, operating results and financial condition would be harmed.
The adverse effect on our financial results may be particularly acute because of the significant research, development, marketing, sales and other expenses we will have incurred.
−Removed: The market in which we participate is evolving and highly competitive, which may negatively affect our ability to add new customers, retain existing customers and grow our business.
−Removed: Our products and solutions address a market that is evolving and highly competitive.
−Removed: We have customers in a wide variety of industries, including real estate, financial services, insurance, manufacturing, and healthcare and life sciences.
−Removed: We intend to continue to expand our sales efforts internationally, where many countries may have less familiarity with and acceptance of e-signature products.
−Removed: It is difficult to predict customer demand for our products and solutions, customer retention and expansion rates, the size and growth rate of the market for agreement automation, the entry of competitive products or the success of existing competitive products.
−Removed: We expect that we will continue to need intensive sales efforts to educate prospective customers, particularly enterprise and commercial customers and international customers, about the uses and benefits of our products and solutions.
−Removed: Additionally, we face competition from different companies depending on the product or solution.
−Removed: For example, our primary global e-signature competitor is currently Adobe Sign.
−Removed: We also face competition from a select number of vendors that focus on specific industries, geographies or product areas such as contract lifecycle management and advanced contract analytics.
−Removed: As we attempt to sell our products and solutions to new and existing customers, we must convince them that our products and solutions are superior to other solutions available to their organizations.
−Removed: Many of our competitors have longer operating histories than us, significantly greater financial, technical, marketing and other resources, stronger brand and customer recognition, larger intellectual property portfolios and broader global distribution.
−Removed: As a result, our competitors may be able to respond more quickly and effectively than we can to new or changing opportunities, technologies, standards or customer requirements.
−Removed: Our competitors may also offer lower pricing
+Added: Rapid and unpredictable advances in AI and other technologies could reduce demand for our solutions, disrupt our business and strategy, and cause competitive and financial harm.
+Added: While we believe recent technological advances complement Docusign’s strategy and will ultimately benefit our business, AI and other technological advances are unpredictable, and there can be no assurance that our strategy will succeed.
+Added: We may fail to predict or respond effectively to market demand for AI-powered solutions, or customer concerns regarding those solutions.
+Added: Even if we successfully create, market and sell AI-based offerings that meet customer demand, the costs of developing and operating such solutions (including initial training costs and ongoing processing and inference costs) may reduce profitability and adversely affect our results of operations.
+Added: Advances in AI have made and may continue to make some foundational capabilities for agreements (such as analyzing, summarizing and comparing text) cheaper and easier to replicate, enabling companies not previously focused on agreements to provide solutions that compete with some or all of ours.
+Added: In addition, advances in AI may significantly lower the cost of developing software, enabling companies to quickly and cheaply create agents or other homegrown alternatives that perform some or all of the functions they currently obtain from Docusign.
+Added: If providers of large language models, data platform companies, enterprise software companies, “hyperscalers,” or other businesses develop solutions that provide comparable functionality at lower cost or in more convenient formats, demand for our products would suffer and our business, financial condition and results of operations would be adversely affected.
+Added: If we are unable to deliver excellent service and support to customers, retain and expand sales to existing customers, and attract new customers, our revenue growth will be adversely affected.
+Added: Our ability to retain and grow our customer base depends on our ability to deliver excellent service and support to our customers.
+Added: Any failure to maintain high-quality customer support and meet or exceed customer expectations could adversely affect customer retention, growth, and our financial condition and results of operations.
+Added: To increase our revenue, we must continue to grow our customer base.
+Added: As our market matures, product and service offerings evolve, and competitors introduce lower cost and/or differentiated products or solutions that compete or are perceived to compete with our products and solutions, our ability to attract new customers could be impaired.
+Added: This may be especially challenging where organizations have already invested significantly in an existing solution.
+Added: If our pricing is not competitive or we cannot attract new customers and subsequently maintain and expand those customer relationships, our business and operating results may be harmed.
+Added: Our ability to increase our revenue also depends on our ability to expand the sales of our products and solutions to, and renew subscriptions with, existing customers and their organizations.
+Added: Our existing customers, especially our enterprise customers, must increase their use of our products and solutions by purchasing new products, additional subscriptions and our enhanced products and solutions.
+Added: We may also, from time to time, invest in products and functionalities to diversify our sales and marketing strategy.
+Added: If these or other efforts to attract new customers or expand sales to our existing customers are not successful, our business, operating results and financial condition may suffer.
+Added: Moreover, a majority of our subscription contracts are for one year.
+Added: Our customers have no obligation to renew their subscriptions and we cannot guarantee that our customers will renew their subscriptions with us for a similar or greater contract period or on the same or more favorable terms.
+Added: Our renewal and expansion rates may decline or fluctuate as a result of a number of factors, including customer spending levels, customer dissatisfaction, decreases in the number of users with our customers, changes in the type and size of our customers, pricing, competitive conditions, customer attrition and general economic and global market conditions, including as a result of inflation, changes in interest rates, increased debt and equity market volatility, tariffs and changes in trade policies and practices, geopolitical conflicts or public health crises.
+Added: If we are unable to improve our renewal rates, our revenue may decline and our business may suffer.
+Added: Furthermore, if our customers do not renew their subscriptions for our products and solutions or if they reduce
Docusign, Inc.
| 2026 Form 10-K | 16
−Removed: than we do or bundle certain competing products and services at a lower price.
−Removed: Further, we could lose customers if our competitors develop new competitive products and solutions, acquire competitive products, reduce prices, form strategic alliances with other companies, are acquired by third parties with greater resources or develop and market new technologies that render our existing or future products less competitive, unmarketable or obsolete.
−Removed: For example, disruptive technologies such as generative AI may fundamentally alter the market for our services in unpredictable ways and reduce customer demand.
−Removed: If we are unable to effectively compete, our business, operating results and financial condition would be harmed.
+Added: their subscription amounts at the time of renewal, our revenue will decline, and our business, operating results and financial condition will suffer.
Our systems and security measures have been, and may in the future be, compromised or subject to data breaches, cyberattacks, or other malicious activity, and third parties have attempted and may continue to attempt to exploit our platform or brand to defraud others, which could result in customers reducing or stopping their use of our products, our reputation being harmed, and significant liabilities and adverse effects on our operating results and financial condition.
4 unchanged sentences
Our ability to monitor our third-party service providers’ data security is limited and any breach of our providers’ security measures may result in unauthorized access to, or misuse, loss or destruction of, our and our customers’ data.
−Removed: While we have security measures in place designed to protect our production and development environments and other systems, maintain the integrity of customer, company, partner and employee information, and prevent data loss, misappropriation and other security breaches and incidents, we are a frequent target of cyberattacks and have faced security incidents in the past that did not have a material impact on our operations.
+Added: We also rely on other third parties, including open-source software providers, model-providers for AI features and others;
+Added: and vulnerabilities, misconfigurations, or supply chain compromises impacting any of these third parties could adversely impact our systems and data.
+Added: While we have security measures in place designed to protect our production and development environments and other systems, maintain the integrity of customer, company, partner and employee information, and prevent data loss, misappropriation and other security breaches and incidents, there can be no assurance that such security measures will be effective, or effective at all times.
+Added: We are a frequent target of cyberattacks and have faced security incidents in the past that did not have a material impact on our operations.
In these cases, upon detection, we took prompt action to prevent any additional unauthorized access, put further security controls in place and worked with law enforcement agencies, when appropriate.
−Removed: While we have taken and will continue to take steps to address cyberattacks and security incidents, these efforts may not always be entirely successful, and there can be no assurance that there will be no impact to our operations from these or similar incidents in the future.
+Added: While we have taken and will continue to take steps to address cyberattacks and security incidents, these efforts to investigate, mitigate, contain, and remediate any such incidents may not always be entirely successful, and there can be no assurance that there will be no impact to our operations from these or similar incidents in the future.
Despite our prevention and response efforts, any security incident or breach, even if immaterial and properly addressed, could result in negative publicity, loss of customers, damage to our reputation and could impair our sales and harm our business.
−Removed: Like other organizations providing valuable technology and services, we are subject to increasing cyberattacks from malicious third parties using widely varying and frequently changing tactics, including phishing and fraud campaigns targeting our personnel via email, text, instant messaging and voice calls.
−Removed: The frequency and sophistication of such threats continues to increase and often becomes further heightened in connection with geopolitical tensions.
−Removed: In addition, we face increased risk in our ability to maintain the performance, reliability, security and availability of our products and technical infrastructure to the satisfaction of our customers.
−Removed: Advances in technology and the increasing sophistication of attackers have led to more frequent and effective cyberattacks, including advanced persistent threats by state-sponsored actors, cyberattacks relying on complex social engineering or “phishing” tactics, ransomware attacks and other methods including credential stuffing and account takeover attacks, denial or degradation of service attacks, malicious code (e.g., viruses and worms), and many other techniques that may lead to the loss, theft or misuse of personal, corporate or financial information, fraudulent payments and identity theft.
−Removed: Bad actors, nation-states, and nation-state-supported actors now engage, and are expected to continue to engage, in cyberattacks, including for geopolitical reasons and in connection with global or regional conflicts and operations.
−Removed: During major global or regional conflicts, we and our partners, service providers, or customers may be vulnerable to heightened risk of such cyberattacks.
+Added: Like other organizations providing valuable technology and services, we are subject to increasing cyberattacks from malicious third parties using widely varying and frequently changing tactics, which may be enhanced or facilitated by AI technology, and may include phishing and fraud campaigns targeting our personnel via email, text, instant messaging and voice calls.
+Added: As AI technologies develop rapidly, threat actors are using these technologies to create new attack methods that are increasingly automated, targeted, and coordinated and more difficult to defend against.
+Added: In addition, we may face increased risk in our ability to maintain the performance, reliability, security and availability of our products and technical infrastructure to the satisfaction of our customers.
+Added: We are subject to increasingly frequent and sophisticated cyberattacks, including advanced persistent threats by state-sponsored actors, cyberattacks relying on complex social engineering or “phishing” tactics, ransomware attacks and other methods including credential stuffing and account takeover attacks, prompt injection, deepfakes, denial or degradation of service attacks, malicious code (e.g., viruses and worms), and many other techniques that may lead to the loss, theft or misuse of personal, corporate or financial information, fraudulent payments, identity theft, and disrupting or disabling our services.
+Added: Bad actors, nation-states, and nation-state-supported actors engage in cyberattacks, including for geopolitical reasons and in connection with global or regional conflicts and operations.
+Added: The frequency and sophistication of cybersecurity threats against us and our partners, service providers or customers may often become further heightened in connection with such geopolitical tensions.
If bad actors gain improper access to our systems or databases or those of our partners, service providers, and other third parties who have access to our data, they may be able to steal, publish, delete, copy, unlawfully or fraudulently use or modify data, including personal information and/or blackmail us to pay a ransom.
1 unchanged sentence
If our efforts to prevent these activities, or limit their impact, are unsuccessful, our reputation and brand could be harmed, we could lose customers, and our business and financial condition could be adversely affected.
−Removed: If our security measures, or the security measures of our partners, service providers, or customers, are compromised, our reputation could be damaged, our ability to attract and retain customers could be adversely affected, we could be
Docusign, Inc.
| 2026 Form 10-K | 17
−Removed: subject to negative publicity, increased costs to remedy any problems and otherwise respond to any incident, monetary and other losses for us or our customers, identity theft for our customers, the inability to expand our business, additional scrutiny, restrictions, fines or penalties from regulatory or governmental authorities, loss of customers and customer confidence in our services, ongoing regulatory oversight, assessments and audits, exposure to civil litigation, and/or a breach of our contracts with third parties, all of which could expose us to significant liability and harm our business, financial condition, and operating results.
+Added: If our security measures, or the security measures of our partners, service providers, or customers, are compromised, our reputation could be damaged and our ability to attract and retain customers could be adversely affected.
+Added: We could also be subject to negative publicity, increased costs to remedy any problems and otherwise respond to any incident, monetary and other losses for us or our customers, identity theft for our customers, the inability to expand our business, additional scrutiny, restrictions, fines or penalties from regulatory or governmental authorities, loss of customers and customer confidence in our services, ongoing regulatory oversight, assessments and audits, exposure to civil litigation, and/or a breach of our contracts with third parties.
+Added: All of the foregoing could expose us to significant liability and harm our business, financial condition, and operating results.
Despite significant efforts to identify vulnerabilities and create security barriers to such threats, it is virtually impossible for us, our service providers, our partners and our customers to entirely mitigate these risks.
−Removed: Further, we could be forced to expend significant financial and operational resources in response to a cyberattack or security incident or breach, including repairing system damage, increasing security protection costs, investigating and remediating any information security vulnerabilities, complying with data breach notification obligations and applicable laws, and defending against and resolving legal and regulatory claims, all of which could divert resources and the attention of our management and key personnel away from our business operations and materially and adversely affect our business, financial condition, and operating results.
+Added: Further, we could be forced to use significant financial and operational resources in response to a cyberattack, security incident, or breach, including repairing system damage, increasing security protection costs, investigating and remediating any information security vulnerabilities, complying with data breach notification obligations and applicable laws, and defending against and resolving legal and regulatory claims, all of which could divert resources and the attention of our management and key personnel away from our business operations and materially and adversely affect our business, financial condition, and operating results.
Additionally, there can be no assurance that any limitations of liability provisions in our contracts would be enforceable or adequate in the event of a security breach or would otherwise protect us from any such liabilities or damages with respect to any particular claim.
We also cannot be sure that our existing general liability insurance coverage, cybersecurity coverage, and coverage for errors or omissions will continue to be available on acceptable terms or will be available in sufficient amounts to cover one or more large claims, or that insurers will not deny coverage as to any future claim.
+Added: Furthermore, our insurance coverage may not extend to all risks we face, including all AI-related security risks, and may not cover us for all losses for errors or omissions caused by AI.
Cyberattacks or security incidents may result in increased costs for such insurance as well.
One or more large, successful claims against us in excess of our available insurance coverage, or changes in our insurance policies, including premium increases or large deductible or coinsurance requirements, could have an adverse effect on our business, operating results and financial condition.
−Removed: We obtain and process a large amount of sensitive customer data.
+Added: The market in which we participate is evolving and highly competitive, which may negatively affect our ability to add new customers, retain existing customers and grow our business.
+Added: Our products and solutions address a market that is evolving and highly competitive.
+Added: We have customers in a wide variety of industries, including real estate, financial services, insurance, manufacturing, and healthcare and life sciences.
+Added: We intend to continue to expand our sales efforts internationally, where many countries may have less familiarity with and acceptance of e-signature products.
+Added: It is difficult to predict customer demand for our products and solutions, customer retention and expansion rates, the size and growth rate of the market for agreement automation, the entry of competitive products or the success of existing competitive products.
+Added: We expect that we will continue to need intensive sales efforts to educate prospective customers, particularly enterprise and commercial customers and international customers, about the uses and benefits of our products and solutions.
+Added: Additionally, we face competition from different companies depending on the product or solution.
+Added: For example, our primary global e-signature competitor is currently Adobe Acrobat Sign.
+Added: We also face competition from a select number of vendors that focus on specific industries, geographies or product areas such as contract lifecycle management and advanced contract analytics.
+Added: We may also face greater competition from non-specialist solutions relying on generic large language models (“LLMs”), generative AI and general-purpose agents to address a broad range of business needs.
+Added: As we attempt to sell our products and solutions to new and existing customers, we must convince them that our products and solutions are superior to other solutions available to their organizations, including generic LLMs, software created using natural language prompts and generative AI (referred to as vibe coding) and other emerging technologies.
+Added: Many of our competitors have longer operating histories than us, significantly greater financial, technical, marketing and other resources, stronger brand and customer recognition, larger intellectual property portfolios and broader global distribution.
+Added: As a result, our competitors may be able to respond more quickly and effectively than we can to new or changing opportunities, technologies, standards or customer requirements.
+Added: Our competitors may also offer lower pricing than we do or bundle certain competing products and services at a lower price.
+Added: Further, we could lose customers if our competitors develop new competitive products and solutions, acquire competitive products, reduce prices, form strategic alliances with other companies, are acquired by third parties with greater resources or develop and market new technologies that render our existing or future products less competitive, unmarketable or obsolete.
+Added: For example, advances in AI and other technologies may fundamentally alter the market for our services in unpredictable ways and reduce customer demand.
+Added: If we are unable to effectively compete, our business, operating results and financial condition would be harmed.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 18
+Added: We collect, store, and process a large amount of customer, employee, partner, and service provider data, including sensitive data.
Any actual or perceived improper use of, disclosure of, or access to such data could harm our reputation, as well as have an adverse effect on our business.
−Removed: We receive, store and process personal information and other data from and about our customers, employees, partners and service providers.
+Added: We collect, store and process personal information and other data from and about our customers, employees, partners and service providers.
In addition, customers use our products and solutions to obtain and store personal information, health information (including protected health information) and personal financial information.
6 unchanged sentences
Although we endeavor to comply with our policies and documentation, we may at times fail to do so or be accused of having failed to do so.
−Removed: The publication of our privacy notices and other related documentation that provide commitments about data privacy and security can subject us to potential actions if they are found to be non-compliant, deceptive, unfair, or otherwise misrepresent our actual practices, which could materially and adversely affect our business, financial condition and results of operations, and subject us to investigations, fines or penalties from regulators or government authorities, or civil litigation.
+Added: Increased regulatory focus on “dark patterns,” data minimization and transparency, along with heightened scrutiny of any statements related to the use of AI, all increase the risk of allegations that our notices and related documentation may be alleged to be non-compliant, deceptive, unfair or otherwise inaccurate.
+Added: The publication of our privacy notices and other related documentation that provide commitments about data privacy and security can subject us to potential claims and enforcement actions if they are found to be non-compliant, deceptive, unfair, or otherwise misrepresent our actual practices.
+Added: These could materially and adversely affect our business, financial condition and results of operations, and subject us to investigations, fines or penalties from regulators or government authorities, or civil litigation.
We are subject to various evolving laws and regulations governing our use of our business data.
For more information on these laws and regulations, see the risk factors “ We are subject to laws and regulations affecting our business, including those related to e-signature, marketing, advertising, privacy, data protection and information security.
−Removed: Our actual or perceived failure to comply with laws or regulations could harm our business.” and “Complying with laws and regulations, in particular those related to privacy and data protection, could also result in additional costs and liabilities to us or inhibit sales of our software.
+Added: Our actual or perceived failure to comply with laws or regulations could harm our business.” and “Complying with laws and regulations related to privacy and data protection could result in additional costs and liabilities to us or inhibit sales of our software.
” If we are not able to comply with these laws or regulations or if we become liable under these evolving laws or regulations, we could be directly harmed, and we may be forced to implement new measures to reduce our exposure to this liability.
2 unchanged sentences
Any costs incurred as a result of this potential liability could harm our business and operating results.
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 17
Additionally, any failure or perceived failure by us to comply with laws, regulations, policies, legal or contractual obligations, industry standards, or regulatory guidance relating to privacy or data security, may result in governmental investigations and enforcement actions, litigation, fines and penalties or adverse publicity, and could cause our customers and partners to lose trust in us, which could have an adverse effect on our reputation and business.
10 unchanged sentences
In some cases, third-party cloud providers run their own platforms that we access, and we are, therefore, vulnerable to their service interruptions.
−Removed: As a result, we depend, in part, on our providers’ ability to protect our service supply chain against damage or interruption, including from natural disasters, regional or global conflicts, power or telecommunications failures, criminal acts and similar events.
+Added: As a result, we depend, in part, on our providers’ ability to protect our service supply chain
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 19
+Added: against damage or interruption, including from natural disasters, regional or global conflicts, power or telecommunications failures, criminal acts and similar events.
+Added: In some instances, we may not be able to identify the cause or causes of these performance problems immediately, and it could take considerable time for such problems to become pronounced enough for us to detect or for our customers to detect and inform us.
In the event that our data center and service arrangements are terminated, or if there are any lapses of service or damage to a data center, we could experience lengthy interruptions in our service as well as delays and additional expenses in arranging new facilities and services.
7 unchanged sentences
We use AI in our business, and challenges with properly governing its use could result in reputational harm, competitive harm, and legal liability, and adversely affect our results of operations.
−Removed: We use AI-powered tools and services as part of operating our business, and also incorporate AI features and applications into our products and solutions and are making further investments in expanding AI capabilities in our products and solutions.
+Added: We use AI-powered tools and services as part of operating our business, and we also incorporate AI features and applications into our products and solutions.
+Added: We are also making further investments in expanding AI capabilities in our products and solutions.
AI technologies can be complex and are rapidly evolving, and while we believe that product features powered by next generation AI technologies, such as generative AI, will help drive the future growth of our business, there is no guarantee that such new product features will ultimately be successful.
−Removed: Our competitors and other third parties may incorporate AI into their products more quickly or more successfully than us, all of which could impair our ability to compete effectively and may adversely affect our results of operations.
−Removed: This use of AI in our products and solutions may present new and evolving challenges, including reputational harm, competitive harm, and legal liability, and adversely affect our results of operations.
−Removed: Additionally, AI technology may lower barriers to entry in our industry and we may be unable to effectively compete with the products or services offered by new competitors.
−Removed: AI-related changes to the products and services on offer may affect our customers’ expectations or requirements in ways we cannot adequately anticipate or adapt to, causing our business to lose sales, market share, or the ability to operate profitably and sustainably.
+Added: Our competitors and other third parties may incorporate AI into their products more quickly or more successfully than us, which could impair our ability to compete effectively.
+Added: Furthermore, we are increasingly developing and deploying agentic AI workflows and autonomous agents designed to perform tasks and make decisions with limited human intervention.
+Added: These agentic systems may act in ways that are unpredictable, exceed their intended authorization, or fail to align with our corporate policies or legal obligations.
+Added: Errors, “hallucinations,” or unintended actions taken by these agents—especially in customer-facing or operationally critical environments—could lead to significant financial loss, data breaches, contractual breaches, or regulatory non-compliance.
+Added: Furthermore, we may face allegations of “AI washing” if our disclosures about our AI capabilities or our AI-related governance are deemed to be exaggerated or misleading, which could result in enforcement actions, litigation or reputational harm.
+Added: The development and use of AI present various intellectual property, data privacy, and security risks.
+Added: Significant investment in the development and maintenance of proprietary datasets and training models and the development of appropriate protections, safeguards, and policies for handling the processing of data, including transparency of customer data extraction and usage in training models may be costly and may subject us to legal liability.
+Added: Additionally, the agentic AI systems described above may inadvertently access or disclose sensitive information beyond their intended scope or be subject to “prompt injection” and other cyberattacks that could cause the agents to take unauthorized or harmful actions.
+Added: Any integration of third-party AI functionality with our products and solutions relies on safeguards implemented by the third-party developers of the underlying AI models, including those related to the accuracy, bias, and other variables of the data, and these safeguards may be insufficient.
+Added: The continued use of AI technology to develop our products and solutions may give rise to risks related to intellectual property infringement.
+Added: If the AI technology we use generates code or materials that are similar to other proprietary code or materials, or to software that is protected by patents, we could be subject to intellectual property infringement claims.
+Added: We may also not be able to anticipate and detect security vulnerabilities in such AI-generated software code, including those that could be induced by a maliciously trained AI model.
+Added: To the extent we use third-party AI technology to develop software code, the terms of use of these tools may reserve rights in the generated code.
+Added: We could also suffer loss of confidentiality, trade secret rights or other intellectual property rights or cause harm to privacy rights of third parties because of our use of AI technology.
+Added: Existing laws and regulations may be interpreted, or new laws and regulations regarding AI have been and may in the future be adopted and interpreted, in ways which could negatively affect the way we use AI in our products.
Docusign, Inc.
| 2026 Form 10-K | 20
−Removed: The development and use of AI features and applications present various intellectual property, data privacy, security and reliability risks that may impact our business.
−Removed: We may choose to significantly invest in the development and maintenance of proprietary datasets and training models and the development of appropriate protections, safeguards, and policies for handling the processing of data, including transparency of customer data extraction and usage in training models, with our AI features and applications, which may be costly and subject us to legal liability.
−Removed: Furthermore, any integration of third-party AI models with our products and solutions relies on certain safeguards implemented by the third-party developers of the underlying AI models, including those related to the accuracy, bias, and other variables of the data, and these safeguards may be insufficient.
−Removed: These risks could negatively impact our business, financial condition, and results of operations.
−Removed: Existing laws and regulations may be interpreted, or new laws and regulations regarding AI have been and may in the future be adopted and interpreted, in ways which could negatively affect the way we use AI in our products.
−Removed: For example, the EU Artificial Intelligence Act prohibits certain AI applications and systems with unacceptable risk and imposes additional requirements on the use of other high-risk or limited-risk AI applications or systems, which may require the implementation of additional quality assurance controls and measures to be reviewed and approved by regulatory submissions of our products.
+Added: example, the EU Artificial Intelligence Act prohibits certain AI applications and systems with unacceptable risk and imposes additional requirements on the use of other high-risk or limited-risk AI applications or systems, which may require the implementation of additional quality assurance controls and measures to be reviewed and approved by regulatory submissions of our products.
+Added: In the U.S., ongoing tension between the states and the federal government over how best to regulate AI may result in increased uncertainty, risk and compliance costs for our business.
Intellectual property ownership issues, licensing and privacy rights surrounding AI technologies are evolving and have not been fully addressed by U.S.
federal or state courts or foreign jurisdictions, which may expose us to claims of intellectual property infringement or misappropriation or privacy rights violations, or result in inquiries by government bodies or agencies.
−Removed: For example, the U.S.
−Removed: Federal Trade Commission initiated multiple AI-related inquiries over the past several years and sent requests to technology companies, including Docusign, seeking additional information about their AI usage and policies.
−Removed: The rapid evolution of AI technologies will require significant resources in research and development in order to develop, test and maintain our platform and products to minimize any potential harmful impact on our business, financial condition, and results of operations.
−Removed: The continued use in our business and incorporation of AI-powered features and applications into our products and solutions may subject us to new and evolving regulatory scrutiny, litigation, social or ethical concerns, unforeseen operational failures, potential for biased or incorrect outputs, or other risks that could harm our business, reputation, brand, and our results of operations.
−Removed: For example, if the content, analyses, or recommendations arising from our AI product offerings are, or are alleged to be, inaccurate, deficient, offensive, or biased, or if they have a perceived or actual negative impact on human rights, privacy rights, employment, or in other social contexts, we may experience brand and reputational harm or legal liability, and our business, financial condition, and results of operations may be adversely affected.
−Removed: Additionally, the significant technical complexity of AI technology will require specialized expertise and may increase compensation-related expenses.
−Removed: Competition for specialized personnel in the AI industry is intense, and failing to attract, integrate, or retain such specialized expertise in AI could adversely affect our business and results of operations.
−Removed: There is also the possibility that the AI models we develop may not perform as expected when deployed, which could hinder our product offerings, impact our competitiveness in the market, or lead to financial losses.
+Added: A number of jurisdictions, including many U.S.
+Added: states such as California and Colorado, have proposed or enacted laws regarding automated decision‑making, algorithmic discrimination and so called “high‑risk” AI technologies (mandating, among other provisions, requirements for risk management, impact assessments, consumer notices and human oversight), which may impact our use of AI and AI-powered tools.
+Added: If the content, analyses, or recommendations arising from our AI product offerings are, or are alleged to be, inaccurate, deficient, offensive, or biased, or if they have a perceived or actual negative impact on human rights, privacy rights, employment, or in other social contexts, we may experience brand and reputational harm or legal liability, and our business, financial condition, and results of operations may be adversely affected.
+Added: The significant technical complexity of AI technology also requires specialized expertise and may increase compensation-related expenses.
+Added: Competition for specialized personnel in the AI industry is intense, and failing to attract, integrate, or retain such expertise could adversely affect our business.
+Added: Finally, the AI models we develop may not perform as expected when deployed, which could lead to financial losses or harm our competitive position.
+Added: Any of the foregoing risks could adversely affect our business, financial condition, and results of operations.
We rely on the performance of highly skilled personnel, including our management and other key employees, and failing to attract, integrate, or retain such employees could harm our business.
1 unchanged sentence
Changes in our management team resulting from the hiring or departure of executives and key employees from time to time could disrupt our business.
−Removed: In the last 12 months, there have been significant changes to our senior leadership team.
−Removed: For example, in August 2024, Steve Shute, our President, Worldwide Field Operations, departed the Company and Paula Hansen was appointed as our President, Chief Revenue Officer.
−Removed: These changes and any future significant leadership changes or senior management transitions involve inherent risk.
+Added: Any future significant leadership changes or senior management transitions involve inherent risk.
In addition, executive leadership transition periods can be disruptive and may result in a loss of personnel with deep institutional or technical knowledge, or result in changes to business strategy or objectives, and may negatively impact our operations and relationships with employees and customers due to increased or unanticipated expenses, operational inefficiencies, uncertainty regarding changes in strategy, decreased employee morale and productivity, and increased turnover.
2 unchanged sentences
Our senior management and key employees are employed on an at-will basis, meaning that we may terminate their employment at any time, with or without cause, and they may resign at any time, with or without cause.
−Removed: If we lose one or more of our senior management or other key employees and are unable to find adequate replacements, or if we fail to attract, integrate,
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 19
−Removed: retain and motivate members of our senior management team and key employees or otherwise fail to retain a significant portion of our workforce, our business could be harmed.
+Added: If we lose one or more of our senior management or other key employees and are unable to find adequate replacements, or if we fail to attract, integrate, retain and motivate members of our senior management team and key employees or otherwise fail to retain a significant portion of our workforce, our business could be harmed.
We also are dependent on the continued service of our existing software engineers because of the complexity of our products and solutions.
8 unchanged sentences
Our sales to government entities and highly regulated organizations are subject to a number of challenges and risks.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 21
We sell to U.S.
−Removed: federal, state and local, as well as foreign, government agencies and public sector customers, as well as to customers in highly regulated industries such as financial services, pharmaceuticals, insurance, healthcare and life sciences.
+Added: federal, state and local, as well as non-U.S.
+Added: government agencies, public sector customers, and state-owned enterprises, and to customers in highly regulated industries such as financial services, pharmaceuticals, insurance, healthcare and life sciences.
Sales to such entities are subject to a number of challenges and risks, including those related to our status as a service provider to U.S.
−Removed: state and federal governmental agencies.
+Added: local, state and federal governmental agencies.
Selling to such entities can be highly competitive, expensive and time-consuming, often requiring significant upfront time and expense to meet unique compliance requirements, some of which may be statutory or regulatory, without any assurance that these efforts will generate a sale.
These longer sale cycles make the timing of future revenue from these entities difficult to predict.
−Removed: Further, government compliance requirements may change, restricting our ability to sell into the government sector until we have met those revised requirements.
−Removed: For example, recently proposed executive orders in the U.S.
−Removed: may impose new limits or restrictions on federal contractors, and noncompliance with such limits or restrictions could impact our business with government entities.
−Removed: Failure to meet government contract compliance obligations can also create the risk of statutory penalties as well as standard breach of contract risk.
−Removed: Government demand and payment for our offerings are affected by public sector budgetary cycles and funding authorizations, and funding reductions or delays, including as a result of macro-economic factors, including inflation, changes in interest rates, government shutdowns or reductions in the government workforce, geopolitical conflicts and public health crises, may adversely affect public sector demand for our products and solutions.
−Removed: We sell to public sector customers primarily through third-party resellers and distributors, who contract directly with government customers and are subject to complex laws, regulations and contractual requirements applicable to government contractors.
+Added: Further, government compliance requirements may change, restricting our ability to sell into the government sector until we have met those updated requirements.
+Added: For example, executive orders and regulations may impose new compliance obligations or restrictions on federal contractors, and noncompliance with such limits or restrictions could impact our business with government entities.
+Added: Any actual or perceived failure to meet government contract compliance obligations may also create the risk of statutory penalties as well as standard breach of contract risk.
+Added: Government demand and payment for our offerings are affected by public sector budgetary cycles and funding authorizations, changes in government buying patterns, and funding reductions or delays, including as a result of macro-economic factors, including inflation, changes in interest rates, government shutdowns, or reductions in the government workforce, geopolitical conflicts and public health crises, which may adversely affect public sector demand for our products and solutions.
+Added: We sell to public sector customers primarily through third-party resellers and distributors, who contract directly with government customers and are subject to complex laws, executive orders, regulations and contractual requirements applicable to government contractors, including Federal Acquisition Regulations, and the Defense Federal Acquisition Regulations in the U.S.
+Added: and public procurement, anti-corruption, trade and competition laws.
If our third-party resellers and distributors fail to comply with these obligations, are suspended, debarred, or otherwise lose the ability to sell to public sector customers, our public sector sales and growth prospects could suffer and our operating results could be adversely affected.
−Removed: In addition, both government agencies and entities in highly regulated industries may demand shorter subscription periods or other contract terms that differ from our standard arrangements, including terms that can lead those customers to obtain broader rights in our offerings than would be standard.
−Removed: Such agencies and entities may have statutory, contractual or other legal rights to terminate contracts with us or our partners due to a default or for other reasons, and any such termination may adversely affect our business, operating results and financial condition.
+Added: In addition, both government agencies and entities in highly regulated industries may demand shorter subscription periods or other contract terms that differ from our standard arrangements, including terms that can lead those customers to seek broader rights in our offerings than would be standard.
+Added: Such agencies and entities may have statutory, contractual or other legal rights to terminate contracts with us or our partners due to a default or for convenience, and any such termination may adversely affect our business, operating results and financial condition.
If we are unable to maintain successful relationships with our partners, our business, operating results and financial condition could be harmed.
In addition to our direct sales force and our website, we use strategic partners, such as global system integrators, value-added resellers and independent software vendors, to sell our subscription offerings and solutions.
−Removed: Our agreements with our partners are generally nonexclusive, meaning our partners may offer their customers products and services of several different companies, including products and services that compete with ours, or may themselves be or become competitors.
+Added: Our agreements with our partners are generally nonexclusive, meaning our partners may offer their customers products and services of several different companies, including products and services that compete with ours, or may themselves become competitors.
If our partners do not effectively market and sell our subscription offerings and solutions, choose to use greater efforts to market and sell their own products and services or those of our competitors, or fail to meet the needs of our customers, our ability to grow our business and sell our subscription offerings and solutions may be harmed.
+Added: Furthermore, our partner relationships and customer demand may be impacted by inflation and interest rate changes, policy changes and other global financial, economic, political, and health events.
Our partners may cease marketing our subscription offerings or solutions with limited or no notice and with little or no penalty.
−Removed: In addition, acquisitions of our partners by our competitors could result in a decrease in the number of our current and potential customers, as our partners may no longer facilitate the adoption of our products and solutions by
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 20
−Removed: potential customers.
+Added: In addition, acquisitions of our partners by our competitors could result in a decrease in the number of our current and potential customers, as our partners may no longer facilitate the adoption of our products and solutions by potential customers.
The loss of a substantial number of our partners, our possible inability to replace them or the failure to recruit additional partners could harm our growth objectives and operating results.
2 unchanged sentences
Failure to establish and maintain relationships with partners that can provide complementary technology offerings and software integrations could limit our ability to grow our business.
−Removed: Our products and solutions seamlessly integrate with hundreds of other software applications, including Google, Microsoft, Workday, Salesforce, SAP, and ServiceNow.
−Removed: Our growth strategy includes expanding the use of our products and solutions through complementary technology offerings and software integrations, such as third-party APIs.
+Added: Our products and solutions seamlessly integrate with hundreds of other software applications, including Salesforce, Microsoft, SAP, Google, ServiceNow, and Workday.
+Added: Our growth strategy includes expanding the use of our products and
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 22
+Added: solutions through complementary technology offerings and software integrations, such as third-party APIs.
While we have established partnerships with providers of complementary offerings and software integrations, we cannot guarantee that we will be successful in continuing to maintain and scale these partnerships or establishing partnerships with additional providers as we grow.
3 unchanged sentences
alter the terms governing use of and access to their applications and APIs;
−Removed: or implement other changes that could functionally limit or terminate our ability to use these third-party technology offerings and software integrations with our platform, any of which could negatively impact our offerings and harm our business.
+Added: implement other changes that could functionally limit or terminate our ability to use these third-party technology offerings and software integrations with our platform;
+Added: or themselves become competitors, any of which could negatively impact our offerings and harm our business.
We have in the past, and may in the future, engage in acquisition and investment activities, which could divert the attention of management, disrupt our business, dilute stockholder value and adversely affect our operating results and financial condition.
18 unchanged sentences
Our ability to increase our customer base and achieve broader market acceptance of our products and solutions depends to a significant extent on our ability to expand our marketing and sales operations.
−Removed: We continue to make
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 21
−Removed: investments in our sales force and strategic partnerships, including expansion and training, both domestically and internationally.
+Added: We continue to make investments in our sales force and strategic partnerships, including expansion and training, both domestically and internationally.
We also dedicate significant resources to our sales and marketing efforts by investing in advertising campaigns on a variety of media platforms, including online and social media.
2 unchanged sentences
We may need to reduce or change our pricing model to remain competitive.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 23
Different pricing structures apply to our Docusign product offerings.
24 unchanged sentences
We have from time to time found defects in our products and solutions and may discover additional defects in the future that could result in data unavailability or unauthorized access or other harm to, or loss or corruption of, our customers’ data.
−Removed: While we implement
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 22
−Removed: bug fixes and upgrades as part of our regularly scheduled system maintenance, we may not be able to reasonably anticipate and correct defects or errors before implementing our products and solutions.
+Added: While we implement bug fixes and upgrades as part of our regularly scheduled system maintenance, we may not be able to reasonably anticipate and correct defects or errors before implementing our products and solutions.
Consequently, we or our customers may discover defects or errors after our products and solutions have been employed.
2 unchanged sentences
The costs incurred in addressing and correcting any material defects or errors in our software and expanding our infrastructure and architecture in order to accommodate increased demand for our products and solutions may be substantial and could adversely affect our operating results.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 24
If we fail to promote or maintain our brand, our ability to expand our customer base will be impaired and our financial condition may suffer.
5 unchanged sentences
If we fail to successfully promote and maintain our brand, we may fail to attract enough new customers or retain our existing customers to the extent necessary to realize a sufficient return on our brand-building efforts, and our business could suffer.
−Removed: Further, we have also made public commitments to our corporate environmental, social, and governance (“ESG”) and human capital management initiatives, including to the recruitment of a diverse workforce and reductions in carbon emissions.
+Added: Further, we have also made public commitments to our corporate environmental, social, and governance (“ESG”) and human capital management initiatives, including reductions in carbon emissions and fostering a culture that celebrates and harnesses the strength of our people.
Any perceived changes in our dedication to these commitments or our failure to achieve progress in these areas on a timely basis, or at all, could adversely impact our relationships with our customers and employees and affect our reputation and the value of our brand.
10 unchanged sentences
In addition to the other risks described herein, factors that may affect our operating results or cause our financial results to fluctuate include the following:
−Removed: ▪ general economic, market and industry conditions, including as a result of inflation, changes in interest rates or foreign exchange rates, increased debt and equity market volatility, tariffs and trade policy changes, geopolitical conflict or public health crises;
+Added: ▪ general economic, market and industry conditions, including as a result of inflation, changes in interest rates or foreign exchange rates, increased debt and equity market volatility, tariffs and changes in trade policies and practices, geopolitical conflict or public health crises;
▪ fluctuations in demand for, or pricing of, our products and solutions, including due to the effects of global macro-economic conditions, and differing levels of demand for our products as our customers’ priorities, resources, financial conditions and economic outlook change;
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 23
▪ our ability to attract new customers;
▪ our ability to renew our subscriptions with, and expand sales of our products and solutions to, our existing customers;
−Removed: ▪ timing of revenue recognition;
+Added: ▪ timing of sales and revenue recognition;
▪ customer delays in purchasing decisions in anticipation of new products or product enhancements by us or our competitors;
1 unchanged sentence
▪ the timing and success of new product and service introductions by us or our competitors or any other change in the competitive dynamics of our industry, including consolidation or new entrants among competitors, customers, or strategic partners ;
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 25
▪ our ability to control costs, including our operating expenses, and related impact to our operating margin;
7 unchanged sentences
▪ the impact of new accounting pronouncements;
−Removed: ▪ changes in laws and regulations that affect our business, including trade policy changes;
+Added: ▪ changes in laws and regulations that affect our business, including changes in trade policies and practices;
▪ significant security breaches of, technical difficulties with, or interruptions to, the delivery and use of our products and solutions;
7 unchanged sentences
This is particularly true of CLM and our other advanced offerings, where longer evaluation, testing and qualification processes often result in longer sales cycles than for our eSignature product, and may also affect sales cycles for our IAM solutions as we market them to a growing number of potential customers.
−Removed: The timing of our sales with our enterprise customers and related revenue recognition is difficult to predict because of the length and unpredictability of the sales cycle for these customers.
+Added: The timing of our sales with our enterprise customers, and related effects on revenue recognition and ARR, is difficult to predict because of the length and unpredictability of the sales cycle for these customers.
During the sales cycle, we expend significant time and money on sales and marketing and contract negotiation activities, which may not result in a sale.
9 unchanged sentences
▪ the competitive market for our products and services;
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 24
▪ evolving customer demands.
3 unchanged sentences
Consequently, a shortfall in demand for our products and solutions and professional services or a decline in new or renewed contracts in any one quarter may not significantly reduce our revenue for that quarter but could negatively affect our revenue in future quarters.
−Removed: Our revenue recognition model also makes it difficult for us to rapidly increase our revenue through additional sales contracts in any period, as revenue from new customers is recognized over the applicable term of their contracts.
+Added: Our revenue recognition model also
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 26
+Added: makes it difficult for us to rapidly increase our revenue through additional sales contracts in any period, as revenue from new customers is recognized over the applicable term of their contracts.
If we fail to forecast our revenue accurately, or if we fail to match our expenditures with corresponding revenue, our operating results could be adversely affected.
15 unchanged sentences
▪ greater difficulty collecting accounts receivable and longer payment cycles;
−Removed: ▪ potential changes in trade relations arising from U.S.
+Added: ▪ potential changes in trade relations or business practices or preferences as a result of U.S.
policy initiatives;
10 unchanged sentences
▪ regional or global conflicts, including sanctions or other laws and regulations prohibiting or limiting operations in certain jurisdictions;
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 25
▪ political instability or terrorist activities;
7 unchanged sentences
▪ exposure to regional or global public health issues, and to travel restrictions and other measures undertaken by governments in response to such issues.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 27
Our limited experience in operating our business internationally increases the risk that any potential future expansion efforts that we undertake may not be successful.
16 unchanged sentences
We fund our operations through payments by our customers for use of our product offerings and related services.
−Removed: In addition, as of January 31, 2025, we had available borrowing capacity of $500.0 million under our credit facility.
−Removed: We cannot be certain when or if our operations will generate sufficient cash to fund our ongoing operations or the growth of our business.
+Added: Our capital resources also include a secured revolving credit facility of up to $750.0 million , which may be increased by an additional $250.0 million subject to the terms of the credit agreement.
Based upon our current operating plan, we believe that our existing cash, cash equivalents and investments are sufficient to fund our current operating expenses and capital expenditure requ irements based on historical forecasts.
4 unchanged sentences
Additional financing may not be available on favorable terms, if at all.
−Removed: In addition, in the event that we incur
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 26
−Removed: additional debt, including under the credit facility, the debt holders would have rights senior to holders of common stock to make claims on our assets.
+Added: In addition, in the event that we incur additional debt, including under the credit facility, the debt holders would have rights senior to holders of common stock to make claims on our assets.
Additionally, the credit facility restricts our ability to pay dividends on common stock and the terms of any future debt could restrict our operations.
2 unchanged sentences
Our ability to use our net operating loss carryforwards to offset future taxable income may be subject to certain limitations.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 28
As of January 31, 2026, we had accumulated net operating loss carryforwards and research tax credits in our federal, state and foreign jurisdictions with varying expiration dates.
3 unchanged sentences
If our estimates or judgments relating to our critical accounting policies prove to be incorrect, our operating results could be adversely affected.
−Removed: The preparation of financial statements in conformity with U.S.
−Removed: generally accepted accounting principles (“GAAP”) requires management to make estimates and assumptions that affect the amounts reported in our consolidated financial statements and accompanying notes.
+Added: The preparation of financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the amounts reported in our consolidated financial statements and accompanying notes.
We base our estimates on historical experience and on various other assumptions that we believe to be reasonable under the circumstances, as provided in the section titled “Management’s Discussion and Analysis of Financial Condition and Results of Operations.” Our operating results may be adversely affected if our assumptions change or if actual circumstances differ from those in our assumptions, which could cause our operating results to fall below the expectations of securities analysts and investors, resulting in a decline in the trading price of our common stock.
9 unchanged sentences
We have not engaged in the hedging of foreign currency transactions to date, so we may not be able to effectively offset the adverse financial impacts that may result from unfavorable movements in foreign currency exchange rates, which could adversely affect our operating results.
−Removed: We could be required to collect additional sales taxes or be subject to other tax liabilities that may increase the costs our clients would have to pay for our offering and adversely affect our operating results.
+Added: We could be required to collect additional sales taxes or other indirect taxes or be subject to other tax liabilities that may increase the costs our clients would have to pay for our offering and adversely affect our operating results.
A successful assertion by one or more states or foreign jurisdictions requiring us to collect taxes where we presently do not do so, or to collect more taxes in a jurisdiction in which we currently do collect some taxes, could result in substantial tax liabilities, including taxes on past sales, as well as penalties and interest.
−Removed: Any imposition by state or local governments or other jurisdictions of sales tax collection obligations on out-of-state or -jurisdiction sellers could also create additional administrative burdens for us, put us at a competitive disadvantage if they do not impose similar obligations on our competitors and decrease our future sales, which could have a material adverse impact on our business and operating results.
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 27
+Added: Any imposition by state or local governments or other jurisdictions of sales tax or other indirect tax collection obligations on out-of-jurisdiction sellers could also create additional administrative burdens for us, put us at a competitive disadvantage if they do not impose similar obligations on our competitors and decrease our future sales, which could have a material adverse impact on our business and operating results.
Legal and Regulatory Risks
2 unchanged sentences
federal government and various state and foreign governments have adopted or proposed limitations on the collection, distribution, use and storage of data relating to individuals and businesses, including the use of contact information and other data for marketing, advertising and other communications with individuals and businesses.
−Removed: In the U.S., various laws, and regulations and agency rules and opinions apply to the collection, processing, disclosure and security of certain types of data, including:
−Removed: ▪ The ESIGN Act in the U.S., eIDAS in the EU and similar U.S.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 29
+Added: U.S., various laws, and regulations and agency rules and opinions apply to the collection, processing, disclosure and security of certain types of data, including:
+Added: ▪ The ESIGN Act in the U.S.
+Added: and similar U.S.
state laws, particularly the Uniform Electronic Transactions Act (the “UETA”), which authorize the creation of legally binding and enforceable agreements utilizing electronic signatures and records.
1 unchanged sentence
for use of electronic signatures and records by providing that electronic signatures and records carry the same weight and have the same legal effect as paper documents and wet ink signatures.
+Added: ▪ The EU’s eIDAS, and ongoing regulatory and standards developments, including eIDAS 2.0 amendments, which may impose additional requirements on trust services and qualified providers in the EU.
▪ The Electronic Communications Privacy Act, the Computer Fraud and Abuse Act, the Gramm Leach Bliley Act, and state laws relating to privacy and data security.
+Added: Amendments to state cybersecurity regulations, such as updates to financial services cybersecurity requirements in New York State and elsewhere may further increase our compliance burdens.
▪ Additionally, the FTC and many U.S.
10 unchanged sentences
For example, the SEC has adopted cybersecurity risk management and disclosure rules, which require mandatory disclosure of information pertaining to cybersecurity incidents and cybersecurity risk management, strategy and governance.
−Removed: In March 2024, the SEC also adopted (but subsequently stayed the implementation of) amendments that would require us to disclose certain climate-related information in our annual reports beginning with our annual report covering fiscal year ended January 31, 2026.
+Added: In March 2024, the SEC also adopted (but subsequently stayed the implementation of) amendments that would require public companies to disclose certain climate-related information in our annual reports beginning with our annual report covering fiscal year ended January 31, 2026.
Additionally, California recently adopted the Climate Corporate Data Accountability Act and the Climate-Related Financial Risk Act, each of which mandate certain climate-related public disclosure requirements (although there are proposals to stay such requirements until 2028).
−Removed: We expect that new laws, regulations and industry standards will continue to be proposed and enacted relating to privacy, data protection, marketing, advertising, electronic signatures, consumer communications and information security in the U.S., the EU and other jurisdictions, and we cannot determine the impact such future laws, regulations and standards may have on our business.
+Added: We expect that new laws, regulations and industry standards will evolve, and new laws, including novel forms of digital regulation, will continue to be proposed and enacted relating to privacy, data protection, marketing, advertising, electronic signatures, consumer communications and information security in the U.S., the EU and other jurisdictions, and we cannot determine the impact this may have on our business.
Future laws, regulations, standards and other obligations or any changed interpretation of existing laws or regulations could impair our ability to develop and market new functionality and maintain and grow our customer base and increase revenue.
−Removed: For example, changes in the regulatory landscape relating to new and evolving technologies, such as generative AI, and future restrictions on the collection, use, sharing or disclosure of data, or additional requirements for the express or implied consent of our customers, partners or end consumers for the use and disclosure of such information could require us to incur additional costs or modify our products and solutions, possibly in a material manner, and could limit our ability to develop new functionality.
+Added: For example, changes in the regulatory landscape relating to new and evolving technologies, such as advances in AI technologies, and future restrictions on the collection, use, sharing or disclosure of data, or additional requirements for the express or implied consent of our customers, partners or end consumers for the use and disclosure of such information could require us to incur additional costs or modify our products and solutions, possibly in a material manner, and could limit our ability to develop new functionality.
Any actual or perceived failure to comply with these or other laws or regulations could harm our business, and result in legal liability, regulatory action, or brand and reputational harm.
+Added: Complying with laws and regulations related to privacy and data protection could result in additional costs and liabilities to us or inhibit sales of our software.
+Added: A wide variety of state, national, and international laws, regulations, and industry standards apply to the collection, use, retention, protection, disclosure, transfer and other processing of personal data and other information, the scope of which are consistently changing, subject to differing interpretations, and may be inconsistent across countries or conflict
Docusign, Inc.
| 2026 Form 10-K | 30
−Removed: Complying with laws and regulations related to privacy and data protection could result in additional costs and liabilities to us or inhibit sales of our software.
−Removed: A wide variety of state, national, and international laws, regulations, and industry standards apply to the collection, use, retention, protection, disclosure, transfer and other processing of personal data and other information, the scope of which are consistently changing, subject to differing interpretations, and may be inconsistent across countries or conflict with other rules.
+Added: with other rules.
Data protection and privacy-related laws and regulations are evolving and may result in increasing regulatory and public scrutiny and escalating levels of enforcement and sanctions.
2 unchanged sentences
Our actual or perceived failure to comply with laws or regulations could harm our business.
−Removed: Internationally, virtually every jurisdiction in which we operate has established its own data privacy and security legal framework with which we, our customers and partners may need to comply.
−Removed: For example, in Europe, the General Data Protection Regulation (the “EU GDPR”) contains robust obligations on data controllers and processors and fulsome documentation requirements for data protection compliance programs by companies.
−Removed: As a result of our presence in Europe and the United Kingdom (“UK”) and our products and services being offered in the EU and the UK, we are subject to the EU GDPR and other similar regional European data privacy and protection regulations (collectively the “GDPR”), all of which impose stringent data protection and cybersecurity requirements, and could increase the risk of non-compliance and the costs of providing our services in a compliant manner.
−Removed: We are also certified as a Privacy Rights Processor under the Asia-Pacific Economic Cooperation.
−Removed: A breach of the GDPR, or other such data protection regulations, could result in regulatory investigations, reputational damage, fines and sanctions, orders to cease or change our processing of our data, enforcement notices, or assessment notices (for a compulsory audit).
+Added: Internationally, virtually every jurisdiction in which we operate has established its own privacy and data security legal framework, which may include compliance requirements for us, our customers and partners.
+Added: For example, in Europe, the General Data Protection Regulation (the “EU GDPR”) contains robust obligations on data controllers and processors and fulsome documentation requirements for corporate data protection compliance programs.
+Added: Our obligations under the EU GDPR and other similar regional European data privacy and protection regulations (collectively the “GDPR”) include stringent data protection and cybersecurity requirements, making it more costly to provide our services in a compliant manner and increasing our risk in the event of non-compliance.
+Added: We are also certified under the Asia-Pacific Economic Cooperation Cross-Border Privacy Rules System and the APEC Privacy Recognition for Processors System.
+Added: A breach of these or other data protection regulations could result in regulatory investigations, reputational damage, fines and sanctions, orders to cease or change our processing of data, enforcement notices, or assessment notices (for a compulsory audit).
Such penalties, which under GDPR may include fines up to the greater of €20 million (£17.5 million) or 4% of global turnover, are in addition to any civil litigation claims by customers and data subjects.
We may also face civil claims including representative actions and other class action-type litigation (where individuals have suffered harm), potentially amounting to significant compensation or damages liabilities, as well as associated costs, diversion of internal resources, and reputational harm.
−Removed: Additionally, the GDPR imposes strict rules on the transfer of personal data out of the EU or the UK to any country whose laws have not been deemed by regulators in the EU or UK to ensure an “adequate” level of data protection safeguards (such as the U.S.).
+Added: Additionally, the GDPR imposes strict rules on the transfer of personal data out of the EU or the UK to any country whose laws have not been deemed by regulators in the EU or UK to ensure an “adequate” level of data protection safeguards (such as the U.S.), and requires appropriate transfer mechanisms and, in some cases, transfer impact assessments and supplementary measures.
These obligations may evolve, be interpreted or applied in a manner that is inconsistent from one jurisdiction to another and may conflict with other requirements or our practices.
−Removed: For example, in June 2023, the European Commission adopted an adequacy decision (“UK Adequacy Decision”) which facilitates personal data sharing from the European Economic Area (“EEA”) to the UK without the need for additional data protection safeguards.
−Removed: The UK Adequacy Decision includes a “sunset clause”, rendering the decision valid for four years, after which it will be reviewed by the European Commission and renewed only if the European Commission considers that the UK continues to ensure an adequate level of data protection.
−Removed: The European Commission also stated that it would intervene at any point within the four years if the UK deviates from the level of protection presently in place.
−Removed: If this adequacy decision is reversed by the European Commission, it would require that companies implement protection measures such as the approved Standard Contractual Clauses for data transfers between the EU and the UK.
−Removed: Legal developments in Europe continue to evolve, creating complexity and uncertainty regarding transfers of personal data from the EU and the UK to the U.S.
−Removed: We currently utilize respective Binding Corporate Rules and Standard Contractual Clauses as the approved data transfer mechanisms by the EU Commission for corresponding applicable data transfer activity.
+Added: Legal developments in Europe, including the EU Data Act, continue to evolve, creating complexity and uncertainty regarding transfers of personal data from the EU and the UK to the U.S.
+Added: We currently utilize a combination of Binding Corporate Rules and Standard Contractual Clauses as the approved data transfer mechanisms by the EU Commission for corresponding applicable data transfer activity.
While we do not anticipate any immediate changes in our current operations, we will continue to monitor these legal developments.
+Added: As supervisory authorities continue to issue further guidance on the cross-border transfers of personal data, we could incur greater costs and be required to modify the manner or location in which we operate.
We have been and may in the future be subject to legal proceedings and litigation for a variety of claims, including labor and employment issues, intellectual property disputes, securities law violations, derivative litigation and other matters, which may be costly and may subject us to significant liability and increased costs of doing business.
3 unchanged sentences
In particular, companies in the software industry are often required to defend against litigation claims based on allegations of infringement or other violations of intellectual property rights.
−Removed: We have from time to time been
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 29
−Removed: subject to intellectual property claims and disputes and may be subject to such claims in the future.
+Added: We have from time to time been subject to intellectual property claims and disputes and may be subject to such claims in the future.
In addition, many of these companies have the capability to dedicate substantially greater resources to enforce their alleged intellectual property rights and to defend claims that may be brought against them.
2 unchanged sentences
Any inability to license third-party technology in the future would have an adverse effect on our business or operating results and would adversely affect our ability to compete.
−Removed: Such disputes may require us to redesign our products, delay releases, enter into costly settlement or license agreements, pay costly damage awards, or face a temporary or permanent injunction prohibiting us from marketing or selling our products and solutions.
+Added: Such disputes may require us to redesign our products, delay releases, enter into costly settlement or license agreements, pay costly damage awards, or face a temporary or permanent injunction prohibiting us from marketing or
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 31
+Added: selling our products and solutions.
Requiring us to change one or more aspects of the way we deliver our products and solutions may harm our business.
12 unchanged sentences
While we have been issued patents in the U.S.
−Removed: and other countries and have additional patent applications pending, we may be unable to obtain patent protection for the technology covered in our patent applications.
+Added: and other countries and have additional patent applications pending, we may be unable to obtain patent protection for the technology covered in our patent applications and such patents may no longer provide us with competitive advantages.
In addition, any patents issued in the future may not provide us with competitive advantages or may be successfully challenged by third parties.
1 unchanged sentence
There can be no guarantee that others will not independently develop similar products, duplicate any of our products or design around our patents.
−Removed: Furthermore, legal standards relating to the validity, enforceability and scope of protection of intellectual property rights are uncertain.
Despite our precautions, it may be possible for unauthorized third parties to copy our products or aspects of our platform and use information that we regard as proprietary to create products and solutions that compete with ours.
8 unchanged sentences
Litigation brought to protect and enforce our intellectual property rights could be costly, time consuming and distracting to management and could result in the impairment or loss of portions of our intellectual property.
−Removed: Furthermore, our efforts to enforce our intellectual property rights may be
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 30
−Removed: met with defenses, counterclaims and countersuits attacking the validity and enforceability of our intellectual property rights.
+Added: Furthermore, our efforts to enforce our intellectual property rights may be met with defenses, counterclaims and countersuits attacking the validity and enforceability of our intellectual property rights.
Our inability to protect our proprietary technology against unauthorized copying or use, as well as any costly litigation or diversion of our management’s attention and resources, could delay further sales or the implementation of our products and solutions, impair the functionality of our products and solutions, delay introductions of new solutions, result in our substituting inferior or more costly technologies into our products and solutions or injure our reputation.
Moreover, there could be public announcements of the results of hearings, motions or other interim proceedings or developments, and if securities analysts or investors perceive these results to be negative, it could have a substantial adverse effect on the price of our common stock.
+Added: Furthermore, legal standards relating to the validity, enforceability and scope of protection of intellectual property rights are uncertain and any changes in, or unexpected interpretations of, intellectual property laws may compromise our ability to enforce our intellectual property rights.
+Added: Any of our intellectual property rights may be successfully challenged, opposed, diluted, misappropriated or circumvented by others or
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 32
+Added: invalidated, narrowed in scope or held unenforceable through administrative process or litigation.
Any of these results could adversely affect our business, operating results and financial condition.
We will not be able to protect our intellectual property if we are unable to enforce our rights or if we do not detect unauthorized use of our intellectual property.
+Added: Intellectual property protection may not be available to us in every country in which our products and services are available, or may be limited in some countries.
Moreover, policing unauthorized use of our technologies, trade secrets and intellectual property may be difficult, expensive and time-consuming, particularly in foreign countries where the laws may not be as protective of intellectual property rights as those in the U.S.
and where mechanisms for enforcement of intellectual property rights may be less effective.
+Added: For example, some foreign countries have compulsory licensing laws under which a patent owner must grant licenses to third parties.
+Added: In addition, many countries limit the enforceability of patents against certain third parties, including government agencies or government contractors.
+Added: In these countries, patents may provide limited or no benefit.
If we fail to adequately protect our intellectual property and proprietary rights, our business, operating results and financial condition could be adversely affected.
4 unchanged sentences
If a court or regulatory body determines that our products and solutions are inadequate to meet these requirements, documents executed through our products and solutions could, in some instances, be rendered unenforceable, resulting in potential loss of customers, liability under customer contracts, and brand and reputational damage.
+Added: Additionally, changes to qualified electronic signature standards and emerging AI and digital identity governance frameworks could necessitate product modifications or recertifications, and any delay or failure to obtain or maintain such authorizations could adversely affect our ability to serve certain customers and markets.
We use open source software in our products, which could subject us to litigation or other actions.
8 unchanged sentences
This would allow our competitors to create similar offerings with lower development effort and time and ultimately could result in a loss of sales for us.
−Removed: If we inappropriately use or incorporate open source software subject to certain types of open source licenses that challenge the proprietary nature of our software products, we may be required to re-engineer our products, discontinue the sale of our products and solutions or take other remedial actions that may divert resources away from our development efforts.
+Added: If we inappropriately use or incorporate open source software subject to certain types of open source licenses that challenge the proprietary nature of our software products, we may be required to re-engineer our products, discontinue the sale of our products and solutions or take other remedial actions that may divert resources away from or delay our development efforts.
Indemnity provisions in various agreements potentially expose us to substantial liability for intellectual property infringement, data protection and other losses.
3 unchanged sentences
Although we normally contractually limit our liability with respect to such obligations, such limitations may not be enforceable in all jurisdictions, and we may still incur substantial liability related to them and we may be required to cease use of certain functions of our products and solutions as a result of any such claims.
−Removed: In addition, our customer agreements generally include a warranty that the proper use of Docusign by a customer in accordance with
+Added: In addition, our
Docusign, Inc.
| 2026 Form 10-K | 33
−Removed: the agreement and applicable law will be sufficient to meet the definition of an “electronic signature” as defined in the Electronic Signatures in Global and National Commerce Act (“ESIGN Act”) and eIDAS.
+Added: customer agreements generally include a warranty that the proper use of Docusign by a customer in accordance with the agreement and applicable law will be sufficient to meet the definition of an “electronic signature” as defined in the Electronic Signatures in Global and National Commerce Act (“ESIGN Act”) and eIDAS.
Any warranty or indemnification claim brought by our customers could result in damage to our reputation and harm our business and operating results.
Changes in tax laws, rulings and interpretations may subject us to potential adverse tax consequences, which could negatively affect our financial position and results of operations.
−Removed: We operate globally and are subject to taxes in the U.S.
−Removed: and numerous other jurisdictions throughout the world, and the tax regimes we are subject to or operate under, including income and non-income taxes, are unsettled and may be subject to significant change.
−Removed: The U.S., other jurisdictions or governmental bodies, such as the European Commission of the European Union, and intergovernmental economic organizations, such as the Organization for Economic Cooperation and Development, have made or could make unprecedented assertions about how taxation is determined and, in some cases, have proposed or enacted new laws that are contrary to the way in which rules or regulations have historically been interpreted and applied.
−Removed: For example, in 2021, the Organization for Economic Cooperation and Development announced Pillar Two Model Rules defining the global minimum tax, which calls for the taxation of large multinational corporations at a minimum of 15%.
−Removed: Many non-U.S.
−Removed: tax jurisdictions have either recently enacted legislation to adopt certain components of the Pillar Two Model Rules beginning in 2024, including the adoption of additional components in later years, or announced their plans to enact legislation in future years.
−Removed: Our effective tax rate could increase in future years as a result of these changes, which could have an adverse impact on our business and operating results.
−Removed: Additionally, our corporate structure and associated transfer pricing policies contemplate future growth into international markets, and consider the functions, risks and assets of the various entities involved in the intercompany transactions.
−Removed: We may be subject to taxation in international jurisdictions with increasingly complex tax laws and precedents which could have an adverse effect on our liquidity and operating results.
−Removed: The amount of taxes we pay in these different jurisdictions may depend on the application of the tax laws of those jurisdictions, including the U.S., to our international business activities, changes in tax rates, new or revised tax laws or interpretations of existing tax laws and policies and our ability to operate our business in a manner consistent with our corporate structure and intercompany arrangements.
−Removed: Furthermore, tax authorities in the jurisdictions in which we operate may challenge our transfer pricing policies and intercompany arrangements or disagree with our determinations as to the income and expenses attributable to specific jurisdictions.
−Removed: If such a challenge or disagreement were to occur, and our position was not sustained, we could be required to pay additional taxes, interest and penalties, which could result in one-time tax charges, higher effective tax rates, reduced cash flows and lower overall profitability of our operations.
−Removed: Our financial statements could fail to reflect adequate reserves to cover such a contingency.
−Removed: In addition, the authorities in these jurisdictions could review our tax returns and impose additional tax, interest and penalties, and the authorities could claim that various withholding requirements apply to us or to our subsidiaries or assert that benefits of tax treaties are not available to us or our subsidiaries which could have a material impact on us and the results of our operations.
+Added: We are a U.S.-based multinational company subject to tax in multiple U.S.
+Added: and foreign tax jurisdictions.
+Added: Significant judgment is required in determining our global provision for income taxes, deferred taxes and other tax liabilities and receivables, and in evaluating our tax positions and other tax attributes on a worldwide basis.
+Added: We are subject to the periodic examination of our domestic and foreign tax returns by the Internal Revenue Service, state, local, and foreign tax authorities, some of whom are challenging our tax positions.
+Added: We regularly assess the likelihood of adverse outcomes from these examinations in determining the adequacy of our provision for income taxes and other tax liabilities and have reserved for potential adjustments that may result from these examinations.
+Added: While we believe our tax estimates are reasonable, the ultimate outcome may differ from the amounts recorded in our financial statements and could materially affect our financial results in the period or periods for which such determination is made.
+Added: We consider many factors when evaluating and estimating our tax positions and tax benefits, which may require periodic adjustments and may not accurately forecast actual tax audit outcomes.
+Added: If the ultimate determination of income and other tax liabilities differ from the amounts recorded or accrued, our business, financial condition or results of operations may be adversely impacted.
+Added: Changes in tax laws or tax rulings, or changes in interpretations of existing laws, could materially affect our financial position, results of operations, and cash flows.
+Added: Tax laws are regularly being re-examined and evaluated globally.
+Added: New laws and interpretations of the law are taken into account for financial statement purposes in the quarter or year that they become applicable.
+Added: Tax authorities are increasingly scrutinizing the tax positions and transfer pricing of companies and we are (and may continue to be) subject to tax audits in a number of jurisdictions.
+Added: Over the last several years, the Organization for Economic Cooperation and Development (“OECD”) has been working on a Base Erosion and Profit Shifting Project that, if implemented, would change various aspects of the existing framework under which our tax obligations are determined in many of the countries in which we do business.
+Added: A number of countries have enacted legislation to implement the OECD’s 15% global minimum tax regime.
+Added: As additional jurisdictions enact legislation, transitional relief expires, and other provisions of the minimum tax legislation become effective, our effective tax rate and cash tax payments could increase in future years.
The requirements of being a public company, including developing and maintaining proper and effective disclosure controls and procedures and internal control over financial reporting, may strain our resources and divert management’s attention away from other business concerns.
5 unchanged sentences
To assist us in complying with these requirements we may need to hire more employees in the future, or engage outside consultants, which will increase our operating expenses.
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 32
Despite significant investment, our current controls and any new controls that we develop may become inadequate because of changes in business conditions.
Any failure to implement and maintain effective internal control over financial reporting could adversely affect the results of periodic management evaluations and annual independent registered public accounting firm attestation reports regarding the effectiveness of our internal control over financial reporting that are required to be included in the periodic reports that we file with the SEC.
−Removed: If our management team or independent registered public accounting firm were to furnish an adverse report, or if it is determined that we have a material weakness or significant deficiency in our internal control over financial reporting, investors could lose confidence in the accuracy and completeness of our financial reports, the market price of our common stock could decline, and we could be subject to sanctions or investigations by Nasdaq, the SEC or other regulatory authorities or shareholder litigation.
−Removed: In addition, as we continue to scale and improve our operations, including our internal systems and processes, we currently utilize, and in the future may seek to implement, a variety of critical systems, such as billing, human resource, financial reporting and accounting systems.
+Added: If our management team or
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 34
+Added: independent registered public accounting firm were to furnish an adverse report, or if it is determined that we have a material weakness or significant deficiency in our internal control over financial reporting, investors could lose confidence in the accuracy and completeness of our financial reports, the market price of our common stock could decline, and we could be subject to sanctions or investigations by Nasdaq, the SEC or other regulatory authorities or shareholder litigation.
+Added: In addition, as we continue to scale and improve our operations, including our internal systems and processes, we currently utilize, and in the future may seek to implement, a variety of critical systems, such as billing, human resources, financial reporting and accounting systems.
The implementation and transition to any new critical system may be disruptive to our business if they do not work as planned or if we experience issues related to such implementation or transition, which could have a material adverse effect on our operations and result in compromised internal reporting and processes.
4 unchanged sentences
These encryption products and the underlying technology may be exported outside of the U.S.
−Removed: only with export authorizations, including by license, a license exception or other appropriate government authorizations, including the filing of an encryption registration.
+Added: to most jurisdictions only with export authorizations, including by license, a license exception or other appropriate government authorizations.
Furthermore, our activities are subject to U.S.
−Removed: economic sanctions laws and regulations that prohibit the shipment or distribution of certain products and services without the required export authorizations, including to countries, governments and persons targeted by U.S.
−Removed: embargoes or sanctions.
−Removed: Obtaining the necessary export license or other authorization for a particular sale may be time-consuming and may result in the delay or loss of sales opportunities even if the export license ultimately may be granted.
−Removed: Additionally, sanctions regimes are rapidly changing as a result of regional or global conflicts.
−Removed: While we take precautions to prevent our products and solutions from being exported in violation of these laws, including obtaining export authorizations, implementing IP address blocking and screenings against U.S.
+Added: economic sanctions laws and regulations that prohibit dealings without the required authorizations with countries, governments and parties targeted by U.S.
+Added: government may not grant us the required authorization for a particular sale.
+Added: Even if the required authorization for a particular sale is ultimately granted, it may be time-consuming and may result in the delay or loss of sales opportunities.
+Added: While we take precautions to prevent business dealings in violation of these laws, including obtaining government authorizations, implementing IP address blocking and screenings against U.S.
government and international lists of restricted and prohibited persons, we cannot guarantee that the precautions we take will prevent violations of export control and sanctions laws.
1 unchanged sentence
sanctions or export control laws can result in significant fines or penalties and possible incarceration for responsible employees and managers could be imposed for criminal violations of these laws.
−Removed: In addition, if our strategic partners fail to obtain appropriate import, export or re-export licenses or permits, we may also be adversely affected, through reputational harm as well as other negative consequences including government investigations and penalties.
−Removed: We presently incorporate export control compliance requirements to our strategic partner agreements;
+Added: In addition, if our strategic partners fail to adhere to U.S.
+Added: sanctions and export control laws, we may also be adversely affected, through reputational harm as well as other negative consequences including government investigations and penalties.
+Added: We presently incorporate export control compliance requirements into our strategic partner agreements;
however, no assurance can be given that our strategic partners will comply with such requirements.
−Removed: Foreign governments also regulate the import and export of certain encryption and other technology, including import and export licensing requirements, and have enacted, and may in the future enact, sanctions and export control laws that could limit our ability to distribute our products and solutions or could limit our end-customers’ ability to implement our products and solutions in those countries.
−Removed: Changes in our products and solutions or future changes in export and import regulations may create delays in the introduction of our products and solutions in international markets, prevent our end-customers with international operations from deploying our products and solutions globally or, in some cases, prevent the export or import of our products and solutions to certain countries, governments or persons altogether.
−Removed: From time to time, various governmental agencies have proposed additional regulation of encryption technology, including the escrow and government recovery of private encryption keys .
−Removed: Any change in export or import regulations, economic sanctions or related legislation, increased export and import controls or change in the countries, governments, persons or technologies targeted by such regulations, could result in decreased use of our products and solutions by, or in our decreased ability to export or sell our products and solutions to, existing or potential end-customers with international operations.
+Added: Foreign governments also regulate the import and export of certain encryption and other technology, and have implemented, and may in the future implement, sanctions and export control laws that could limit our ability to distribute our products and solutions or could limit our end-customers’ ability to implement our products and solutions in those countries.
+Added: Changes in our products and solutions or future changes in export and import regulations may create delays in the introduction of our products and solutions in international markets, prevent our end-customers with international operations from deploying our products and solutions globally or, in some cases, prevent the export or import of our products and solutions to certain countries, governments or parties altogether.
Any decreased use of our products and solutions or limitation on our ability to export or sell our products and solutions would adversely affect our business, operating results and prospects.
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 33
We are subject to anti-corruption, anti-bribe ry, anti-money laundering, and similar laws, and non-compliance with such laws can subject us to criminal and/or civil liability and harm our business.
7 unchanged sentences
We can be held liable for the corrupt or other illegal activities of these third-party intermediaries and our employees, representatives, contractors, partners, and agents, even if we do not explicitly authorize such activities.
−Removed: While we have policies and procedures to address compliance with such laws, we cannot assure you that our employees and agents will not take actions in violation of our policies and applicable law, for which we may be ultimately held responsible.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 35
+Added: While we have policies and controls to address compliance with such laws, we cannot assure you that our employees and agents will not take actions in violation of our policies and applicable law, for which we may be ultimately held responsible.
As we increase our international sales and business, our risks under these laws may increase.
1 unchanged sentence
In addition, noncompliance with anti-corruption, anti-bribery, or anti-money laundering laws could subject us to whistleblower complaints, investigations, sanctions, settlements, prosecution, other enforcement actions, disgorgement of profits, significant fines, damages, other civil and criminal penalties or injunctions, suspension and/or debarment from contracting with certain persons, the loss of export privileges, reputational har m, adverse media coverage and other collateral consequences.
−Removed: If any subpoenas or investigations are launched, or governmental or other sanctions are imposed, or if we do not prevail in any possible civil or criminal litigation, our business, operating results and financial condition could be materially harmed.
+Added: If any subpoenas or investigations are launched, or governmental or other sanctions are imposed, or if we do not prevail in any relevant civil or criminal litigation, our business, operating results and financial condition could be materially harmed.
In addition, responding to any action will likely result in a materially significant diversion of management’s attention and resources and significant defense costs and other professional fees.
20 unchanged sentences
▪ changes in the anticipated future size and growth rate of our market;
−Removed: ▪ changes in the political climate in the U.S.;
+Added: ▪ changes and uncertainty in the political climate in the U.S.;
▪ terrorist attacks, natural disasters and the effects of climate change, regional and global conflicts, sanctions, laws and regulations that prohibit or limit operations in certain jurisdictions, public health crises or other such events impacting countries where we have operations.
1 unchanged sentence
In the past, companies that have experienced volatility in the market price of their securities have been subject to securities class action litigation.
−Removed: We have been, and may in the future be, subject to this type of litigation, which could result in substantial costs, divert our management’s
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 34
−Removed: attention from our business and adversely affect our business.
+Added: We have been, and may in the future be, subject to this type of litigation, which could result in substantial costs, divert our management’s attention from our business and adversely affect our business.
For more information on our pending legal proceedings, see Item 3.
3 unchanged sentences
Our amended and restated certificate of incorporation and amended and restated bylaws include provisions that:
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 36
▪ authorize our board of directors to issue, without further action by the stockholders, shares of undesignated preferred stock with terms, rights and preferences determined by our board of directors that may be senior to our common stock;
20 unchanged sentences
On March 18, 2020, however, the Delaware Supreme Court reversed the decision of the Delaware Chancery Court and held that such provisions are facially valid.
−Removed: In light of that recent decision, we announced that we may in the future enforce our Federal
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 35
−Removed: Forum Provision.
+Added: In light of that recent decision, we announced that we may in the future enforce our Federal Forum Provision.
While there can be no assurance that federal courts or other state courts will follow the holding of the Delaware Supreme Court or determine that the Federal Forum Provision should be enforced in a particular case, application of the Federal Forum Provision generally means that suits brought by our stockholders to enforce any duty or liability created by the Securities Act must be brought in federal court and cannot be brought in state court.
2 unchanged sentences
Our stockholders will not be deemed to have waived our compliance with the federal securities laws and the regulations promulgated thereunder.
+Added: Docusign, Inc.
+Added: | 2026 Form 10-K | 37
Any person or entity purchasing or otherwise acquiring or holding any interest in any of our securities shall be deemed to have notice of and consented to our exclusive forum provisions, including the Federal Forum Provision.
7 unchanged sentences
Negative conditions in the general economy both in the U.S.
−Removed: and abroad, including conditions resulting from inflation, changes in interest rates or foreign exchange rates, tariffs and trade policy changes, gross domestic product growth, financial and credit market fluctuations, geopolitical conflict, natural catastrophes and the effects of climate change, public health crises, and terrorist attacks in the U.S., Europe, the Asia Pacific region or elsewhere, could cause a decrease in business investments, including spending on information technology, and negatively affect the growth of our business.
+Added: and abroad, including conditions resulting from inflation, changes in interest rates or foreign exchange rates, tariffs and changes in trade policies and practices, gross domestic product growth, financial and credit market fluctuations, geopolitical conflict, natural catastrophes and the effects of climate change, public health crises, and terrorist attacks in the U.S., Europe, the Asia Pacific region or elsewhere, could cause a decrease in business investments, including spending on information technology, and negatively affect the growth of our business.
In addition, unfavorable conditions in certain industry sectors could impact customers or partners disproportionately, which could also impact the demand for our products.
9 unchanged sentences
Additionally, while we believe our exposure from the recent conflicts in Ukraine and the Middle East is limited, we could experience unanticipated disruptions to our business as a result of current or future regional and global conflicts, including sanctions or other laws and regulations prohibiting or limiting operations in certain jurisdictions, increased risks of potential cyberattacks, related impacts to our customers, or micro- or macro-economic effects on the global economy.
−Removed: Docusign, Inc.
−Removed: | 2025 Form 10-K | 36
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.