What changed in this filing

/stocks — the workspaceLOADING

Item 9A. Controls and Procedures

2026-02-27 compared with 2025-02-19 · 31 added, 28 removed, 472 unchanged (11% of the section changed)

1 unchanged sentence

Disclosure Controls and Procedures

The duly authorized officers of the Sponsor performing functions equivalent to those a principal executive officer and principal financial officer of the Trust would perform if the Trust had any officers, with the participation of the Trustee, have evaluated the effectiveness of the Trust’s disclosure controls and procedures, and have concluded that the disclosure controls and procedures of the Trust were effective as of the end of the period covered by this report to provide reasonable assurance that information required to be disclosed in the reports that the Trust files or submits under the Securities Exchange Act of 1934, as amended, is recorded, processed, summarized and reported, within the time periods specified in the applicable rules and forms, and that it is accumulated and communicated to the duly authorized officers of the Sponsor performing functions equivalent to those a principal executive officer and principal financial officer of the Trust would perform if the Trust had any officers, as appropriate to allow timely decisions regarding required disclosure.

The duly authorized officers of the Sponsor performing functions equivalent to those a principal executive officer and principal financial officer of the Trust would perform if the Trust had any officers, with the participation of the Trustee, have evaluated the effectiveness of the Trust’s disclosure controls and procedures, and have concluded that the disclosure controls and procedures of the Trust were effective as of December 31, 2025, the end of the period covered by this report, to provide reasonable assurance that information required to be disclosed in the reports that the Trust files or submits under the Securities Exchange Act of 1934, as amended, is recorded, processed, summarized and reported, within the time periods specified in the applicable rules and forms, and that it is accumulated and communicated to the duly authorized officers of the Sponsor performing functions equivalent to those a principal executive officer and principal financial officer of the Trust would perform if the Trust had any officers, as appropriate to allow timely decisions regarding required disclosure.

There are inherent limitations to the effectiveness of any system of disclosure controls and procedures, including the possibility of human error and the circumvention or overriding of the controls and procedures.

9 unchanged sentences

Based on their assessment and those criteria, the Sponsor’s management concluded that the Trust maintained effective internal control over financial reporting as of December 31, 2025.

The effectiveness of the Trust’s internal control over financial reporting as of December 31, 2024 has been audited by PricewaterhouseCoopers LLP, the independent registered public accounting firm that audited and reported on the financial statements included in this Form 10-K, as stated in their report which is included herein.

The effectiveness of the Trust’s internal control over financial reporting as of December 31, 2025 has been audited by PricewaterhouseCoopers LLP, an independent registered public accounting firm, as stated in their report which is included herein.

Changes in Internal Control over Financial Reporting

There were no changes in the Trust’s internal control over financial reporting that occurred during the Trust’s fourth fiscal quarter of the period covered by this report that have materially affected, or are reasonably likely to materially affect, the Trust’s internal control over financial reporting.

There were no changes in the Trust’s internal control over financial reporting that occurred during the quarter ended December 31, 2025 that have materially affected, or are reasonably likely to materially affect, the Trust’s internal control over financial reporting.

Other Information.

Not applicable.

Section 13 (r) Disclosure

Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012, which added Section 13 (r) of the Exchange Act, the Trust hereby incorporates by reference herein Exhibit 99.1 of this report, which includes disclosures regarding activities at Malaysia Airport Holdings Berhad, in which certain funds and entities affiliated with Global Infrastructure Management, LLC, a consolidated subsidiary of BlackRock, Inc., obtained a minority non-controlling interest.

Disclosure Regarding Foreign Jurisdictions that Prevent Inspections.

19 unchanged sentences

Bryan Bowers , 51, has been employed by BlackRock or its affiliates since September 6, 2011, performing supervisory and managerial functions.

Since October 4, 2021, Mr.

Bowers has served as a Director of BlackRock and manages the Product Oversight and Governance team within BlackRock’s Global Accounting and Product Services (“GAAPS”) function.

In that capacity, Mr.

Bowers oversees fund accounting operations, strategic product initiatives, fund certifications, accounting policies and provides support to the Audit Committee of the Board for each iShares Trust, iShares, Inc.

Bowers is a Managing Director of BlackRock and is a member of the Product Governance & Reporting Team within BlackRock's Global Accounting and Product Services (“GAAPS”) function.

Bowers serves as the Chief Trust Officer of BlackRock Institutional Trust Company (“BTC”) and the Chief Financial Officer for the US iDTS trusts.

From 2021 to 2025, Mr.

Bowers oversaw fund accounting operations, strategic product initiatives, fund certifications, accounting policies and provides support to the audit committee of the board for each iShares Trust, iShares, Inc.

and iShares U.S.

16 unchanged sentences

Landini is a certified financial planner.

Lindsey Haswell , 46, is a member of the Sponsor’s audit committee.

Haswell is the Chief Legal and Administrative Officer of MoonPay, a web3 and crypto payments company that she joined in February 2023.

She served in the same capacity for crypto-asset firm Blockchain.com from May 2021 to February 2023.

Lindsey Haswell , 47, is the Chief Legal Officer of Tempo Labs, a layer-one blockchain designed specifically for payments that was incubated by Stripe and Paradigm that she joined in August 2025.

She is also on the board of ProCap Acquisition Corp., a fintech-focused special purpose acquisition company.

She served as the Chief Legal and Administrative Officer for crypto payments firm MoonPay from February 2023 to August 2025, and the Chief Legal and Administrative Officer for crypto-asset firm Blockchain.com from May 2021 to February 2023.

Since July 2022, she also has served on the founding team of the Core blockchain network, a Bitcoin-powered layer-one blockchain.

6 unchanged sentences

The Code of Ethics is available by writing the Sponsor at 400 Howard Street, San Francisco, CA 94105 or calling the Sponsor at (415) 670-2000.

The Sponsor’s Code of Ethics is intended to be a codification of the business and ethical principles that guide the Sponsor, and to deter wrongdoing, to promote (1) honest and ethical conduct (including the ethical handling of actual or apparent conflicts of interest), (2) full, fair, accurate, timely and understandable disclosure in public reports, documents and communications, (3) compliance with applicable laws and governmental rules and regulations, (4) the prompt internal reporting of violations of the Code of Ethics and (5) accountability for adherence to the Code of Ethics.

The Sponsor’s Code of Ethics is intended to be a codification of the business and ethical principles that guide the Sponsor, and to deter wrongdoing, to promote (1) honest and ethical conduct (including the ethical handling of actual or apparent conflicts of interest), (2) full, fair, accurate, timely and understandable disclosure in public reports, documents and communications, (3) compliance with applicable laws and governmental rules and regulations, (4) prompt internal reporting of violations of the Code of Ethics and (5) accountability for adherence to the Code of Ethics.

BlackRock has adopted an insider trading policy governing the purchase, sale and other dispositions of BlackRock’s securities that applies to all employees of BlackRock and its subsidiaries, and BlackRock’s directors and officers, as well as BlackRock itself.

3 unchanged sentences

The Trust has no employees, officers or directors.

The Trust is managed by the Sponsor and pays the Sponsor the Sponsor’s fee.

For the year ended December 31, 2024, the Trust has incurred Sponsor’s fees of $63,272,642.

The Trust is managed by the Sponsor and pays the Sponsor the Sponsor’s fees.

For the year ended December 31, 2025, the Trust incurred Sponsor’s fees of $95,546,277.

Security Ownership of Certain Beneficial Owners and Management and Related Stockholder Matters.

5 unchanged sentences

See Item 11 above.

Principal Accounting Fees and Services.

Principal Accountant Fees and Services.

Audit and Non-Audit Fees

4 unchanged sentences

The audit committee of the Board of Directors of the Sponsor approved, prior to the commencement of the engagement, the engagement of and compensation to be paid to PricewaterhouseCoopers LLP as auditors of the Trust.

Exhibits, Financial Statement Schedules.

Exhibits and Financial Statement Schedules.

Financial Statements

18 unchanged sentences

Executive Officer Incentive-Based Compensation Clawback Policy is incorporated by reference to Exhibit 97.1 of the Annual Report on Form 10-K filed by the Registrant on February 20, 2024

Section 13(r) Disclosure

Inline XBRL Instance Document - the instance document does not appear in the Interactive Data File because its XBRL tags are embedded within the Inline XBRL document.

79 unchanged sentences

Net Realized and Unrealized Gain (Loss)

Net realized gain (loss) from:

Net realized gain from:

Litigation proceeds (a)

17,333 138,783 —

Silver bullion sold to pay expenses

2 unchanged sentences

3,625,989,545 1,216,849,453 282,624,263

Net realized gain (loss)

Net realized gain

3,649,571,483 1,227,169,811 286,497,320

18 unchanged sentences

( 95,546,277 ) ( 63,272,642 ) ( 53,561,823 )

Net realized gain (loss)

Net realized gain

3,649,571,483 1,227,169,811 286,497,320

66 unchanged sentences

38,060,491,397

Less Liabilities — (0.04) %

Liabilities in Excess of Other Assets — (0.04) %

( 14,200,889 )

6 unchanged sentences

13,407,235,411

Less Liabilities — (0.04) %

Liabilities in Excess of Other Assets — (0.04) %

( 5,976,407 )

41 unchanged sentences

Litigation proceeds (a)

— — 138,783 —

Net change in unrealized appreciation/depreciation

14 unchanged sentences

— — 1,227,031,028 —

Litigation proceeds (a)

— — 138,783 —

Net change in unrealized appreciation/depreciation

2 unchanged sentences

463,837,932 $ 11,628,353,352 $ 13,407,235,411 $ 1,227,031,028

Includes a payment received from a class action settlement related to silver of $ 138,783 .

Year Ended December 31, 2023

7 unchanged sentences

( 2,285,669 ) ( 49,834,316 ) ( 53,707,373 ) 3,873,057

Net realized loss

Net realized gain

— — 286,497,320 —

8 unchanged sentences

Offering of the Shares

Trust Shares are issued and redeemed continuously in aggregations of 50,000 Shares in exchange for silver bullion rather than cash.

Shares are issued and redeemed continuously in aggregations of 50,000 Shares in exchange for silver bullion rather than cash.

Individual investors cannot purchase or redeem Shares in direct transactions with the Trust.

16 unchanged sentences

Segment Reporting

The Trust adopted Financial Accounting Standards Board Update 2023 - 07, Segment Reporting (Topic 280 ) - Improvements to Reportable Segment Disclosures (“ASU 2023 - 07” ) during the period.

The Trust’s adoption of the new standard impacted financial statement disclosures only and did not affect the Trust’s financial position or results of operations.

The Chief Financial Officer of the Sponsor acts as the Trust’s Chief Operating Decision Maker (“CODM”) and is responsible for assessing performance and allocating resources with respect to the Trust.

2 unchanged sentences

3 - Trust Expenses

The Sponsor’s fee is accrued daily at an annualized rate equal to 0.50 % of the net asset value of the Trust, paid monthly in arrears.

The Sponsor’s fees are accrued daily at an annualized rate equal to 0.50 % of the net asset value of the Trust, paid monthly in arrears.

The Sponsor has agreed to assume the following administrative and marketing expenses incurred by the Trust:

12 unchanged sentences

In the normal course of business, the Trust may enter into contracts with service providers that contain general indemnification clauses.

The Trust’s maximum exposure under these arrangements is unknown as this would involve future claims that may be made against the Trust that have not yet occurred.

The Trust’s maximum exposure under these arrangements is unknown as this would involve future potential claims that may be made against the Trust that have not yet occurred.

7 - Concentration Risk

71 unchanged sentences

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 9A. Controls and Procedures