Risk Sleuth
PYPL · 10-K filed 3 Feb 2026 · year to 31 Dec 2025

PayPal Holdings

28 named things its latest annual report says its results depend on, each in the company's own words. 12 of them are also named by other companies we've read.

Suppliers

Cryptocurrency custodians

depends onnamed as a risk
We hold our customers’ cryptocurrency assets through one or more third-party custodians.Risk factors (Item 1A)

Third-party cloud and data center providers

depends onnamed as a risk
From time to time, we have experienced interruptions in the provision of such facilities and services provided by these third parties.Risk factors (Item 1A)

Partners and platforms

Payment card networks

depends onnamed as a risk
Any increase in interchange fees, special fees, or assessments for transactions that we pay to networks or payment processors could make our pricing less competitive, increase our operating costs, and reduce our operating income, which could materially harm our business, financial condition, and results of operations.Risk factors (Item 1A)

Also named by ABNB, ASO, CSGP, INTU, TFC, UBER

PYUSD Issuer

depends onnamed as a risk
In addition, we could face reputational harm through our relationship with the PYUSD Issuer if the PYUSD Issuer were to face regulatory scrutiny or make operational errors or if PYUSD is alleged to be used for transactions in connection with illicit or illegal activities.Risk factors (Item 1A)

Independent chartered financial institution (U.S. credit partner bank)

depends onnamed as a risk
In the event of any termination or interruption in a partner bank’s ability or willingness to lend, our ability to offer consumer credit and merchant financing products could be interrupted or limited, which could materially and adversely affect our business.Risk factors (Item 1A)

Other companies

Strategic investments (equity securities)

exposed to its price · $1.9 billionnamed as a risk
As of December 31, 2025 and 2024, our strategic investments totaled $1.9 billion and $1.6 billion, respectively, and represented approximately 13% and 10% of our total cash, cash equivalents, and short-term and long-term investment portfolio at those respective dates.Market risk (Item 7A)

Cross-border trade

earns fromnamed as a risk
Cross-border trade (i.e., transactions where the merchant and consumer are in different countries) is an important source of our revenues and profits.Risk factors (Item 1A)

Places

Singapore

operates innamed as a risk
For many of our other markets outside the U.S., we provide services on a cross-border basis through PayPal Pte. Ltd., our wholly-owned subsidiary based in Singapore.Risk factors (Item 1A)

Also named by A, AAPL, ALAB, AMAT, ANET, APP, AVGO, DLR and 12 more

Germany

operates innamed as a risk
For example, in August 2025, PayPal experienced a temporary service disruption triggered by a coding error in a system update, which primarily impacted a limited number of customers and partners in Germany.Risk factors (Item 1A)

Also named by APO, AXGN, BF/B, CPRT, DASH, EBAY, GD, GDDY and 12 more

Hazards

San Francisco Bay Area earthquakes

operates innamed as a risk
Our corporate headquarters are located in the San Francisco Bay Area, a seismically active region in California.Risk factors (Item 1A)

Also named by FFIV, FTNT, PANW, PLTR, RBRK, RDDT, TWLO, XYZ and 1 more

Commodities and inputs

Japanese yen revolving credit borrowings

exposed to its price · ¥90.0 billion (approximately $575 million)named as a risk
As of December 31, 2025 and 2024, ¥90.0 billion (approximately $575 million) and ¥90.0 billion (approximately $574 million), respectively, was outstanding under these facilities.Market risk (Item 7A)

British pound, Euro, Australian dollar, Canadian dollar, Indian rupee

exposed to its price · approximately $547 millionnamed as a risk
We have significant operations internationally that are denominated in foreign currencies, primarily the British pound, Euro, Australian dollar, Canadian dollar, and Indian rupee, which subject us to foreign exchange risk and may adversely impact our financial results.Market risk (Item 7A)

Regulators

Consumer Financial Protection Bureau (CFPB)

subject tonamed as a risk
As a large market participant of remittance transfers, we are subject to the direct supervisory authority of the CFPB.Business (Item 1)

Also named by ABNB, AFRM, ALLY, AN, AUB, AXP, BAC, CASH and 61 more

Office of Foreign Assets Control (OFAC)

subject tonamed as a risk
In the ordinary course of business we may identify and voluntarily report, and have reported, potential compliance issues to regulatory authorities, including the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”), and our compliance history may be considered by OFAC and other regulators as part of any potential future investigation regarding our compliance with sanctions.Risk factors (Item 1A)

Also named by ABNB, ADP, AIG, APP, BMI, BMNR, BPOP, CAT and 46 more

New York State Department of Financial Services

subject tonamed as a risk
PayPal holds a full Bitlicense issued by the State of New York Department of Financial Services to offer cryptocurrency services in the state.Business (Item 1)

Also named by AFL, AIG, AMP, BPOP, COIN, EFX, FNF, GS and 9 more

U.K. Financial Conduct Authority (FCA)

subject tonamed as a risk
We serve our customers in the U.K. through PayPal U.K. Limited (“PayPal U.K.”), a wholly-owned subsidiary that is subject to regulation as an electronic money institution in the U.K. by the FCA.Business (Item 1)

Also named by ARES, BEN, BX, COIN, GLXY, JEF, MCO, SPGI

European Central Bank (ECB)

subject tonamed as a risk
If the business activities of PayPal (Europe) exceed certain thresholds, or if the European Central Bank (“ECB”) so determines, PayPal (Europe) may be deemed a significant supervised entity and certain activities of PayPal (Europe) would become directly supervised by the ECB, rather than by the Luxembourg Commission de Surveillance du Secteur Financier.Risk factors (Item 1A)

Also named by BNY, GS, JPM, NTRS, STT, V

Monetary Authority of Singapore (MAS)

subject tonamed as a risk
PayPal Pte. Ltd. is supervised by the Monetary Authority of Singapore (“MAS”), and in July 2023 was issued a Major Payment Institution license by the MAS under the Payment Services Act 2019.Risk factors (Item 1A)

Also named by AIG

Luxembourg Commission de Surveillance du Secteur Financier (CSSF)

subject tonamed as a risk
We serve our customers in the EU through PayPal (Europe) S.à.r.l. et Cie, S.C.A. (“PayPal (Europe)”), a wholly-owned subsidiary that is licensed and subject to regulation as a credit institution in Luxembourg by the CSSF.Business (Item 1)

Utah Department of Financial Institutions and FDIC (PayPal Bank application)

subject tonamed as a risk
There is no assurance that our applications to establish PayPal Bank will receive regulatory approval.Business (Item 1)

Paidy (Japan) / Ministry of Economy, Trade and Industry

subject to
Paidy, Inc. holds multiple licenses for the issuance of its consumer installment products in Japan and is registered with the Ministry of Economy, Trade and Industry as a Comprehensive Credit Purchase Intermediary.Business (Item 1)

Laws and programs

OECD Pillar Two global minimum tax

subject to · 15%named as a risk
As additional jurisdictions enact similar legislation, transition rules expire, and other provisions of the minimum tax legislation become effective, our effective tax rate and cash tax payments could increase in future years.Risk factors (Item 1A)

Also named by ABNB, ACN, ADI, ADM, ADSK, AKAM, ALB, AMAT and 70 more

GENIUS Act

subject tonamed as a risk
Additionally, we are a digital asset service provider under the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the “GENIUS Act”), which subjects us to obligations relating to our cryptocurrency business and may affect the competitive landscape for payment stablecoins.Risk factors (Item 1A)

Also named by AUB, C, CFR, COF, COIN, CUBI, EWBC, FCNCA and 15 more

Electronic Fund Transfer Act and Regulation E

subject tonamed as a risk
We are subject to, and have paid amounts in settlement of, lawsuits alleging that our business violated the EFTA and Regulation E or otherwise advancing claims for relief relating to our business practices (e.g., that we improperly held consumer funds or otherwise improperly limited consumer accounts).Risk factors (Item 1A)

U.S. state money transmitter licenses

subject tonamed as a risk
If we fail to comply with applicable laws or regulations required to maintain our licenses, we could be subject to liability and/or additional restrictions, forced to cease doing business with residents of certain states or territories, forced to change our business practices, or required to obtain additional licenses or regulatory approvals, which could impose substantial costs and harm our business.Risk factors (Item 1A)

FDIC/OCC valid-when-made rule

subject tonamed as a risk
An adverse outcome of these or similar challenges, or changes to applicable laws and regulations or regulatory policy, could materially impact our U.S. PPWC and PPBL products, certain installment loan products, and our business.Risk factors (Item 1A)

EU Multilateral Interchange Fee Regulation

subject tonamed as a risk
For example, in the EU, the Multilateral Interchange Fee Regulation caps interchange fees and provides for business rules to be complied with by any company dealing with payment card transactions.Business (Item 1)

EU Consumer Credit Directive

subject tonamed as a risk
This will change in the E.U. markets with the implementation of the revised Consumer Credit Directive which will take effect in November 2026 and result in formerly “unregulated” credit products being generally (and subject to the principle of proportionality in particular regarding underwriting obligations) subject to the same laws as fully regulated credit.Business (Item 1)