We reported that the corporate risk section tripled in fifteen years. Before believing our own chart, we re-ran it on the 1,619 companies that filed in every year β to tell firms getting wordier apart from a changing cast of filers.
An earlier article in this series, The Risk Section That Ate the 10-K, made a clean-looking claim: the median corporate risk section grew from 3,788 words in 2006 to 11,008 by fiscal 2020 β a 2.9Γ expansion that never once reversed. That number was computed the way most such numbers are: across every filing in each year, whoever happened to file.
But filers enter and leave. A firm goes public, another gets acquired, a third delists after a bad decade. If the companies entering the pool write longer risk sections than the ones leaving it, the aggregate can "triple" without any individual company changing a word. So which is it β the same firms getting wordier, or a changing cast? The honest way to find out is to fix the cast: keep only the 1,619 companies that filed in all fifteen years, and watch them alone.
Hold the cast fixed and the risk section still balloons. The 1,619 survivors went from a median of 3,637 words in 2006 to 8,759 in 2020 β a 2.4Γ expansion of the same companies' own disclosures. The full-pool figure is larger, 2.9Γ, and the gap between the two lines is the part of the story that belongs to the changing cast, not to any individual firm.
How much of the increase is within-firm depends on how you measure "length." Using the published metric β the median section β 71% of the 2006β2020 growth is the survivors' own. On the multiplicative scale a word like "tripled" implies, it runs higher: between 72% comparing average lengths and 84% averaging each firm's own log-growth, with a firm-fixed-effects regression near 76% β and that ratio never falls below 70% across two dozen robustness variations. On ratios, the finding is solid. Two caveats keep it from being airtight, and they belong in the open: in raw average word count only 58% is within-firm, and the median figure is tender at the edges β start the clock in 2008 rather than 2006, before Item 1A had finished phasing in, and it slips toward 64%. The tripling is mostly the same companies β but "mostly" is three-quarters on the ratio scale, not the near-certainty a single tidy number would imply.
The tidy version of the composition story is a crisis story: the 2008β2010 delisting wave flushed out failing firms, leaving a survivor pool that looks artificially stable. It is a good guess. It is also wrong here. The pooled and survivor lines track each other almost exactly through 2011 β the survivors' median even runs ahead of the pool in 2008β2010 β and only begin to separate from about 2012 on, widening most in 2014, 2018, and 2020. The compositional gap is a steady, modern divergence, not a financial-crisis artifact.
The original piece also reported that risk sections grew harder to read. That, too, could have been composition β verbose newcomers dragging the average fog index up. It mostly wasn't: depending on the estimator, between about two-thirds and four-fifths of the 2006β2020 rise in the fog proxy is within-firm (a firm-fixed-effects estimate puts it near 68%; the balanced panel nearer 75β79%). The same companies did not just write more; they wrote it more densely. The claim that readability declined is not entirely a within-firm effect β something like a quarter of it is the changing cast β but it is predominantly the same lawyers, writing worse, year after year.
Because the interesting outcome was not guaranteed. We pre-registered three questions before running any of this: whether the length finding would survive a balanced panel, whether composition would prove to be a small crisis-era effect, and whether the readability decline was within-firm. The first passed, and had it failed β had the tripling turned out to be mostly a changing cast β that would have been the more surprising and more important article. It didn't. But the second failed on its mechanism and the third came back "mostly, not entirely," and reporting those honestly is what earns the first one its credibility. A number you have tried to break and couldn't is worth more than a number you only admired.
Source: the shipped edgar-risk slice (EDGAR-CORPUS, Loukas et al. 2021), Item 1A of 10-K filings, FY2006β2020 β 91,493 filings, one per company-year (verified: distinct on CIKΓyear). The balanced panel is the 1,619 CIKs present in all fifteen years. For each year we compute pooled (all filers) and balanced (survivors) length and readability; the 2006β2020 change is split as pooled = within-firm (survivors) + composition, with within-share = Ξsurvivors / Ξpooled. Reported across scales: median words 71%, ratio of average lengths 72%, firm-fixed-effects within regression 76% (pyfixest, firm-clustered SEs; Ξlog 0.839 Β± 0.013), and mean of firms' log-growth 84% β all above 70%, and stable across a 24-cell robustness sweep [0.83β0.88] on the log scale. But only 58% on raw arithmetic-mean words, and 64% if the clock starts in 2008 (Item 1A was still phasing in). Readability uses the same decomposition on the Gunning-fog proxy; the within-firm share ranges 68% (firm-fixed-effects) to 79% (winsorized balanced-panel mean), central β75%. Fog means are winsorized at the 1st/99th percentile; medians are not.
A balanced panel is a selected panel: survivors are systematically larger and older, so their levels differ from the full pool β which is the point, but means these figures describe continuous filers, not the market. Fiscal-year labelling follows the corpus (an "FY2019" 10-K is usually filed in early 2020). The fog proxy is a consistent trend measure, not a calibrated readability score. Composition here is entry/exit of filers, not merger accounting.
SEC filings are US public domain. Corpus: cite Loukas et al. (2021), arXiv:2109.14394. Article text and figures: CC BY 4.0.