⚠ AI-Generated

The summary below was generated by an AI language model and may contain errors or omissions. All other content on this page is deterministically extracted from the original SEC EDGAR filing.

CMS Energy modified five existing risk disclosures between the 2025 and 2026 filings, with no risks added or removed, reflecting substantive updates rather than structural shifts in risk categories. The most significant modifications addressed taxation complexity, rate regulation impacts, data center-driven electricity demand, and labor relations, indicating CMS Energy's focus on evolving regulatory, operational, and market-driven challenges. These refinements suggest the company is adjusting its risk narrative to emphasize emerging pressures, particularly around data center growth and tax policy uncertainties, while maintaining its core risk framework of 31 total risk factors.

Classification is based on semantic text similarity scoring and may include approximations. “No match” means no high-confidence textual match was found — not necessarily that a section was removed.

🟡 Modified

Changes in taxation as well as the inherent difficulty in quantifying potential tax effects of business decisions could negatively impact CMS Energy and Consumers.

high match confidence

Sentence-level differences:

Reworded sentence: "In July 2025, President Trump signed the OBBBA into law."

Current (2026):

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CMS Energy and Consumers are required to make judgments regarding the potential tax effects of various financial transactions and results of operations in order to estimate their obligations to taxing authorities. The tax obligations include income taxes, real estate taxes, sales and use taxes, employment-related taxes, and ongoing issues related to these tax matters. The judgments include determining reserves for potential adverse outcomes regarding tax positions that have been taken and may be subject to challenge by the IRS and/or other taxing authorities. Unfavorable settlements of any of the issues related to these reserves or other tax matters at CMS Energy or Consumers could have a material adverse effect. Additionally, changes in federal, state, or local tax rates or other changes in tax laws could have adverse impacts. In July 2025, President Trump signed the OBBBA into law. CMS Energy and Consumers evaluated the provisions of the OBBBA and concluded that the legislation is not expected to have a material impact on their respective financial statements. This conclusion is subject to change as additional guidance or interpretations become available. 44 44 44 Table of Contents Table of Contents

View prior text (2025)

CMS Energy and Consumers are required to make judgments regarding the potential tax effects of various financial transactions and results of operations in order to estimate their obligations to taxing authorities. The tax obligations include income taxes, real estate taxes, sales and use taxes, employment-related taxes, and ongoing issues related to these tax matters. The judgments include determining reserves for potential adverse outcomes regarding tax positions that have been taken and may be subject to challenge by the IRS and/or other taxing authorities. Unfavorable settlements of any of the issues related to these reserves or other tax matters at CMS Energy or Consumers could have a material adverse effect. Additionally, changes in federal, state, or local tax rates or other changes in tax laws could have adverse impacts. The change in administration and the expiring tax cuts in the TCJA could result in changes to the renewable energy tax credits enacted in the Inflation Reduction Act of 2022. These changes could impact CMS Energy’s and Consumers’ clean energy efforts.

🟡 Modified CMS Energy and Consumers are subject to rate regulation, which could have a material adverse effect on financial results. 🔒

🟡 Modified Demand for electricity associated with data center expansion could have a material effect on CMS Energy and Consumers. 🔒

🟡 Modified A work interruption or other union actions could adversely affect CMS Energy and Consumers. 🔒

🟡 Modified Changes to ROA could have a material adverse effect on CMS Energy’s and Consumers’ businesses. 🔒

4 more changes in this filing

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