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Kamada plans to explain inventory cost accounting

The SEC staff comment addressed Kamada's accounting judgment for inventory designated for research and development activities.

(Moderate)

Sentiment and the balance of points

Rhea-AI Sentiment reads the wording of the document, how positive or negative its language is on a 1 to 5 scale. The balance of points shown with the takes weighs what the document actually discloses, so the two can disagree, for example when a trial that missed its main goal is described in upbeat language.

Form Type
6-K

Rhea-AI Filing Summary

Kamada Ltd. responded to SEC staff comments on its Form 20-F for the fiscal year ended December 31, 2025. The company stated that it did not capitalize costs related to inventory produced for commercial sale before regulatory approval in the fiscal years ended December 31, 2025, and December 31, 2024. Kamada intends to revise future filings to describe when economic benefits may be considered probable for capitalization of pre-approval inventory costs and, to the extent material, the types of costs that may be capitalized.

Filing Explained

In this Form 6-K, Kamada files its response to SEC accounting comments and incorporates the report by reference into the listed Form S-8 registration statements, making the response part of those registration filings too.

capitalization of inventory costs financial
"capitalization of inventory costs prior to receipt of regulatory approval"
regulatory approval regulatory
"prior to receipt of regulatory approval"
Regulatory approval is the official permission given by government agencies or authorities that allows a product, service, or business activity to be legally operated or sold. It is important to investors because receiving approval often indicates that a product has been reviewed for safety and compliance, which can influence its success and the company’s prospects in the market. Without this approval, launching or selling certain products may be restricted or prohibited.
economic benefits may be considered probable financial
"economic benefits may be considered probable"

FAQ

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What did KMDA tell the SEC about pre-approval inventory costs?

Kamada said it did not capitalize costs related to inventory produced for commercial sale before regulatory approval in the fiscal years ended December 31, 2025, and December 31, 2024. It intends to revise future filings to describe circumstances under which economic benefits may be considered probable for capitalization and, to the extent material, the types of costs that may be capitalized.

AI-generated analysis. How Rhea-AI works. Not financial advice.

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Learn about SEC filing dates

 

 

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

FORM 6-K

 

Report of Foreign Private Issuer

Pursuant to Rule 13a-16 or 15d-16

of the Securities Exchange Act of 1934

 

For the Month of October 2026

 

Commission File Number 001-35948

 

Kamada Ltd.

(Translation of registrant’s name into English)

 

2 Holzman Street
Science Park, P.O. Box 4081
Rehovot 7670402
Israel
(Address of principal executive offices)

 

Indicate by check mark whether the registrant files or will file annual reports under cover Form 20-F or Form 40-F.

 

Form 20-F ☒         Form 40-F ☐

 

 

 

 

This Form 6-K is being incorporated by reference into the Registrant’s Form S-8 Registration Statements, File Nos. 333-192720, 333-207933, 333-215983, 333-222891, 333-233267 and 333-265866.

 

Due to an administrative error, correspondence with the Securities and Exchange Commission (the “SEC”) was filed with the Israel Securities Authority, the Israeli equivalent of the SEC. This 6-K is filed in parity.

 

The following exhibit is attached:

 

99.1   Response to SEC Comment Letter dated September 25, 2026

 

1

 

SIGNATURE

 

Pursuant to the requirements of the Securities Exchange Act of 1934, the registrant has duly caused this report to be signed on its behalf by the undersigned hereunto duly authorized.

 

Date: October 5, 2026 KAMADA LTD.
   
  By: /s/ Nir Livneh
    Nir Livneh
Vice President, General Counsel and
Corporate Secretary

 

2

 

EXHIBIT INDEX

 

EXHIBIT NO.   DESCRIPTION
99.1   Response to SEC Comment Letter dated September 25, 2026

 

3

Exhibit 99.1

 

Kamada Ltd.

2 Holzman Street St.

Science Park, P.O. Box 4081,

Rehovot 7670402 Israel

 

VIA EDGAR

 

October 5, 2026

 

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Life Sciences

Washington, D.C. 20549

 

Attn: Eric Atallah
  Bonnie Baynes

 

Re: Kamada Ltd.
  Form 20-F for Fiscal Year Ended December 31, 2025
  Filed March 11, 2026
  CIK No. 0001567529

 

Ladies and Gentleman:

 

Kamada Ltd. (the “Company”) hereby transmits its response to the comment letter received from the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) on September 25, 2026, relating to Form 20-F for Fiscal Year Ended December 31, 2025, filed by the Company with the Commission on March 11, 2026.

 

For the Staff’s convenience, we have repeated below the Staff’s comment in bold and have followed the comment with the Company’s response.

 

Form 20-F for Fiscal Year Ended December 31, 2025

 

Note 3 - Significant Accounting Judgments, Estimates and Assumptions used in the Financial Statements

 

a. Judgments

 

Inventory designated for R&D activities, page F-23

 

1.We note your policy of recognizing inventory produced for commercial sale prior to regulatory approval and, in certain cases, prior to completion of Phase 3 clinical trials, based on a determination of probable future economic benefit. Please address the following:

 

●Confirm that you will expand your accounting policy disclosure in future filings to explain how you assess “probable future economic benefit” in this context and how you determine when regulatory and technical feasibility have been established, including the specific clinical milestones, regulatory indicators, or data endpoints that trigger capitalization. Refer to IAS 1, paragraphs 122 and 125, IAS 2 and IAS 38.

 

●To the extent that pre-launch manufacturing costs are material, revise your disclosure in future filings to clarify the accounting treatment for the distinct classes of capitalized pre-approval materials (e.g., raw materials versus work-in-process, etc.). Refer to Item 5 of Form 20-F.

 

Response: The Company acknowledges the Staff’s comment and respectfully advises that for the fiscal years ended December 31, 2025, and 2024, the Company did not capitalize costs related to inventory produced for commercial sale prior to receipt of regulatory approval. In response to the Staff’s comments, the Company intends to revise in its future filings its disclosure of Note 3 - Significant Accounting Judgments, Estimates And Assumptions Used In The Preparation Of The Financial Statements, to describe circumstances under which economic benefits may be considered probable in the context of capitalization of inventory costs prior to receipt of regulatory approval and, to the extent material, types of costs that may be capitalized.

 

* * *

 

 

The Company acknowledges that it is responsible for the adequacy and accuracy of its disclosures, notwithstanding any review, comments, action or absence of action by the Staff.

 

Should you have any further questions or comments regarding the above-referenced filing, please feel free to contact the undersigned at chaimeo@kamada.com, or our counsel, Nir Livneh at nirl@kamada.com and Jaclyn Liu of Morrison & Foerster LLP at (415) 268-6722. Thank you for your assistance.

 

Very truly yours,

 

Chaime Orlev

Chief Financial Officer

 

cc:Eric Atallah and Bonnie Baynes

Division of Corporation Finance

Office of Life Sciences

United States Securities and Exchange Commission

 

Jaclyn Liu, Esq.

Morrison & Foerster LLP

 

Filing Exhibits & Attachments

1 document

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