MDT submits Iran Threat Reduction Act notice with FY25 10-K filing

Rhea-AI Filing Summary

Medtronic plc (MDT) has delivered a routine notice to the U.S. Securities and Exchange Commission stating that its Annual Report on Form 10-K for the fiscal year ended April 25, 2025, filed on June 20, 2025, contains disclosure made under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act. The letter, signed by Vice President, Global Controller and Chief Accounting Officer Denise L. Blomquist, fulfills the statutory requirement to alert the SEC of any Iran-related activities discussed in the 10-K. No quantitative details or descriptions of the underlying transactions are provided in this notice, leaving investors to consult the full 10-K for specifics.

Positive

• None.

Negative

• The filing acknowledges Iran-related activities, introducing potential regulatory, sanctions, or reputational risks pending further detail.

Insights

Compliance Risk Analyst

TL;DR Routine 13(r) filing flags potential Iran exposure; lack of detail implies modest but monitor-worthy compliance risk.

The filing is a statutory formality triggered whenever an issuer reports Iran-related dealings in its periodic reports. Although the notice itself is short, its presence confirms that some level of activity, however minor, required disclosure under Section 13(r). This raises possible sanctions and reputational considerations until investors can gauge scope and materiality in the 10-K. Absent specifics, probability of a severe penalty appears low, yet ongoing compliance monitoring is prudent for stakeholders.

Portfolio Manager

TL;DR Standard notification; impact neutral unless 10-K reveals material revenue or penalties.

From a portfolio standpoint, this notice alone does not change the investment thesis. Large multinationals routinely file 13(r) notices for de minimis or legacy transactions. Without figures, cash‐flow sensitivity or regulatory fines cannot be assessed. I will review the Form 10-K to confirm whether the Iran-related activities are immaterial or require position sizing adjustments, but for now I treat the disclosure as procedural.

June 20, 2025

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: Notice of disclosure filed in Annual Report on Form 10-K under Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the U.S. Securities Exchange Act of 1934, as amended

Ladies and Gentlemen,

Pursuant to Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the U.S. Securities Exchange Act of 1934, as amended, notice is hereby provided that Medtronic plc has made disclosure pursuant to such provisions in its Annual Report on Form 10-K for the period ended April 25, 2025, which was filed with the U.S. Securities and Exchange Commission on June 20, 2025.

Sincerely,

Medtronic plc

/s/ Denise L. Blomquist

Denise L. Blomquist

Vice President, Global Controller and Chief Accounting Officer (Principal Accounting Officer)

FAQ

Why did Medtronic (MDT) file a Section 13(r) notice on June 20, 2025?

Because its FY2025 Form 10-K contains disclosure about activities covered by the Iran Threat Reduction and Syria Human Rights Act, triggering mandatory SEC notification.

What period does the Medtronic 10-K with Iran disclosure cover?

The fiscal year ended April 25, 2025.

Who signed the Section 13(r) notice for Medtronic?

Denise L. Blomquist, Vice President, Global Controller and Chief Accounting Officer.

Does the notice reveal financial impact of Medtronic's Iran-related activities?

No. The letter only states that disclosure exists; investors must read the 10-K for specifics.

What laws require Medtronic to file this notice?

Section 219 of the Iran Threat Reduction and Syria Human Rights Act of 2012 and Section 13(r) of the Exchange Act.