ITM Power Keeps Selling More Electrolyzers — but for Six Straight Years, Making Them Cost More Than Selling Them Brought In

There is a trap investors fall into especially easily when the subject is the future of energy. It has no official name; we call it the story trap: a narrative is so convincing that we stop asking for the bill. Green hydrogen is that kind of story. Steel mills, refineries and chemical parks need it to get off coal and gas; governments back it with billions; and someone has to build the machines that make it from water and clean electricity. Whoever builds those machines, the story goes, sits at the source.

ITM Power of Sheffield, England, builds exactly those machines, and for years its stock has been widely held by German retail investors — the shareholder register further down shows it. So let's do the opposite of what the story trap wants: read the reports first, then decide what we think of the story. The tension running through this analysis is simple: revenue is growing fast, but ITM Power has not earned a gross profit in any of the past six fiscal years — making the product cost more than selling it brought in, every single time. In the second half of the latest fiscal year, by our calculation, the math tipped slightly into the black. Whether that holds is the one question everything hinges on.

Update October 2026: The FY2026 results — guidance met, gross profit slightly positive in the second half

As of this update: October 19, 2026. Is this the turnaround? Part of it, but not all of it yet. On October 19, 2026, ITM published its results for fiscal 2026 (May 2025 through April 2026). The full 2026 annual report is available on the company's website. It carries an unmodified opinion from the new auditor, BDO, dated October 16, 2026. That also means ITM meets the AIM Rule 19 deadline of October 31, 2026. ITM met or slightly beat its guidance:

• Revenue of £43.6 million (prior year: £26.0 million), up 68 percent and just above the £40 million to £43 million guidance. £3.9 million of it was booked under the new percentage-of-completion method; without it, revenue would have been £39.8 million. Revenue was recognized on 153 megawatts of deliveries (prior year: 40 megawatts).
• Adjusted EBITDA of minus £20.2 million (prior year: minus £33.0 million), at the better end of the minus £20 million to minus £21 million range raised on October 8. The pre-tax loss nearly halved to £24.8 million (prior year: £45.4 million, including the Linde settlement), or minus 4.0 pence per share.
• Cash of £215.6 million on April 30, 2026, at the top end of the upgraded £210 million to £215 million guidance range, according to the company. That includes £39.1 million in net proceeds from the Great British Energy subscription. Without it, cash would have been about £176 million.
• Gross profit of minus £6.1 million (prior year: minus £23.7 million). That is the sixth gross loss in a row, but the smallest of the six years. Notably, cost of sales stayed practically flat at £49.7 million even though revenue rose by two thirds.

Where the remaining gross loss comes from, the financial review explains in one sentence:

“The gross loss was £6.1m (FY25: £23.7m), a year-on-year reduction of almost 75%. This loss is due to the under-absorption of factory costs of £7.5m, resulting from increased production capacity as well as manufacturing losses or inventory write-off provisions, as per our policy, of £5.0m.”

— ITM Power, results announcement of October 19, 2026 (“Preliminary Results”), section “Gross margin”

It gets interesting when you split the year into its halves. This is our own calculation, not a company figure: full year minus the first half as reported in the half-year report. In the second half (November 2025 through April 2026), £25.6 million of revenue came with £25.2 million of cost of sales — a gross profit of about £0.4 million. The first half had still produced minus £6.5 million. Second-half adjusted EBITDA was minus £8.3 million, after minus £11.9 million in the first half. The calculation holds only if the half-year figures stood unchanged in the audited accounts; ITM itself reports no second-half figures.

Why we don't celebrate that plus without looking closer: during the fiscal year, ITM released £4.4 million of provisions for loss-making legacy contracts, used £1.5 million and created £3.4 million. Released provisions boost earnings — in which line and in which half, the report does not say. If all or most of the release fell into the second half, the narrow half-year gross profit would not have held up without it. At the same time, the annual report shows the legacy burden shrinking: 83 percent of the £144.0 million order backlog now consists of profitable contracts, up from 71 percent in January and 60 percent in April 2025.

For the current fiscal year 2027, ITM expects revenue of £50 million to £60 million, adjusted EBITDA of minus £17 million to minus £20 million and cash of £170 million to £180 million on April 30, 2027 — including capital spending on the new CHRONOS production line. By our calculation, that implies a cash outflow of roughly £36 million to £46 million, more than in the year just ended. So the loss is only expected to shrink a little. ITM's explanation: the loss remains a function of how fully the factory is loaded.

Two points of context. First, CEO Dennis Schulz, CFO Amy Grey and CTO Simon Bourne presented the results at 9:00 a.m. GMT on October 19 via the Investor Meet Company platform. A recording was not yet publicly available at the time of writing; we therefore analyzed the results announcement and the full annual report, not the presentation. Second, on October 16, 2026, the last trading day before the results, the shares closed at 91.95 pence, according to fundamental data. With 691.4 million shares, that is a market value of about £636 million. The section “What the stock costs” uses this price.

What this means for this analysis: the direction is right, and it is now backed by audited accounts, not just guidance. But the core question is only half answered. A slightly positive half year with released provisions at its back is not yet a business model that carries itself. The next piece of evidence comes with the FY2027 half-year report, due by January 31, 2027 at the latest.

What ITM Power actually does — machines that split water into hydrogen

ITM Power was founded in 2000 and has been listed since 2004 on AIM, the growth market of the London Stock Exchange. The company makes electrolyzers. Think of an electrolyzer as a battery running in reverse: you push electricity through water, and the water splits into oxygen and hydrogen. If the power comes from wind or solar, the result is called green hydrogen. ITM uses PEM technology, in which a wafer-thin polymer membrane keeps the two gases apart. The heart of the system is the stack of such cells — ITM's current stack is called TRIDENT, and its successor, CHRONOS, is in development.

Out of those stacks come complete plants in three sizes: NEPTUNE V, a 5-megawatt containerized plant; POSEIDON, a 20-megawatt module for large projects; and, since October 2025, ALPHA 50, a complete 50-megawatt plant that ITM prices at €50 million, according to its half-year report. On top of that come maintenance, engineering studies and, since June 2025, a subsidiary called Hydropulse that is meant to build, own and operate hydrogen plants itself and sell the hydrogen to industrial customers. On October 12, 2026, Hydropulse announced heads of terms with a European oil refinery for a 150-megawatt project with a ten-year term; a final investment decision is targeted for 2027, production for 2029. As of April 30, 2026, ITM had 301 employees, according to the annual report.

Its best-known reference projects are in Germany. Together with Linde Engineering, ITM is supplying RWE with two 100-megawatt plants in Lingen, in Lower Saxony. The first is now operational, according to the results announcement; on August 4, 2026, ITM announced that hydrogen from Lingen had, for the first time, reached Evonik's chemical park in Marl through roughly 120 kilometers of pipeline. The second is due for completion in the current fiscal year. For Shell, the 100-megawatt REFHYNE II project is under way in Wesseling. Europe excluding the U.K. accounted for £41.0 million of £43.6 million in fiscal 2026 revenue, about 94 percent.

Two notes that matter for every number in this piece. First, ITM's fiscal year ends on April 30. “FY2026” means May 2025 through April 2026. Second, ITM Power does not report to the U.S. securities regulator, the SEC. The symbol ITMPF is merely a U.S. over-the-counter quote with no reporting obligation. All evidence therefore comes from the company's own reports — the 2025 and 2026 annual reports, the half-year report of January 29, 2026, and the regulatory announcements distributed through the London Stock Exchange's news service (RNS).

How the stock landed on our desk

Through the forum ranking of the German finance portal wallstreet-online — the list of stocks German retail investors discuss most — in late September 2026, where it appeared under its U.S. symbol ITMPF. A list like that measures attention, not quality. How big the German fan base really is shows up in the shareholder register in the 2026 annual report (as of October 16, 2026): among the notifiable holders, next to the British investment platforms Hargreaves Lansdown (8.44 percent) and Interactive Investor (6.00 percent), sit Deutsche WertpapierService Bank (5.62 percent), ING-DiBa (3.10 percent) and Commerzbank (2.91 percent) — custodians that mostly hold shares for private accounts.

There was plenty to talk about. The stock moved a lot this year: based on the regulatory announcement published the next day, it closed at about 64.4 pence on April 8, 2026 (the issue price of 55.56 pence was 13.7 percent below that). On September 15, 2026, the three executive directors bought shares under the employee share plan at 98.89 pence. That is a gain of just over 50 percent in five months. In between came the investment by state-owned Great British Energy, an approved £46.5 million government grant, a collaboration with Rheinmetall and the first hydrogen from Lingen. Exactly the stuff stories are made of. By October 16, 2026, the price had eased to 91.95 pence.

The numbers over the years — given their due

First, what is genuinely impressive: the growth. Revenue was £4.3 million in FY2021, stalled for two years at £5.6 million and £5.2 million, then jumped to £16.5 million (FY2024), £26.0 million (FY2025) and £43.6 million (FY2026) — ten times as much in five years. For FY2027, ITM is targeting £50 million to £60 million. The factory is running better, too: the share of plants that pass the factory acceptance test on the first attempt rose from below 50 percent to 99 percent, according to the FY2025 results.

Now the other line of the income statement. Gross profit — revenue minus what it cost to make the plants that were sold — was negative in every one of those years: minus £6.5 million, minus £23.5 million, minus £79.1 million, minus £16.7 million, minus £23.7 million and, most recently, minus £6.1 million in FY2026. Adjusted EBITDA (a company measure of operating earnings before depreciation, excluding exceptional items and part of share-based pay) improved from minus £33.0 million to minus £20.2 million, and the pre-tax loss from £45.4 million to £24.8 million. Lower administrative expenses helped (£26.2 million instead of £34.3 million); interest income fell from £10.2 million to £7.4 million.

What has made the losses bearable so far is the cash pile. Over the years, ITM has repeatedly raised fresh money from shareholders; as of April 30, 2026, the balance sheet showed £578.9 million of share premium (the money raised above par value in share issues) against an accumulated deficit of £371.6 million. Cash peaked at £365.9 million on April 30, 2022. A year before the peak, on April 30, 2021, it was £176.1 million. It then stood at £282.6 million (2023), £230.3 million (2024) and £207.0 million (2025), each on April 30. On October 31, 2025, it was £197.8 million, and on April 30, 2026, £215.6 million — the first increase at a fiscal year-end since 2022, carried by the state's investment. ITM has practically no debt apart from lease obligations.

A note on the audit: the FY2026 accounts are the first audited by BDO as the new auditor. The opinion is unmodified, and BDO sees no material uncertainty about the company's ability to continue as a going concern. As key audit matters, BDO names exactly the spots this analysis focuses on: the valuation of provisions for loss-making contracts and for warranties, revenue recognition under the IFRS 15 accounting standard, and the valuation of inventory, including how factory costs are allocated to the plants. Rule of thumb: a clean audit opinion confirms the numbers, not the business model.

Uncomfortable truth No. 1: for six years, every pound of revenue cost more than a pound

In FY2025, £26.0 million of revenue came with cost of sales of £49.7 million. For every pound a customer paid, ITM spent about £1.91 before a single penny went to administration, research or sales. In FY2026, the ratio improved markedly to £49.7 million of costs against £43.6 million of revenue, about £1.14 per pound of revenue — but still above one. In the second half, by our calculation, it dipped just below, to about £0.99. The company's explanation for the rest: the factory is not yet fully utilized, so its fixed costs are spread over too few plants. And the order book still contains old contracts signed at prices on which ITM cannot make money:

“The remaining legacy projects, which do not contribute to margin but are fully provided for, are expected to be recognised over the next 18 months.”

— ITM Power, half-year report of January 29, 2026, section “Income statement”

In plain English: in January 2026, 29 percent of the order backlog came from legacy contracts with no margin. As of April 30, 2026, it is only 17 percent of £144.0 million, according to the results announcement — roughly £24 million. ITM already booked the losses on those contracts as provisions in earlier years. That has a side effect worth knowing: the cost of those deliveries does not show up again in gross profit, because it was booked earlier. And where a legacy contract turns out better than feared, provisions are even released and boost earnings — £4.4 million in FY2026. Part of the improved gross result is genuine progress; part of it is simply that old losses don't count twice. How long this effect will last is in the annual report:

“We expect that the majority of this provision will be released during FY27 as these projects complete, however these timescales are not within the Group's control.”

— ITM Power, Annual Report 2026, Note 22 “Provisions,” section “Provision for contract losses”

The provision for loss-making contracts amounts to £20.6 million gross; the balance sheet shows £9.5 million net, because £11.1 million has been offset directly against the inventory of those projects. Management estimates that the actual requirement could fall between £17.6 million and £25.5 million. For investors, this means: from FY2028 on, this tailwind is gone, and gross profit has to come from new contracts alone.

On top of that comes the change in how revenue is booked. ITM used to recognize revenue only at milestones such as delivery or acceptance. For new, non-standard contracts (POSEIDON, ALPHA, non-standard NEPTUNE), revenue is now spread according to construction progress. In FY2026, that amounted to £3.9 million, just under 9 percent of revenue. When ITM raised its revenue guidance on February 17, 2026, it explicitly cited this method as one reason, because it brings revenue onto the books earlier. More revenue by percentage of completion does not mean more business — it means business booked sooner.

Uncomfortable truth No. 2: part of the cash pile is customers' money

In the first half of fiscal 2026, cash fell by only £9.2 million. That sounded like a company almost covering its own losses. The half-year report already explained back then why the picture was too flattering:

“Cash at 31 October 2025 was £198m (31 October 2024: £203m), representing an outflow since the year-end of £9.2m as we continued manufacturing customer commitments for which cash had been received in previous periods.”

— ITM Power, half-year report of January 29, 2026, section “Cash flow and balance sheet”

Picture a contractor who takes a deposit on every job. As long as new jobs with deposits keep coming in, his bank account looks healthy — even if he makes nothing on the individual jobs. At ITM those deposits sit on the balance sheet as “deferred income”: £68.2 million as of April 30, 2026, up from £64.2 million a year earlier. The annual report says openly that ITM structures its payment milestones to cover material costs up front.

The full year shows how quickly that tailwind fades. Excluding the £39.1 million in net proceeds from Great British Energy, about £30.5 million flowed out in FY2026 — £9.2 million in the first half and about £21.3 million in the second. Operating cash outflow was £24.0 million (prior year: £20.0 million), plus £13.2 million of capital spending on buildings, machinery and development, offset by £7.4 million of interest received. For FY2027, ITM guides to cash of £170 million to £180 million, including capital spending on the new CHRONOS line; by our calculation, that means an even larger outflow of roughly £36 million to £46 million. The £46.5 million grant from the energy ministry is only paid out as the money is spent.

The fair counterpoint: an outflow of that size against more than £200 million in cash is not an acute danger. According to the annual report, management stress-tested its forecast through the end of October 2027 in a scenario in which no customer pays at all — and cash would still stay positive for twelve months, and BDO sees no material uncertainty about the going concern. ITM has time. The only question is whether the time is enough for the factory to start making money.

Uncomfortable truth No. 3: two customers delivered almost four fifths of revenue — and Linde sits on every side of the table

The reports do not name customers, but they give their size. A single customer, labeled “Customer B” in the half-year report, accounted for £12.6 million of £18.0 million in revenue in the first half of fiscal 2026, just under 70 percent. For the full FY2026, the largest customer brought in £25.6 million of £43.6 million (59 percent), according to the annual report, and the second-largest £8.8 million (20 percent) — so two customers account for almost four fifths of revenue. Whether the year's largest customer is the same as Customer B in the half year cannot be determined; the letter labels change between reports. According to the half-year report, revenue came predominantly from deliveries for Lingen 1. A few large projects make up most of the revenue, and each of them ends at some point.

Even more remarkable is the role of another name: Linde. The industrial-gas group is ITM's largest shareholder with 100 million shares (14.46 percent as of October 16, 2026), has a representative on the board, is a partner in the joint venture ITM Linde Electrolysis and a project partner in Lingen. It is also a customer: in FY2026, ITM billed the Linde/BOC group £15.0 million in milestone payments, according to the annual report (prior year: £12.2 million), of which £5.4 million was outstanding at year-end. And it was the opposing party in a dispute that cost ITM a lot of money:

“In the last financial year, the Group reached the conclusion of the commercial dispute with Linde/BOC Group, represented on the Board by M von Plotho, leading to a payment to Linde of £13.0m.”

— ITM Power, half-year report of January 29, 2026, Note 7 “Related Parties”

£13.0 million — half of FY2025's entire revenue, paid to the company's own major shareholder. The details of the dispute remain confidential; according to the 2026 annual report, the directors are satisfied that all historic claim risk is now settled. Add the people at the top: CEO Dennis Schulz, in office since December 2022, previously held senior roles at Linde Engineering. Since January 15, 2026, Jürgen Nowicki has chaired the board; he previously spent five years as Linde's nominated board representative, and most recently he was CEO of Linde Engineering. The board reviewed this prior role, according to the 2026 annual report, and lists Nowicki as independent. Since June 24, 2026, Oleg Williamson has represented the major shareholder on the board as Linde's nominated director; according to the 2026 annual report, the board does not consider him independent as a shareholder nominee.

None of this is hidden; all of it is disclosed. But it means that at ITM a single group is at once the largest owner, a partner, a customer and — until recently — an opposing party in a dispute, and both the CEO and the board chair previously worked at Linde. That can be an advantage, because it opens doors. It can also mean that in a conflict it is not obvious who sits on which side of the table. Anyone holding the stock should read the related-party disclosures in every report carefully.

Uncomfortable truth No. 4: the state bought in at a 13.7 percent discount

On April 9, 2026, ITM announced two pieces of good news at once. Great British Energy, the U.K.'s publicly owned energy company, is investing £40 million in new shares. And the Department for Energy Security and Net Zero signaled a grant of £46.5 million, formally awarded on July 9, 2026. Both are meant to fund an automated production line in Sheffield for the new CHRONOS stack with one gigawatt of annual capacity; ITM expects to invest up to £120 million over three years and targets commercial operation in 2028. The grant is paid quarterly in arrears, and ITM has committed to adding about 250 jobs in the U.K. over five years.

The terms appear further down in the same announcement:

“The Subscription Shares will represent approximately 10.4% of the Company's issued share capital immediately following the Subscription and the Subscription Price represents a 13.7% discount to the closing mid-market price of an ITM Power ordinary share on 8 April 2026.”

— ITM Power, regulatory announcement of April 9, 2026, section “The Subscription”

Dilution means your slice of the cake gets smaller because more people are eating. Great British Energy received 71,994,240 new shares at 55.56 pence, without existing shareholders being able to participate. Together with 2.0 million shares from exercised employee options, the share count rose from 617.4 million to 691,405,563 by April 30, 2026; there has been no more recent notification. Options come on top: as of April 30, 2026, 14,962,228 options with an exercise price of 5 pence were outstanding, according to the annual report, up from 12.4 million a year earlier — including the April 2026 awards to the three executive directors with a one-off discretionary award of 1.3 million to the CEO.

The same announcement contained a clause that was easy to miss: had ITM raised capital again within six months at a deeper discount, it would have had to compensate Great British Energy as if it had subscribed at that discount. That window closed on October 9, 2026, with no new capital raise through October 19. At the annual general meeting on October 30, 2026, however, the board is seeking the usual authority to issue new shares — under the correction of October 16, 2026, resolution 11b covers up to a nominal amount of £23,046,852, about two thirds of the capital; the original notice had mistakenly stated an amount equal to the entire capital there. Great British Energy may also send an observer to board meetings and, with a stake of at least 10 percent, nominate a director. That leaves two major shareholders with their own agendas in the register, Linde and the British state — according to the annual report, a combined 24.87 percent of the shares are not in public hands.

What the stock costs

At the October 16, 2026 close of 91.95 pence, the last trading day before the results, ITM Power is worth about £636 million with 691.4 million shares. Measured against FY2026 revenue of £43.6 million, that is about 14.6 times sales; against the midpoint of FY2027 guidance (£55 million), about 11.6 times. Subtract cash of £215.6 million at April 30, 2026, and the enterprise value is roughly £420 million, just under ten times FY2026 revenue.

There is no price-to-earnings ratio because there are no earnings. Against equity of £240.1 million as of April 30, 2026, the market pays a little over 2.6 times book value. The “as of today” box on this page shows how far the share price has moved since. The order of magnitude is what matters: at ITM, the market is not paying for profits today but for the expectation that the factory fills up and the legacy contracts roll off. That is a price argument, not a verdict on quality — but it shows how much future is already in the price.

For comparison, it's worth looking at Plug Power, the American hydrogen company that also sells electrolyzers and has faced the same gross-margin question for years. And for the defense angle of the story: the collaboration agreed with Rheinmetall in April 2026 targets decentralized plants for synthetic fuels for NATO forces, initially in the U.K. and Germany — so far a collaboration without a quantified order.

Upside and risks at a glance

What speaks for ITM Power:

• Revenue is growing strongly: from £26.0 million (FY2025) to £43.6 million (FY2026), with FY2027 guidance of £50 million to £60 million.
• Gross profit improved from minus £23.7 million to minus £6.1 million; in the second half of FY2026, by our calculation, it was slightly positive.
• The share of profitable contracts in the backlog rose from 60 percent (April 2025) to 83 percent (April 2026).
• The balance sheet is debt-free, with £215.6 million in cash as of April 30, 2026; the new auditor BDO's first opinion is unmodified.
• The British state is both a shareholder and a grant provider (£40 million of equity plus a £46.5 million grant); Lingen 1 is operational, and Hydropulse is negotiating a 150-megawatt project.

What speaks against ITM Power:

• There was no gross profit in any fiscal year from FY2021 through FY2026; in FY2026, production still cost £1.14 per pound of revenue, and the narrow second-half plus came with a tailwind from £4.4 million of released provisions.
• Excluding the state investment, about £30.5 million flowed out in FY2026; by our calculation, the FY2027 cash guidance implies an outflow of roughly £36 million to £46 million.
• High customer concentration: two customers with almost four fifths of annual revenue, plus Linde's multiple roles as major shareholder, partner, customer and former opposing party.
• Dilution: the share count rose by about 12 percent in 2026 to 691.4 million, and the new shares were issued at a 13.7 percent discount.
• The price assumes a lot of success: about 14.6 times FY2026 revenue on October 16, 2026.

A human conclusion

Remember the story trap from the start? ITM Power's story is not made up. The plants run, hydrogen from Lingen flows through a pipeline to a chemical park, the British state has put money on the table, and revenue has grown tenfold in five years. But the story has one line it rarely tells: in each of the six fiscal years through FY2026, making the plants it sold cost more than selling them brought in — before a single office was paid for. And the cash pile is carried partly by customers' money and partly by the state's.

None of that makes ITM Power a bad company. It makes it a company that has delivered half of the proof. The FY2026 results show real progress: more revenue at the same cost of sales, a half year slightly in the black, an order book with fewer and fewer legacy contracts. The rest of the proof has to come with the FY2027 half-year report, by the end of January 2027 at the latest: does gross profit stay positive once the provisions for legacy contracts are used up? Anyone who reads only the story until then is reading half of it. What you make of it is up to you. The decision is yours.

Sources

• ITM Power — Annual Report 2026 (fiscal year to April 30, 2026; BDO opinion of October 16, 2026; provisions, customers, related parties, shareholders; latest periodic report)
• ITM Power — preliminary results FY2026 (RNS of October 19, 2026; FY2027 guidance)
• ITM Power — half-year report to October 31, 2025 (RNS of January 29, 2026; basis for the split into halves)
• ITM Power — Annual Report 2025 (fiscal year to April 30, 2025) and Annual Report 2023 (key figures FY2021 to FY2023)
• Trading update of December 4, 2025, guidance raise of February 17, 2026 and guidance upgrade of October 8, 2026
• Regulatory announcement of April 9, 2026 (Great British Energy, grant) and grant award of July 9, 2026
• Option awards of April 17, 2026 and total voting rights of April 30, 2026 (691,405,563 shares)
• MorGen Energy investment decision of March 11, 2026, Rheinmetall of April 17, 2026, Protium of June 3, 2026, DB Systemtechnik of June 24, 2026, Hydropulse 150-megawatt heads of terms of October 12, 2026
• New chair of January 16, 2026 and new Linde representative of June 25, 2026
• First hydrogen from Lingen, August 4, 2026 and directors' dealings of September 17, 2026 (purchase at £0.9889 on September 15, 2026)
• Notice of annual general meeting of October 5, 2026 and correction of October 16, 2026 (AGM on October 30, 2026, share-issuance authority)
• AIM Rules for Companies (Rules 18 and 19, deadlines for half-year and annual reports)
• Source: fundamental data & ITM Power plc reports (annual and half-year reports, RNS regulatory announcements)

This analysis is a journalistic assessment based on publicly available company reports. It is not investment advice and not a solicitation to buy or sell securities. Stocks can lose value, up to a total loss. All figures carry the date of their source; share prices are dated snapshots. Positions held by the operator are disclosed daily; where one exists, it appears as a notice at the top of this analysis.