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SEC Comment Letter for COTY (COTY) — Feb 26, 2026

COTY INC.
Date: Feb. 26, 2026 · CIK: 0001024305 · Accession: 0000000000-26-002004

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File numbers found in text: 001-35964

Date
February 26, 2026
Author
Services
Form
UPLOAD
Company
COTY INC.

Letter

Re: COTY INC. Form 10-K for the Year Ended June 30, 2025 Form 10-Q for the Period Ended December 31, 2025 File No. 001-35964 Dear Laurent Mercier:

February 26, 2026

Laurent Mercier Chief Financial Officer COTY INC. 350 Fifth Avenue New York, NY 10118

We have reviewed your filing and have the following comment.

Please respond to this letter within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe a comment applies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this letter, we may have additional comments.

Form 10-Q for the Period Ended December 31, 2025 Critical Accounting Policies, page 60

1. You disclose, there have been no material changes to the items disclosed as critical accounting policies and estimates, including goodwill, since the disclosure in the Form 10-K. Please expand your disclosure to address the subsequent substantial decrease in market capitalization and the impact on your assessment of the likelihood of future material goodwill impairment charges. Tell us and disclose your consideration of ASC 350-20-35-30 and the need to perform a more recent impairment test. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Please contact Nudrat Salik at 202-551-3692 or Jeanne Baker at 202-551-3691 if you have questions regarding comments on the financial statements and related matters. February 26, 2026 Page 2

Sincerely,
Division of Corporation Finance
Office of Industrial Applications and
Services

Show Raw Text
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<TEXT>
 February 26, 2026

Laurent Mercier
Chief Financial Officer
COTY INC.
350 Fifth Avenue
New York, NY 10118

 Re: COTY INC.
 Form 10-K for the Year Ended June 30, 2025
 Form 10-Q for the Period Ended December 31, 2025
 File No. 001-35964
Dear Laurent Mercier:

 We have reviewed your filing and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-Q for the Period Ended December 31, 2025
Critical Accounting Policies, page 60

1. You disclose, there have been no material changes to the items
disclosed as critical
 accounting policies and estimates, including goodwill, since the
disclosure in the Form
 10-K. Please expand your disclosure to address the subsequent
substantial decrease in
 market capitalization and the impact on your assessment of the
likelihood of future
 material goodwill impairment charges. Tell us and disclose your
consideration of ASC
 350-20-35-30 and the need to perform a more recent impairment test.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

 Please contact Nudrat Salik at 202-551-3692 or Jeanne Baker at
202-551-3691 if you
have questions regarding comments on the financial statements and related
matters.
 February 26, 2026
Page 2

 Sincerely,

 Division of Corporation Finance
 Office of Industrial Applications and
 Services
</TEXT>
</DOCUMENT>