{"url_path":"/sec/pgyww/10-k/2026/item-9a","section_key":"item-9a","section_title":"Item 9A Controls and Procedures","topic":"sec","document":{"doc_type":"10-K/A","doc_date":"2026-06-01","source_url":"https://www.sec.gov/Archives/edgar/data/1883085/0001883085-26-000036-index.html","accession_number":"0001883085-26-000036","cik":"0001883085","ticker":"PGY","issuer_name":"Pagaya Technologies Ltd.","edgar_url":"https://www.sec.gov/Archives/edgar/data/1883085/0001883085-26-000036-index.html","primary_entity_key":"0001883085","primary_entity_name":"Pagaya Technologies Ltd."},"word_count":741,"has_tables":true,"body_markdown":"Item 9A. Controls and Procedures\n\nDisclosure Controls and Procedures\n\nWe maintain disclosure controls and procedures (as that term is defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended) that are designed to ensure that information required to be disclosed in the Company’s reports under the Exchange Act is recorded, processed, summarized and reported within the time periods specified in the SEC’s rules and forms and that such information is accumulated and communicated to our management, including our Chief Executive Officer and Chief Financial Officer, as appropriate, to allow timely decisions regarding required disclosures. Any controls and procedures, no matter how well designed and operated, can provide only reasonable assurance of achieving the desired control objectives. Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, has evaluated the effectiveness of the design and operation of our disclosure controls and procedures as of December 31, 2025. Based upon that evaluation, our Chief Executive Officer and Chief Financial Officer concluded that, as of December 31, 2025, our disclosure controls and procedures were effective to accomplish their objectives at the reasonable assurance level.\n\nManagement’s Annual Report on Internal Control over Financial Reporting and Attestation Report of the Registered Public Accounting Firm\n\nOur management is responsible for establishing and maintaining adequate internal control over financial reporting as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act. In order to evaluate the effectiveness of our internal control over financial reporting, as required by Section 404 of the Sarbanes-Oxley Act of 2002, management has conducted an assessment,\n\n85\n\n[Table of](#iab92c5b483164dd6bfa8efca5afa979f_7)[Contents](#iab92c5b483164dd6bfa8efca5afa979f_7)\n\nincluding testing, of the Company’s internal control over financial reporting as of December 31, 2025, based on criteria established in Internal Control - Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”).\n\nInternal control over financial reporting is a process designed by, or under the supervision of, our principal executive and principal financial officers, or persons performing similar functions, and overseen by our Board of Directors, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles (GAAP) and includes those policies and procedures that:\n\n•pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of our assets;\n\n•provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that our receipts and expenditures are being made only in accordance with authorizations of our management and directors; and\n\n•provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of our assets that could have a material effect on the financial statements.\n\nThe effectiveness of any system of internal control over financial reporting is subject to inherent limitations, including the exercise of judgment in designing, implementing, operating, and evaluating the controls and procedures, and the inability to eliminate misconduct completely. Accordingly, any system of internal control over financial reporting, no matter how well designed and operated, can only provide reasonable, not absolute assurance, that its objectives will be met. In addition, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate due to changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. We intend to continue to monitor and upgrade our internal controls as necessary or appropriate but such improvements will be subject to the same inherent limitations outlined in this section.\n\nManagement has assessed the effectiveness of the Company’s internal control over financial reporting as of December 31, 2025. Based on that assessment, management has concluded that the Company’s internal control over financial reporting was effective as of December 31, 2025.\n\nOur independent registered accounting firm, Kost Forer Gabbay & Kasierer, a member of EY Global, has audited the effectiveness of the Company’s internal control over financial reporting as of December 31, 2025, as stated in their attestation report, which is included herein.\n\nChanges in Internal Control over Financial Reporting\n\nThere were no changes in our internal control over financial reporting (as such term is defined in Rules 13a-15(f) and 15d-15(f) under the Securities Exchange Act) that occurred during the quarter ended December 31, 2025 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.\n\n86\n\n[Table of](#iab92c5b483164dd6bfa8efca5afa979f_7)[Contents](#iab92c5b483164dd6bfa8efca5afa979f_7)"}