Resources / Glossary / Disclosure schedule

Disclosure schedule.

Aka. Disclosure letter · Schedules of exceptions

What is a disclosure schedule?

A disclosure schedule is the document — called a disclosure letter in some jurisdictions — in which the seller lists the specific exceptions to the representations and warranties it makes in the purchase agreement. A rep states a clean position; the schedule is where the seller carves out where reality differs. The two are read together to know what the seller has actually promised.

Its function is both protective and informational. By disclosing a fact against a rep, the seller qualifies that rep — so the buyer cannot later claim a breach for something it was told. At the same time, the schedule is one of the most candid documents in a deal: it is where the seller has to put on paper the litigation, the contract exceptions, the related-party arrangements, and the other facts the clean reps would otherwise contradict.

Because disclosure shifts known risk to the buyer, what goes on the schedule — and how it is worded — is negotiated as carefully as the reps themselves.

How the disclosure schedule works

The schedule is organized to track the representations it qualifies.

  1. Mapped to the reps. Each section of the schedule corresponds to a specific representation, listing the exceptions to that rep.
  2. Disclosed facts qualify the rep. A matter properly disclosed against a rep cannot be the basis for a later breach claim — the buyer was told.
  3. Negotiated for completeness and wording. The seller wants to disclose broadly to be protected; the buyer wants disclosures specific enough to actually understand the risk.
  4. Finalized at signing. The schedule is delivered with the agreement and, where there is a gap to closing, sometimes updated — itself a negotiated right.

Frequently asked.

4 questions
01 What's the relationship between the disclosure schedule and reps and warranties?

They are inseparable. The reps state clean positions; the disclosure schedule lists the exceptions. A representation can only be breached relative to what was disclosed against it, so you cannot understand what a seller has promised by reading the reps alone — you have to read them together with the schedule.

02 Why does the disclosure schedule protect the seller?

Because a fact properly disclosed against a rep cannot later be claimed as a breach. By putting an issue on the schedule, the seller informs the buyer of it, and the buyer takes the business knowing it. Disclosure shifts that known risk from the seller to the buyer.

This is why sellers push to disclose broadly and buyers push for disclosures specific enough to be meaningful.

03 What goes into a disclosure schedule?

The specific exceptions to the seller's representations: pending or threatened litigation, contracts with unusual terms or change-of-control provisions, related-party arrangements, exceptions to clean title, known compliance matters, and any other fact that would make a clean rep untrue. It is, in effect, the catalog of the business's known imperfections.

04 How does the disclosure schedule connect to diligence?

It is where diligence and the contract meet. The buyer's diligence informs which reps to ask for and how hard to scrutinize the schedule; the schedule, in turn, surfaces facts the buyer then investigates further. Together with the diligence record, it defines what the buyer knew at close — which matters for indemnity claims and sandbagging.

Keeping the schedule and the diligence behind it queryable after close lets the team trace any later issue back to whether, and how, it was disclosed.

Related terms

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