This paper compares management and auditor going concern risk disclosure. It exploits a unique regulatory change in Japan that impacted the going concern risk disclosure practice. Prior to 2009, managers were directed to make financial statement note disclosure if they considered there was substantial doubt about the going concern status. The note disclosures were required to be audited. After 2009, substantial doubt disclosures by management are not audited and can be considered voluntary. We test whether going concern risk disclosure is enhanced by requiring managers rather than auditors to make the disclosure voluntarily. Analysis shows increased overall levels of going concern risk disclosure after the 2009 regulatory change, which is substantially attributable to voluntary disclosure in the Business Risk Section of annual reports. The results are of interest to regulators because they suggest that it is appropriate for managers to be assigned primary responsibility for going concern risk disclosure.