Exhibit 5.1

 

		HUNTON ANDREWS KURTH LLP 600 TRAVIS, SUITE 4200 HOUSTON, TEXAS 77002-2929   TEL 713 • 220 • 4200 FAX 713 • 220 • 4285
		FILE NO: 106754.0000003

October 23, 2026

Walmart Inc.

1 Customer Drive

Bentonville, Arkansas 72716

Walmart Inc.

$750,000,000 5.050% Notes Due 2029

$500,000,000 5.150% Notes Due 2031

$1,000,000,000 5.350% Notes Due 2033

$750,000,000 5.550% Notes Due 2036

C$750,000,000 4.150% Notes Due 2030

C$2,000,000,000 4.450% Notes Due 2033

C$1,750,000,000 4.950% Notes Due 2038

C$500,000,000 5.250% Notes Due 2056

Ladies and Gentlemen:

Reference is made to the (i) Pricing Agreement, dated October 19, 2026, related to the USD Notes (as defined herein) (the “USD Notes Pricing Agreement”), between Walmart Inc., a Delaware corporation (the “Company”), and BNP Paribas Securities Corp., BofA Securities, Inc., Morgan Stanley & Co. LLC, Citigroup Global Markets Inc., Goldman Sachs & Co. LLC and Wells Fargo Securities, LLC, acting for themselves and as representatives of the other several underwriters named in Schedule I thereto (collectively, the “USD Notes Underwriters”), and the Underwriting Agreement, dated October 19, 2026, between the Company and the USD Notes Underwriters, incorporated by reference into the USD Notes Pricing Agreement (such Underwriting Agreement, together with the USD Notes Pricing Agreement, the “USD Notes Agreement”), and (ii) Pricing Agreement, dated October 19, 2026, related to the CAD Notes (as defined herein) (the “CAD Notes Pricing Agreement”), between the Company and Merrill Lynch Canada Inc., Scotia Capital Inc. and TD Securities Inc., acting for themselves and as representatives of the other several underwriters named in Schedule I thereto (collectively, the “CAD Notes Underwriters”), and the Underwriting Agreement, dated October 19, 2026, between the Company and the CAD Notes Underwriters, incorporated by reference into the CAD Notes Pricing Agreement (such Underwriting Agreement, together with the CAD Notes Pricing Agreement, the “CAD Notes Agreement,” and the CAD Notes Agreement, together with the USD Notes Agreement, the “Agreements”).

ATLANTA AUSTIN BANGKOK BOSTON BRUSSELS CHARLOTTE DALLAS DUBAI HOUSTON

LONDON LOS ANGELES MIAMI NEW YORK RICHMOND SAN FRANCISCO TOKYO TYSONS WASHINGTON, DC

www.Hunton.com

Walmart Inc.

October 23, 2026

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Further reference is made to: (i) the Registration Statement on Form S-3 (File No. 333-275878), which was prepared pursuant to the Securities Act of 1933, as amended (the “Securities Act”), and the rules and regulations of the Securities and Exchange Commission (the “Commission”) thereunder, was filed with the Commission on December 4, 2023, and upon filing with the Commission, became effective pursuant to Rule 462(e) under the Securities Act (the “Registration Statement”); (ii) the Prospectus, dated December 4, 2023, constituting a part of the Registration Statement, including the documents incorporated therein by reference at each pertinent time (the “Base Prospectus”); (iii) the Preliminary Prospectus Supplement related to the USD Notes, dated October 19, 2026, which supplemented the Base Prospectus and was filed with the Commission pursuant to Rule 424(b)(5) under the Securities Act on October 19, 2026 (the “USD Notes Preliminary Prospectus Supplement”); (iv) the Preliminary Prospectus Supplement related to the CAD Notes, dated October 19, 2026, which supplemented the Base Prospectus and was filed with the Commission pursuant to Rule 424(b)(5) under the Securities Act on October 19, 2026 (the “CAD Notes Preliminary Prospectus Supplement”); (v) the Final Term Sheet, dated October 19, 2026, relating to $750,000,000 aggregate principal amount of the Company’s 5.050% Notes Due 2029 (the “2029 Notes”), $500,000,000 aggregate principal amount of the Company’s 5.150% Notes Due 2031 (the “2031 Notes”), $1,000,000,000 aggregate principal amount of the Company’s 5.350% Notes Due 2033 (the “USD 2033 Notes”) and $750,000,000 aggregate principal amount of the Company’s 5.550% Notes Due 2036 (the “2036 Notes” and, collectively with the 2029 Notes, the 2031 Notes and the USD 2033 Notes, the “USD Notes”), which was filed with the Commission on October 20, 2026 pursuant to Rule 433 under the Securities Act (the “USD Notes Final Term Sheet”); (vi) the Final Term Sheet, dated October 19, 2026, relating to C$750,000,000 aggregate principal amount of the Company’s 4.150% Notes Due 2030 (the “2030 Notes”), C$2,000,000,000 aggregate principal amount of the Company’s 4.450% Notes Due 2033 (the “CAD 2033 Notes”), C$1,750,000,000 aggregate principal amount of the Company’s 4.950% Notes Due 2038 (the “2038 Notes”) and C$500,000,000 aggregate principal amount of the Company’s 5.250% Notes Due 2056 (the “2056 Notes” and, collectively with the 2030 Notes, the CAD 2033 Notes and the 2038 Notes, the “CAD Notes” and the CAD Notes, together with the USD Notes, the “Notes”), which was filed with the Commission on October 20, 2026 pursuant to Rule 433 under the Securities Act (the “CAD Notes Final Term Sheet”); (vii) the Prospectus Supplement related to the USD Notes, dated October 19, 2026, which supplemented the Base Prospectus and was filed with the Commission pursuant to Rule 424(b)(5) under the Securities Act on October 21, 2026 (the “USD Notes Prospectus Supplement”); (viii) the Prospectus Supplement related to the CAD Notes, dated October 19, 2026, which supplemented the Base Prospectus and was filed with the Commission pursuant to Rule 424(b)(5) under the Securities Act on October 21, 2026 (the “CAD Notes Prospectus Supplement” and, together with the USD Notes Prospectus Supplement, the “Prospectus Supplements” and each, a “Prospectus Supplement”); and (ix) the Indenture, dated as of July 19, 2005 (the “Original Indenture”),

Walmart Inc.

October 23, 2026

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between the Company and The Bank of New York Mellon Trust Company, N.A., as successor trustee under such indenture (in such capacity, the “Trustee”), as supplemented by the First Supplemental Indenture, dated as of December 1, 2006, between the Company and the Trustee (the “First Supplemental Indenture”), the Second Supplemental Indenture, dated as of December 19, 2014, between the Company and the Trustee (the “Second Supplemental Indenture”) and the Third Supplemental Indenture, dated as of June 26, 2018, between the Company and the Trustee (the “Third Supplemental Indenture” and, the Original Indenture as supplemented by the First Supplemental Indenture, the Second Supplemental Indenture and the Third Supplemental Indenture, the “Indenture”).

We have acted as counsel to the Company in connection with the offer and sale of the Notes by the Company.

In rendering this opinion, we have examined and relied upon, without independent investigation or verification, executed originals, counterparts or copies of: (i) (a) the Restated Certificate of Incorporation of the Company, executed October 25, 1988, as amended, and as in effect at all times during the period from October 26, 1988 to 12:10 am Eastern Time on February 1, 2018; (b) the Restated Certificate of Incorporation of the Company, executed January 31, 2018, as in effect at all times during the period from 12:10 am Eastern Time on February 1, 2018 to, but excluding, February 23, 2024; (c) the Restated Certificate of Incorporation of the Company executed January 31, 2018, as amended by the Certificate of Amendment to the Restated Certificate of Incorporation of the Company, executed February 23, 2024, as in effect at all times during the period from February 23, 2024 to, but excluding, June 4, 2026; (d) the Restated Certificate of Incorporation of the Company, executed June 4, 2026, as in effect at all times during the period from June 4, 2026 to, and including, the date hereof; and (e) the bylaws of the Company, as amended and as amended and restated from time to time, and in effect at all times, during the period from June 3, 1993 to, and including, the date hereof; (ii) the Registration Statement; (iii) the Base Prospectus; (iv) the USD Notes Preliminary Prospectus Supplement; (v) the CAD Notes Preliminary Prospectus Supplement; (vi) the USD Notes Final Term Sheet; (vii) the CAD Notes Final Term Sheet; (viii) the USD Notes Prospectus Supplement; (ix) the CAD Notes Prospectus Supplement; (x) the Indenture; (xi) the USD Notes Agreement; (xii) the CAD Notes Agreement; (xiii) the form of each of two global notes, one of which will be in the principal amount of $500,000,000 and one of which will be in the principal amount of $250,000,000, and each of which will be dated October 23, 2026 and payable to Cede & Co., as nominee of The Depository Trust Company, as the depositary for the USD Notes (the “USD Notes Nominee”), which global notes will represent the 2029 Notes being sold to the USD Notes Underwriters pursuant to the USD Notes Agreement (the “2029 Global Notes”); (xiv) the form of one global note, which will be in the principal amount of $500,000,000, and which will be dated October 23, 2026 and payable to

Walmart Inc.

October 23, 2026

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the USD Notes Nominee, which global note will represent the 2031 Notes being sold to the USD Notes Underwriters pursuant to the USD Notes Agreement (the “2031 Global Note”); (xv) the form of each of two global notes, each of which will be in the principal amount of $500,000,000, and each of which will be dated October 23, 2026 and payable to the USD Notes Nominee, which global notes will represent the USD 2033 Notes being sold to the USD Notes Underwriters pursuant to the USD Notes Agreement (the “USD 2033 Global Notes”); (xvi) the form of each of two global notes, one of which will be in the principal amount of $500,000,000 and one of which will be in the principal amount of $250,000,000, and each of which will be dated October 23, 2026 and payable to the USD Notes Nominee, which global notes will represent the 2036 Notes being sold to the USD Notes Underwriters pursuant to the USD Notes Agreement (the “2036 Global Notes” and, collectively with the 2029 Global Notes, the 2031 Global Note and the USD 2033 Global Notes, the “USD Global Notes”); (xvii) the form of one global note, which will be in the principal amount of C$750,000,000, and which will be dated October 23, 2026 and payable to CDS & Co., as nominee of CDS Clearing and Depository Services Inc., as the depositary for the CAD Notes (the “CAD Notes Nominee”), which global note will represent the 2030 Notes being sold to the CAD Notes Underwriters pursuant to the CAD Notes Agreement (the “2030 Global Note”); (xviii) the form of one global note, which will be in the principal amount of C$2,000,000,000, and which will be dated October 23, 2026 and payable to the CAD Notes Nominee, which global note will represent the CAD 2033 Notes being sold to the CAD Notes Underwriters pursuant to the CAD Notes Agreement (the “CAD 2033 Global Note”); (xix) the form of one global note, which will be in the principal amount of C$1,750,000,000, and which will be dated October 23, 2026 and payable to the CAD Notes Nominee, which global note will represent the 2038 Notes being sold to the CAD Notes Underwriters pursuant to the CAD Notes Agreement (the “2038 Global Note”); (xx) the form of one global note, which will be in the principal amount of C$500,000,000, and which will be dated October 23, 2026 and payable to the CAD Notes Nominee, which global note will represent the 2056 Notes being sold to the CAD Notes Underwriters pursuant to the CAD Notes Agreement (the “2056 Global Note” and, collectively with the 2030 Global Note, the CAD 2033 Global Note and the 2038 Global Note, the “CAD Global Notes” and the CAD Global Notes, together with the USD Global Notes, the “Global Notes”); (xxi) extracts from minutes of meetings of the Board of Directors of the Company pertinent to the matters addressed in this opinion letter; (xxii) certain written consents of the Executive Committee of the Board of Directors of the Company pertinent to the matters addressed in this opinion letter; (xxiii) the Series Terms Certificate Pursuant to the Indenture Relating to 5.050% Notes due 2029, dated as of October 19, 2026 (the “2029 Series Terms Certificate”); (xxiv) the Series Terms Certificate Pursuant to the Indenture Relating to 5.150% Notes due 2031, dated as of October 19, 2026 (the “2031 Series Terms Certificate”); (xxv) the Series Terms Certificate Pursuant to the Indenture Relating to 5.350% Notes due 2033, dated as of October 23, 2026 (the “USD 2033 Series Terms Certificate”); (xxvi) the Series Terms Certificate Pursuant to the Indenture

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October 23, 2026

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Relating to 5.550% Notes due 2036, dated as of October 19, 2026 (the “2036 Series Terms Certificate”); (xxvii) the Series Terms Certificate Pursuant to the Indenture Relating to 4.150% Notes due 2030, dated as of October 19, 2026 (the “2030 Series Terms Certificate”); (xxviii) the Series Terms Certificate Pursuant to the Indenture Relating to 4.450% Notes due 2033, dated as of October 19, 2026 (the “CAD 2033 Series Terms Certificate”); (xxix) the Series Terms Certificate Pursuant to the Indenture Relating to 4.950% Notes due 2038, dated as of October 19, 2026 (the “2038 Series Terms Certificate”); (xxx) the Series Terms Certificate Pursuant to the Indenture Relating to 5.250% Notes due 2056, dated as of October 19, 2026 (the “2056 Series Terms Certificate” and, collectively with the 2029 Series Terms Certificate, the 2031 Series Terms Certificate, the USD 2033 Series Terms Certificate, the 2036 Series Terms Certificate, 2030 Series Terms Certificate, the CAD 2033 Series Terms Certificate and the 2038 Series Terms Certificate, the “Series Terms Certificates”); and (xxxi) such other documents, records and certificates as we considered necessary or appropriate to enable us to express the opinions set forth herein. In all such examinations, we have assumed the authenticity and completeness of all documents submitted to us as originals and the conformity to authentic and complete originals of all documents submitted to us as photostatic, conformed, notarized or certified copies.

In rendering this opinion, we have assumed, without independent investigation or verification, that: (i) each natural person signing any document reviewed by us had the legal capacity to do so; (ii) each person signing in a representative capacity (other than on behalf of the Company) had the authority to sign in such capacity; (iii) each of the Agreements has been duly authorized and validly executed and delivered by the parties thereto other than the Company; (iv) at or prior to the time of delivery of the Global Notes, the authorization of the Notes and of each series of notes of which the Notes are a part, including the Series Terms Certificates, will not have been modified or rescinded and there will not have occurred any change in law affecting the validity or enforceability of the Notes; (v) the Global Notes executed and delivered by the Company as contemplated herein will be identical in form to the forms of the Global Notes examined by us as described herein; and (vi) (A) the Indenture is and, at the time of delivery of the Notes, will be the legal, valid and binding agreement of the Trustee, enforceable against the Trustee in accordance with its terms, (B) at the time of delivery of the Notes, the Indenture will continue to be the legal, valid and binding agreement of the Company, enforceable against the Company in accordance with its terms, and (C) the Indenture has been and will continue to be at all pertinent times qualified pursuant to the Trust Indenture Act of 1939, as amended.

Walmart Inc.

October 23, 2026

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As to certain facts material to our opinion, we have made no independent investigation or verification of such facts and have relied, to the extent that we deem such reliance proper, upon certificates of public officials, the Company and officers or other representatives of the Company and the representations of the Company in each of the Agreements.

Based on the foregoing and subject to the qualifications set forth below, we are of the opinion that, (i) with respect to the USD Notes, upon the execution of the USD Global Notes, the authentication of the USD Global Notes in accordance with the terms of the Indenture and the delivery of the USD Global Notes against payment therefor in accordance with the USD Notes Agreement, the USD Notes will constitute valid and binding obligations of the Company, enforceable against the Company in accordance with their terms, and will be entitled to the benefits of the Indenture, and (ii) with respect to the CAD Notes, upon the execution of the CAD Global Notes, the authentication of the CAD Global Notes in accordance with the terms of the Indenture and the delivery of the CAD Global Notes against payment therefor in accordance with the CAD Notes Agreement, the CAD Notes will constitute valid and binding obligations of the Company, enforceable against the Company in accordance with their terms, and will be entitled to the benefits of the Indenture.

The foregoing opinions are qualified to the extent that the enforceability of the Indenture, the Notes or any related document or instrument may be limited by or subject to the effects of bankruptcy, insolvency, moratorium, reorganization, liquidation, rearrangement, probate, conservatorship, fraudulent conveyance, fraudulent transfer or other similar laws (including court decisions) now or hereafter in effect relating to or affecting creditors’ rights and remedies generally or providing for the relief of debtors, general principles of equity (regardless of whether such remedies are sought in a proceeding in equity or at law) or public policy.

We note that the enforceability of specific provisions of the Indenture and the Notes may be subject to (i) standards of reasonableness and “good faith” limitations and obligations such as those provided in the New York Uniform Commercial Code and similar applicable principles of common law and judicial decisions and (ii) the course of dealings between the parties, the usage of trade and similar provisions of common law and judicial decision.

With respect to our opinions expressed above as they relate to provisions of the Original Indenture relating to debt securities denominated in a currency other than U.S. dollars, we note that (i) a New York statute provides that a judgment rendered by a court of the State of New York in respect of an obligation denominated in any such other currency would be rendered in such other currency and would be converted into Dollars at the rate of exchange prevailing on the date of entry of the judgment, and (ii) a judgment rendered by a federal court sitting in the State of New York in respect of an obligation denominated in any such other currency may be expressed in Dollars, but we express no opinion as to the rate of exchange such federal court would apply.

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October 23, 2026

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We express no opinion as to Section 3.12 of the Indenture or any other provision of the Agreements, the Indenture or the Global Notes (collectively, the “Transaction Documents”) providing for indemnity or reimbursement by any party against any loss in obtaining the currency due to such party under any of the Transaction Documents from a court judgment in another currency.

We express no opinion as to the enforceability of the severability clauses in Section 1.11 of the Original Indenture, Section 5 of the First Supplemental Indenture, Section 5 of the Second Supplemental Indenture, Section 5 of the Third Supplemental Indenture, Section 16 of the USD Global Notes or Section 18 of the CAD Global Notes or any provision of the Indenture or the Global Notes that purports to waive or not give effect to rights to notice, defenses, subrogation or other rights or benefits that cannot be effectively waived under applicable law, including Section 1.15 and Section 12.01 of the Original Indenture, Section 13 of the USD Global Notes and Section 15 of the CAD Global Notes. We express no opinion with respect to the enforceability of (i) the parenthetical clause in Section 8.07(i) of the Original Indenture relating to the limitations on the compensation of trustees or (ii) Section 12.01 of the Original Indenture, Section 13 of the USD Global Notes and Section 15 of the CAD Global Notes to the extent that any of those provisions purport to waive liability for violation of securities laws. We express no opinion as to any provision of the Indenture that purports to confer subject matter jurisdiction in respect of bringing suits, enforcement of judgments or otherwise on any federal court, to the extent such court does not otherwise have such jurisdiction.

The foregoing opinions are limited in all respects to matters under and governed by the federal laws of the United States of America, the laws of the State of New York and the General Corporation Law of the State of Delaware, as each is in force and effect as of the date of this opinion. We do not express any opinion as to the laws of any other jurisdiction.

We consent to the filing by you of this opinion as an exhibit to the Company’s Current Report on Form 8-K to be filed with the Commission on the date hereof and the incorporation by reference of this opinion letter into the Registration Statement, and we further consent to the use of our name under the caption “Legal Matters” in each Prospectus Supplement. In giving this consent, we do not admit that we are included in the category of persons whose consent is required under Section 7 of the Securities Act or the rules and regulations of the Commission promulgated thereunder. This opinion is expressed as of the date hereof, and we disclaim any undertaking to advise you of any subsequent changes in the facts stated or assumed herein or any subsequent changes in law.

Walmart Inc.

October 23, 2026

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