Actions decline 71% in largest year-over-year drop recorded; monetary settlements also hit record low.
The U.S. Securities and Exchange Commission (SEC) initiated 71% fewer enforcement actions against public companies and subsidiaries in FY 2026 than in FY 2025. The 16 actions initiated in FY 2026 were the lowest fiscal year total recorded by the Securities Enforcement Empirical Database (SEED). The findings are presented in SEC Enforcement Activity: Public Companies and Subsidiaries—Fiscal Year 2026 Update, released today by Cornerstone Research and the NYU Pollack Center for Law & Business.
The decline from 56 actions in the prior fiscal year was the largest year-over-year change recorded in SEED, which started its tracking in FY 2010. Total monetary settlements also fell to a record low of $184 million, more than $600 million below the FY 2025 total.
The decline in both enforcement actions and monetary settlements was broad and significant.
“The decline in both enforcement actions and monetary settlements was broad and significant,” said Stephen Choi, a report coauthor and the Bernard Petrie Professor of Law and Business at New York University School of Law and Co-Director of the NYU Pollack Center for Law & Business. “But based on Chair Atkins’s statement that the SEC will emphasize quality enforcement over quantity, these results are not entirely surprising.”
“The SEC’s priorities under Chair Atkins are coming into focus,” said Sara Gilley, cohead of Cornerstone Research’s securities litigation practice and a report coauthor. “The continued attention on issuer reporting and disclosure, along with the increased proportion of public company and subsidiary actions with individuals as named defendants, provides an indication of where the Commission is concentrating its enforcement efforts.”
The SEC’s priorities under Chair Atkins are coming into focus.
In FY 2026, half of SEC actions against public companies and subsidiaries involved issuer reporting and disclosure allegations, up from 39% in FY 2025 and tied for the largest proportion in SEED. Additionally, individuals were named as defendants in a larger proportion of public company and subsidiary actions than in any of the prior 10 fiscal years. No actions involved Foreign Corrupt Practices Act (FCPA) allegations, making FY 2026 the first fiscal year in SEED without an FCPA action against a public company or subsidiary. By comparison, FCPA actions accounted for an annual average of 10% of actions from FY 2017 through FY 2025.
The report analyzes information from the Securities Enforcement Empirical Database, created by the NYU Pollack Center for Law & Business and Cornerstone Research. SEED identifies 1,065 enforcement actions initiated against 903 public companies and subsidiaries between October 1, 2009, and September 30, 2026.