Accounting and auditing enforcement actions (Actions) at the SEC plummeted to their lowest level in nine years in 2025.
Accounting and auditing enforcement actions (Actions) plummeted to their lowest level in nine years in 2025, the first year of Paul Atkins’s tenure as Chair of the Securities and Exchange Commission (SEC).1 The SEC initiated only 10 Actions—a 68% year-over-year decline compared to 2024, and just one-fifth of the annual average of the prior eight years.2 This decline is consistent with recent commentary by the Director of the Division of Enforcement, Margaret Ryan, who stated she is “far more concerned with the quality and impact” of investigations than with “chasing numbers.”3
The SEC initiated Actions against 11 respondents in 2025, representing a 71% decline from the 38 respondents in 2024.
The SEC initiated Actions against 11 respondents in 2025, representing a 71% decline from the 38 respondents in 2024. Monetary settlements also fell sharply to $31 million across 13 respondents, down from $907 million involving 54 respondents in 2024. Notably, almost all (98%) the $31 million of 2025 settlements was imposed during the three-week period between January 1, 2025, and Gary Gensler’s resignation as SEC Chair on January 20, 2025.4
2025 activity was markedly below the numbers of actions initiated during the prior two Chairs’ first years.
Only four of the 10 Actions in 2025 were initiated in the eight months following Chair Atkins’s swearing-in on April 21, 2025. While a change in administration is typically associated with a decrease in enforcement activity, 2025 activity was markedly below the numbers of actions initiated during the prior two Chairs’ first years. For comparison, 17 Actions were initiated in 2017 after Jay Clayton was sworn in on May 4, 2017, and 30 Actions were initiated in 2021 after Chair Gensler assumed the role on April 17, 2021.5
1 Jay Clayton was sworn in as Chair of the SEC on May 4, 2017 (https://www.sec.gov/news/press-release/2017-94), while Gary Gensler was sworn in as Chair of the SEC on April 17, 2021 (https://www.sec.gov/news/press-release/2021-65).
2 Accounting and auditing enforcement action data are collected from the SEC’s Accounting and Auditing Enforcement Releases (AAERs) available on the SEC’s website at https://www.sec.gov/enforcement-litigation/accounting-auditing-enforcement-releases. Note that the data included in the SEC Accounting and Auditing Enforcement Activity 2025 Year in Review are not comparable to prior editions of the report because the SEC’s Division of Enforcement did not release its annual report for fiscal year 2025.
3 “Year Initiated” is the calendar year in which an administrative proceeding was instituted or a civil action complaint was filed.
4 Margaret Ryan, Director, Division of Enforcement, “Remarks to the Los Angeles County Bar Association,” February 11, 2026, https://www.sec.gov/newsroom/speeches-statements/margaret-ryan-02-11-26-remarks-los-angeles-county-bar-association.
5 Hester M. Peirce, Caroline A. Crenshaw, Mark T. Uyeda, “Statement on the Departure of Chair Gary Gensler,” January 20, 2025, https://www.sec.gov/newsroom/speeches-statements/departure-gensler-012025.
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