The SEC initiated five actions, the lowest in the first half of a fiscal year in at least 16 years.
U.S. Securities and Exchange Commission (SEC) enforcement activity against public companies and subsidiaries continued at a slower pace in 1H FY 2026 with the SEC initiating five actions, the lowest in the first half of a fiscal year in at least 16 years.
The findings in this article are based on data from the Securities Enforcement Empirical Database (SEED), a collaboration between the NYU Pollack Center for Law & Business and Cornerstone Research.
- The five actions were a small uptick from the three actions initiated against public companies and subsidiaries in 2H FY 2025. Historically, the SEC files more actions in the second half of fiscal years.
- Three of the 1H actions included a public company defendant, and the other two included only a subsidiary defendant.
- Three actions, all filed against the public company and not a subsidiary, contained Issuer Reporting and Disclosure allegations. Over the past 10 fiscal years, Issuer Reporting and Disclosure allegations accounted for an average of 38% of actions filed annually.
- Enforcement actions involving Issuer Reporting and Disclosure allegations in 1H FY 2026 align with topics Chair Paul Atkins has discussed in public statements. For example, Chair Atkins stated “the SEC is returning its enforcement program to first principles of rooting out fraud and remedying investor harm” and that “[s]ince [he] rejoined the Commission last year, [the SEC has] brought enforcement actions to address … accounting and financial frauds.”
- The other two actions initiated in 1H FY 2026, each with a single subsidiary defendant, involved an investment advisor and an exchange.
- There have been three dismissals of actions against public companies and subsidiaries under the current administration, two in 1H FY 2026 and one in 1H FY 2025. No other public company or subsidiary action has been dismissed in at least 16 years.
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