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Analysis of SEC Enforcement Actions in FY26

The Brattle Group has released a comprehensive report detailing the enforcement actions taken by the U.S. Securities and Exchange Commission (SEC) during fiscal year 2026 (FY26). The findings reveal a striking conclusion: although there was a notable spike in enforcement actions in the latter half of the fiscal year, the overall number remained significantly below historical averages.

In total, the SEC initiated 308 enforcement actions in FY26. This number reflects a staggering 57% decrease compared to the average of 710 actions recorded between fiscal years 2018 and 2025. The report indicates that while the SEC saw a rise from 93 actions in the first half of the year to a total of 215 in the latter half—including an impressive 99 actions in September alone—the annual total was still underwhelming when compared to the 2018-2025 period.

The authors of the report, Brattle Senior Associate Adrienna Huffman and Principal Jan Jindra, utilized data that spans back to FY18 to analyze SEC enforcement patterns. They highlighted several contributing factors to the year’s low enforcement figures, including a government shutdown, persistent staffing shortages, and shifts in leadership within the SEC’s Enforcement Division. According to Dr. Jindra, "Several developments shaped the context for enforcement this year... Filings increased substantially in the second half, particularly in September, but the annual total remained far below historical levels."

The report elaborates on the nature of the allegations made during these enforcement actions. It was found that for FY26, the most common allegation categories were Securities Offerings and Delinquent Filings, each accounting for 21.4% of total actions. Insider Trading also showed an interesting trend, marking its highest share since FY18 at 12.3%. However, there was a noticeable drop in actions directed at individual respondents, falling from 54.8% in the first half to 40.5% in the second half. This suggests a shift in focus or possibly the impact of the aforementioned factors.

Interestingly, while SEC announcements pointed to parallel criminal indictments in 7.5% of FY26 actions, a deeper dive into public records indicates that this figure might be as high as 16.9%, translating to approximately 52 actions.

Looking ahead, the Brattle Group analysts anticipate a modest rebound in SEC enforcement for FY27, projecting between 350 and 450 actions. Dr. Huffman noted, "Even at that level, activity would remain well below the FY18-FY25 average. The upcoming year will be critical in determining if the upward trend observed in September evolves into a sustained rise in filings."

The full report examining SEC enforcement activity in FY26 is accessible on the Brattle Group's official website, providing stakeholders and observers with valuable insights into the regulatory landscape and enforcement efficacy.

For further details, visit Brattle’s website.

About Brattle: The Brattle Group is a global economic consulting firm with expertise in finance and regulatory analysis. The company comprises over 550 professionals operating across North America, Europe, and the Asia-Pacific region. For more information about their services, visit brattle.com.