Securities Regulation Daily Wrap Up, ENFORCEMENT—Brattle Group report highlights the decline in SEC enforcement activity for FY 2025, (Nov 12, 2025)
Organizations Mentioned:The Brattle Group, Inc.
By R. Jason Howard, J.D.
SEC enforcement activity in FY26 will test whether the FY25 slowdown is likely the start of a ‘new normal’ at the Commission.
The Brattle Group has released a report titled SEC Enforcement Activity for Fiscal Year 2025: A Tale of Two Halves, which explores SEC enforcement activity during the Fiscal Year 2025 and highlights a 13 percent decline from Fiscal Year 2024 which marks an unprecedented slowdown in enforcement activity.
As stated in the press release, the report highlights a sharp divide between the first and second halves of the year which coincides with leadership changes at the Commission and the shifting priorities under the new SEC Chairman.
Some of the key findings from the report include, among others, that: the SEC initiated 506 enforcement actions, well below the average of 716 cases per fiscal year; the 144 cases initiated in the second half of FY25 were the fewest for any half-year analyzed; enforcement actions in the second half of the year showed notable variations from prior years, “with Securities Offerings cases nearly doubling, and cases involving the Foreign Corrupt Practices Act (FCPA), Issuer Reporting, and Broker-Dealer allegations declining”; and there was a record proportion of parallel criminal investigations in the second half of FY25.
The report also offers predictions about SEC activity in 2026, including “a further decline in enforcement activity, an increased proportion of cases involving individual respondents, an increased proportion of cases focused on capital formation, and an increased proportion of cases with parallel criminal indictments.”
SEC enforcement activity in FY26 will test whether the FY25 slowdown is likely the start of a ‘new normal’ at the Commission and "continued review of leadership priorities, resource allocation, and case mix will be critical to understanding the direction of enforcement in the year ahead," the report concludes.
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