Actions decline 71% in largest year-over-year drop recorded; monetary settlements also hit record low.
NEW YORK, Nov. 12, 2026 /PRNewswire/ -- 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," 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."
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.
Additional Highlights
- Civil actions represented a larger share of enforcement activity. The SEC brought four of the 16 actions, or 25%, as civil actions, the highest percentage since FY 2013.
- Fewer defendants received monetary settlements. 63% of settling defendants had a monetary settlement, the lowest share since FY 2010 and well below the FY 2017–FY 2025 average of 92%.
- Admissions of guilt returned to their earlier historical pattern. No public company or subsidiary defendant admitted guilt in FY 2026, marking the first time since FY 2021.
- Disgorgement and prejudgment interest reached a record low. The combined total was $1 million, approximately $100 million below the previous low in FY 2025. These amounts represented 1% of total monetary settlements, also a record low.
- Civil penalties accounted for nearly all monetary settlements. Civil penalties represented 99% of total monetary settlements, the highest percentage recorded in SEED.
About the Securities Enforcement Empirical Database
The Securities Enforcement Empirical Database tracks and records information about SEC enforcement actions filed against public companies traded on major U.S. exchanges and their subsidiaries. Created by the NYU Pollack Center for Law & Business in cooperation with Cornerstone Research, SEED facilitates the analysis and reporting of SEC enforcement activity through regular updates covering new filings and settlement information for ongoing actions. The variables tracked include defendant names and types, allegations, venues, and resolutions.
About the NYU Pollack Center for Law & Business
Established in 1997, the NYU Pollack Center for Law & Business is a joint venture of New York University School of Law and the Stern School of Business. Its mission is to enrich the teaching curriculum at both schools in areas where law and business intersect; facilitate professional interaction and academic research by faculty who share an interest in the structure, regulation, and function of the market economy; and contribute to the public welfare by supporting scholarship that assists governmental and private policymakers in their pursuit of enhanced business productivity.
About Cornerstone Research
Cornerstone Research is at the forefront of economic and financial consulting, delivering the rigorous analytical solutions required to navigate complex disputes. The firm draws from an extensive network of prominent academic and industry experts to support each matter effectively. Pairing a deep understanding of economics and finance with a suite of industry-leading artificial intelligence and machine learning tools, Cornerstone provides clients with a sophisticated, tailored approach. A reputation for innovation, precision, and excellence has defined Cornerstone since 1989. That momentum continues with over 1,000 professionals collaborating across nine offices in the US, UK, and EU.
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SOURCE Cornerstone Research
