A new report indicates that the U.S. Securities and Exchange Commission (SEC) brought 30% fewer enforcement actions against public companies and subsidiaries in fiscal year 2025 compared to fiscal year 2024. This decline coincided with the change in SEC administration, with Paul Atkins taking over as Chairman in April 2025 after being nominated by President Trump in December 2024 and confirmed by the Senate.
The findings are part of the "SEC Enforcement Activity: Public Companies and Subsidiaries—Fiscal Year 2025 Update" released by Cornerstone Research and the NYU Pollack Center for Law & Business on November 19, 2025. The report is based on SEC data available as of November 14, 2025. The Securities Enforcement Empirical Database (SEED) has tracked SEC enforcement actions against public companies and subsidiaries since fiscal year 2010, encompassing four changes in SEC administrations.
According to the report, nearly all enforcement activity in fiscal year 2025 occurred before the change in SEC administration. Specifically, outgoing Chair Gary Gensler oversaw 52 actions, which is 93% of the total, while only four actions were initiated under the new SEC administration. This marks the highest and lowest respective totals for outgoing and incoming chairs during a transition year since at least fiscal year 2013. Mark Uyeda served as acting chair between Gensler's departure in January 2025 and Atkins' swearing-in in April.
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, noted that the timing of the actions is a striking aspect of this year's data. Choi stated that the analysis helps reveal the timing and composition of activity in ways that overall totals alone may not. Sara Gilley, a report coauthor and cohead of the Cornerstone Research securities litigation practice, added that declines in enforcement activity have historically occurred during SEC leadership transitions, and fiscal year 2025 aligned with those patterns.
In addition to the decline in enforcement actions, fiscal year 2025 saw lower overall monetary settlements, totaling $808 million. This is the lowest amount for any year in which there was an SEC administration change and the second-lowest for any year in SEED.
Since assuming his role, Chairman Atkins has expressed his intention to refocus the SEC on its core mission: protecting investors, furthering capital formation, and safeguarding fair, orderly, and efficient markets. In line with this, three of the four actions initiated against public companies and subsidiaries after Gensler's departure involved Issuer Reporting and Disclosure allegations, and this is expected to continue into fiscal year 2026.
Furthermore, Chairman Atkins issued a statement in September 2025 to restore the SEC's prior practice of permitting a settling entity to request that the Commission simultaneously consider an offer of settlement and any related waiver request. This policy change aims to enhance efficiency and certainty in the settlement process.
Atkins has also initiated "Project Crypto" with the goal of applying "basic fairness and common sense in the application of the federal securities laws to crypto assets and related transactions". This includes creating a "token taxonomy" to delineate which cryptocurrencies would be considered securities, rooted in the Howey Test.
These shifts signal a potentially significant change in the SEC's approach to enforcement and regulation under Chairman Atkins, with a focus on traditional enforcement areas, investor protection, and adapting to emerging technologies.
