---
title: SEC Enforcement Actions Fell to a Nine-Year Low in Fiscal 2026, With a Third Filed in September
description: Brattle estimates the SEC filed 308 enforcement actions in fiscal 2026, 57% below average, with 99 in September, the last month of its fiscal year.
author: Darie Nani (Editor-in-Chief)
date: 2026-10-21T21:49:08.156Z
updated: 2026-10-21T21:49:08.164Z
canonical: https://www.sovereignmagazine.com/article/why-do-sec-enforcement-filings-spike-in-september
image: https://cdn.nanimediahouse.com/sec-headquarters-washington-467745.webp
categories: Legal
content_type: News
region: United States
publication: Sovereign Magazine
schema_type: Article
---

The Securities and Exchange Commission filed an estimated 308 enforcement actions in its 2026 fiscal year. That is 57% fewer than its average of 710 a year from fiscal 2018 through 2025, and the lowest total in at least nine years, according to [a report published Oct. 20 by the economics consultancy The Brattle Group](https://www.brattle.com/insights-events/publications/sec-enforcement-activity-for-fiscal-year-2026-a-september-pickup-amid-a-continued-slowdown/).

The SEC filed 99 of those actions in September, 32.1% of the year's total. September is the last month of the SEC's fiscal year, which runs from Oct. 1 to Sept. 30, and the agency counts its annual enforcement results to that date. From fiscal 2018 through 2025, September was the SEC's busiest month, with an average of 189 actions, or 26.6% of the annual count, by Brattle's figures.

The SEC has not yet published its own count for fiscal 2026, so Brattle built its estimate from the agency's litigation releases, administrative proceedings and press releases.

The annual count has now fallen for three straight years, from 783 in fiscal 2023 to 583 in fiscal 2024, 456 in fiscal 2025 and an estimated 308 in fiscal 2026.

## Second-Half Filings More Than Doubled After a Six-Week Government Shutdown

The federal government shut down from Oct. 1 to Nov. 12, 2025, the longest shutdown in US history, covering the first weeks of the SEC's fiscal year. The agency filed 93 actions in the first half of fiscal 2026 and 215 in the second. Only one second half in Brattle's data was lower, the 144 filed in the same period of fiscal 2025. The SEC filed more actions than a year earlier in five of the six months from April to September, but stayed below its fiscal 2018 to 2025 monthly averages in every one of them.

"Several developments shaped the context for enforcement this year, including the government shutdown, persistently low staffing levels, and a change in Enforcement Division leadership," said Jan Jindra, a Brattle principal and former assistant director at the SEC. Jindra wrote the report with Adrienna Huffman, a senior associate at the firm.

## The SEC's Enforcement Division Changed Leaders Twice During the Year

Margaret Ryan resigned as director of the SEC's Division of Enforcement in March 2026, and principal deputy director Sam Waldon was named acting director. David Woodcock took over the division on May 4. He was previously a partner at Gibson, Dunn & Crutcher, where he chaired the securities enforcement practice, and before that he spent nearly five years as director of the SEC's Fort Worth regional office. In February, the division announced its first update to its Enforcement Manual since 2017, including changes to investigative procedures, and updated its Wells process.

## SEC Leaders Say the Lower Case Count Reflects a Deliberate Shift Toward Fraud

When the SEC announced its fiscal 2025 results in April, it said enforcement resources had been "misapplied in prior years to pursue media headlines and run up numbers." Chairman Paul Atkins, under whom the agency had already [pulled back from crypto cases](https://www.sovereignmagazine.com/article/ripple-the-sec-and-washington-s-changing-crypto-playbook-in-2025) in 2025, said the SEC had redirected resources toward fraud, market manipulation and abuses of trust, and "away from approaches that prioritized volume and record-setting penalties over true investor protection." He said a key part of the change was "a renewed emphasis on holding individual wrongdoers accountable."

Woodcock addressed the falling numbers in a May 13 speech at the MFA Legal & Compliance conference in New York. "Let me be clear: this Commission has deliberately shifted toward an emphasis on quality over quantity, and I fully support that direction," he said.

By Brattle's count, actions naming only individuals, with no company as a respondent, made up 44.8% of fiscal 2026 cases, the highest share since fiscal 2020.

## Insider Trading Cases Held Steady While Other SEC Cases Fell

Insider trading cases made up 12.3% of actions in fiscal 2026. That is their highest share since fiscal 2018 and more than twice their average share of 5.0%. Brattle cautions that this "does not mean that there were twice as many insider trading cases." The SEC brought 26 civil-only insider trading actions, against an average of 25 a year from fiscal 2018 through 2025, so the count held roughly level while most other kinds of case fell. Insider trading was the only category whose count rose above its historical average.

Securities offering cases and delinquent filing cases were the most common types, at 21.4% of actions each. Delinquent filing cases rose from 4.3% of first-half actions to 28.8% in the second half, the largest share of any category in that period. Broker-dealer cases fell to a historically low share of 11.0%, and Brattle counted no Foreign Corrupt Practices Act cases.

## Brattle Estimates 52 SEC Cases Ran Alongside Criminal Charges

SEC announcements mentioned a parallel criminal indictment in 7.5% of fiscal 2026 actions, a historical low. Brattle searched public records and found parallel criminal charges in 16.9% of actions, or 52 cases. That share is the highest in Brattle's data, while 52 cases is a low total by historical standards. When the SEC's announcement did not mention the criminal case, the agency typically filed its civil case 66 days after the indictment.

## Brattle Forecasts 350 to 450 Enforcement Actions in Fiscal 2027

"We expect a partial rebound in FY27, with 350 to 450 enforcement actions compared with an estimated 308 in FY26," Huffman said. Even the top of that range is below the fiscal 2018 to 2025 average. "The coming year will show whether September's pickup develops into a more sustained increase in filings," she said.

Brattle expects offering fraud, insider trading, market manipulation and investment adviser cases to make up a larger share of actions in fiscal 2027. In his May speech, Woodcock listed his priorities as offering frauds, accounting and disclosure fraud, insider trading, market manipulation, fraud by foreign actors, and breaches of fiduciary duties by advisers misusing client assets. He said "these are the cases the Division intends to pursue aggressively during my tenure," and that the division would bring back its Retail Fraud Working Group.

In August, the SEC set up a Financial Reporting and Accounting Unit inside the Enforcement Division to pursue accounting and financial reporting fraud and auditor misconduct, led by Timothy Zimmerman. Because the unit is so new, Brattle expects it to add cases more slowly.

## FAQ

**Q: What are the latest official statistics on SEC enforcement actions?**
The latest official figures are for fiscal 2025, published on April 7, 2026: 456 enforcement actions, 303 of them standalone, and orders for $17.9 billion in monetary relief. For fiscal 2026, Brattle's figure of 308 is an outside estimate built from the SEC's public releases.

**Q: How did the rest of the SEC's fiscal 2026 caseload break down?**
Investment adviser and investment company cases were the third-largest category, at 17.9% of actions, by Brattle's estimate. Issuer reporting cases made up 10.1%.