New Brattle Report Finds SEC Enforcement Activity Remains Subdued in H1 FY26

SAN FRANCISCO, April 20, 2026 /PRNewswire/ -- According to a new report by Brattle Senior Associate Adrienna Huffman and Principal Jan Jindra, the US Securities and Exchange Commission (SEC) filed just 92 enforcement actions in the first half of fiscal year 2026 (H1 FY26) – a level well below historical averages and continuing the slowdown observed in the second half of FY25.

First Half of FY26 SEC Enforcement Activity: New Evidence of a Continued Slowdown examines enforcement trends during H1 FY26 (October 1, 2025 through March 31, 2026) and compares them to patterns observed between FY18 and FY25. The report provides an early, independent look at enforcement activity in FY26, including analysis by respondent type, allegation category, and the presence of parallel criminal indictments. It builds on and extends the SEC's FY25 enforcement results.

"Our analysis of enforcement activity in the first six months of FY26 suggests that the decline in enforcement activity observed in late FY25 – as documented in the SEC's recent announcement – has carried into FY26, and points to a potentially sustained shift in the SEC's enforcement baseline," said Dr. Jindra.

Key findings from the report include:

• The 92 enforcement actions filed in H1 FY26 are approximately 59% below the FY18–FY25 first-half average of 225 cases.
• Actions involving individual respondents alone reached a record high, accounting for more than half of all cases, while enforcement against non-individual entities fell to a record low 22% of all actions since FY18.
• Certain allegation categories, including Securities Offerings and Investment Advisers/Investment Companies, remained prominent, while others declined sharply relative to historical norms; notably, Foreign Corrupt Practices Act (FCPA) cases were absent.
• The share of cases involving parallel criminal indictments remained elevated relative to historical norms, though total volumes were low.
• Three notable settlements during H1 FY26 exceeded $10 million and reached as high as $40 million.

"Even at lower levels of activity, the composition of enforcement actions continues to evolve, with notable shifts in the types of cases being brought and who they target," said Dr. Huffman.

The report also examines factors that may have influenced enforcement activity, including leadership changes within the SEC, the impact of the late-2025 government shutdown, and evolving agency priorities.

The full report can be found on Brattle's website: https://www.brattle.com/insights-events/publications/first-half-of-fy26-sec-enforcement-activity-new-evidence-of-a-continued-slowdown/.

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SOURCE The Brattle Group