Ideagen/Audit Analytics recently issued its 2026 report on comment letter trends. The report looks at comment letters issued during the period from 2016-2025. Here are some of the highlights:

– The total number of comment letter conversations referencing periodic filings declined overall in the past 10 years. However, prior to 2025, there had been a slight rebound in the trend. Total conversations were at their highest in 2016, with 1,485 conversations started, and dipped to a low of 545 in 2021. In 2022, there was a nearly 76% increase in comment letter conversations from 2021, the highest amount seen since 2017. Conversations remained elevated in 2023 at 1,074 before declining to 975 in 2024. The 2025 figure of 423 conversations reflects data disseminated through March 6, 2026; conversations initiated in the later part of 2025 may not yet be publicly available, which may account for the lower volume relative to prior years.

– For 2025, results of operations was the leading issue, referenced in 140 conversations and comprising 33% of all conversations started during the year. This figure combines references to both the results of operations disclosure topic and SEC Release No. 33-8350, which addresses the same MD&A guidance. Financial statement segment reporting was the second most common issue in 2025, appearing in 117 conversations and 28% of all conversations — nearly double its 14% share over the full ten-year period — likely driven by the implementation of ASU 2023-07. Non-GAAP measures, which has led this list for the majority of the period, ranked third in 2025 at 26% of conversations.

– For 2025, segment reporting emerged as the leading accounting issue, cited in 117 conversations and 38% of all conversations that included an accounting issue — a significant shift from its third-place position over the full period. Revenue recognition ranked second at 23% of accounting conversations. Research and development issues ranked third in 2025 at 12% of accounting conversations, reflecting increased SEC scrutiny of R&D capitalization and clinical-stage company disclosures, particularly in the Life Sciences sector. Fair value measurement, which ranked first over the ten-year period, did not appear in the 2025 top 10, indicating a notable shift in SEC staff focus.

The report goes into detail about the Staff’s comments on segment reporting and revenue recognition, and notes that the sharp increase in segment reporting comments in 2025 continues a trend that began following implementation of ASU 2023-07 in 2024, and reflects the fact that companies are still adapting their disclosures to the new standard, and the Staff is actively reviewing their efforts. When it comes to revenue recognition, many Staff comments focus on how companies recognize revenue, but many also address disclosure issues relating to disaggregation of revenue information required under ASC 606-10-55-89 through 91.

– John Jenkins