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No official report of SEC enforcement activity for the fiscal year ended September 30, 2026 has been released so far, but we have some data on enforcement activity nonetheless from the Brattle Group and Covington. Kevin LaCroix recently summarized these reports on the D&O Diary blog. Overall, they found the total number of enforcement actions in the fiscal year was down, though it increased in the second half.

The Brattle Group’s report puts the number of FY 2026 SEC enforcement actions at 308, the lowest annual number of SEC enforcement actions since at least FY 2018, figures that the Covington law firm memo describes as “historically low enforcement numbers.” The Covington report also states that the FY 2026 numbers represent the “lowest SEC enforcement stats in over a decade.”

To be sure, SEC enforcement activity increased in the second half of FY 2026, with the agency bringing 163 actions in the second half of the fiscal year, compared to just 69 in the first half of the fiscal year. As the Covington memo notes, the higher number of enforcement actions in the second half of FY 2026 is “consistent with historical trends even as overall enforcement numbers have declined.”

The D&O Diary points to a number of factors contributing to this overall decline, including a recentering of enforcement cases on the Commission’s core mission, staffing levels, the government shutdown and leadership changes. The blog also highlights the concentration of cases in four of the nine common categories, with continued focus especially on insider trading and securities offerings.

During FY 2026, 88% of the SEC enforcement activity was concentrated in just four of the nine categories into which the SEC itself normally categorizes its activity. The four categories in which the activity was concentrated are securities offerings; issuer reporting and auditing; investment advisers and investment companies; and insider trading. By contrast, activity in these four categories represented 75% of the SEC’s FY 2025 enforcement activity, and 64% in FY 2024.

Activities in the other five categories (broker-dealers, market manipulation, the Foreign Corrupt Practices Act, municipal securities, and other matters) declined to only 12% of FY 2026 activity, compared to 25% in FY 2025, and 36% in FY 2024.

Kevin points out that a reduction in enforcement activity often means a reduction in private securities litigation because “historically at least 20% of securities class action litigation filings have followed in the wake of SEC enforcement actions” — especially FCPA cases.

– Meredith Ervine