93% of FY 2025 actions were filed before the SEC administration change.
NEW YORK, Nov. 19, 2025 /PRNewswire/ — The U.S. Securities and Exchange Commission (SEC) brought 30% fewer enforcement actions against public companies and subsidiaries in FY 2025 than in FY 2024—a decline that coincided with the change in SEC administration. The findings, presented in the SEC Enforcement Activity: Public Companies and Subsidiaries—Fiscal Year 2025 Update released today by Cornerstone Research and the NYU Pollack Center for Law & Business, are based on SEC data available as of November 14, 2025.
While a decline aligns with previous years in which there was an SEC administration change, FY 2025 stood out for its composition: outgoing Chair Gary Gensler oversaw 52 actions (93%), while only four were initiated under the new SEC administration—the highest and lowest respective totals for outgoing and incoming chairs during a transition year since at least FY 2013. After Chair Gensler stepped down in January 2025, Mark Uyeda served as acting chair until April when Chair Paul Atkins was sworn in.
“What’s striking this year is not the overall decline, but when the actions occurred,” said 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. “Nearly all of this enforcement activity took place before the SEC administration change, with very few actions under the new administration. Our analysis helps us see the timing and composition of activity in ways that overall totals alone may not reveal.”
“We’ve historically seen declines in enforcement activity during SEC leadership transitions, and FY 2025 aligned with those patterns,” said Sara Gilley, a report coauthor and cohead of the Cornerstone Research securities litigation practice. “Even within that overall decline, the year stood out for its record highs and lows and the unusually low monetary settlements observed.”
The report analyzes information from the Securities Enforcement Empirical Database (SEED), which has tracked SEC enforcement actions filed against public companies and subsidiaries since FY 2010—a period that has seen four changes in SEC administrations. In addition to record activity levels, FY 2025 was notable for lower overall monetary settlements—$808 million, the lowest for any year in which there was an SEC administration change and the second lowest for any year in SEED. FY 2025 also included the SEC’s February 2025 dismissal of its civil action against Coinbase, the first such dismissal in SEED amid the agency’s ongoing reassessment of its approach to cryptocurrency oversight.
Additional Highlights:
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Chair Atkins to Focus on Issuer Reporting and Disclosure : Three of the four actions initiated against public companies and subsidiaries after Chair Gensler’s departure involved Issuer Reporting and Disclosure allegations. This is expected to continue into FY 2026. In his May 2025 remarks, Chair Atkins signaled his administration would “return” to the “core mission that Congress set” for the SEC—prioritizing “protecting investors; furthering capital formation; and safeguarding fair, orderly, and efficient markets.”
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Final Off-Channel Communications Sweep Under Chair Gensler: The SEC initiated nine actions in January 2025 as part of Chair Gensler’s off-channel communications sweep—an area that Chair Atkins indicated interest in addressing in remarks made in October 2025.
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Cooperation and Admissions of Guilt Continued Under Chair Gensler: The SEC noted cooperation by 73% of public company and subsidiary defendants that settled in FY 2025, higher than the FY 2016–FY 2024 average of 65%—reflecting the SEC’s continued emphasis on cooperation under Chair Gensler.
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Record-Low Disgorgement and Prejudgment Interest: The total amount of disgorgement and prejudgment interest ($108 million) was the lowest in any fiscal year in SEED—more than $300 million below the next-lowest total in FY 2012.
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Civil Penalties Continued in Administrative Proceedings: FY 2025 civil penalties for administrative proceedings accounted for the highest percentage of the total monetary settlement for any fiscal year in SEED.
About the Securities Enforcement Empirical Database
The Securities Enforcement Empirical Database (SEED) tracks and records information for SEC enforcement actions filed against public companies traded on major U.S. exchanges and their subsidiaries. Created by the NYU Pollack Center for Law & Business in cooperation with Cornerstone Research, SEED facilitates the analysis and reporting of SEC enforcement actions through regular updates of new filings and settlement information for ongoing enforcement actions. The variables tracked include defendant names and types, violations, venues, and resolutions.
About the NYU Pollack Center for Law & Business
Established in 1997, the NYU Pollack Center for Law & Business is a joint venture of the NYU School of Law and the Stern School of Business. Its mission is to enrich the teaching curriculum at both schools in areas where law and business intersect; to facilitate professional interaction and academic research by faculty who share an interest in the structure, regulation, and function of the market economy; and to contribute to the public welfare by supporting scholarship that assists governmental and private policymakers in their pursuit of enhanced business productivity.
About Cornerstone Research
Cornerstone Research provides economic and financial consulting and expert testimony in all phases of complex disputes and regulatory investigations. The firm works with an extensive network of prominent academics and industry practitioners to identify the best-qualified expert for each assignment. With a reputation for high quality and effectiveness, Cornerstone Research has consistently delivered rigorous, state-of-the-art analysis since 1989. The firm has more than 1,000 professionals in nine offices across the United States, UK, and EU.
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