How far did SEC enforcement fall in 2025?
The SEC filed 456 enforcement actions in fiscal 2025, down from 583 the year before. That is a 22 percent drop.
Staff went the same way. The Enforcement Division had 1,302 full-time equivalent staff in fiscal 2025 and 1,114 enacted for fiscal 2026, about 14 percent fewer. The fiscal 2027 request asks for 1,168.
Operating funding went from $2.199 billion in fiscal 2025 to $2.149 billion in fiscal 2026. The Enforcement program's budget fell from $693 million to $607 million, per the SEC's fiscal 2027 budget request.
Firms hired for the 2021 to 2023 enforcement run. White-collar and SEC defense groups grew at firms with serious regulatory practices. Antitrust merger-review groups grew too. We think firms now carry more SEC defense capacity than the work supports, and most of that capacity faces lower demand than forecast. What work did arrive came later, and in other parts of the practice.
- Fiscal 2021697
- Fiscal 2022760
- Fiscal 2023784
- Fiscal 2024583
- Fiscal 2025456
- 2021
- Total actions
- 697
- Standalone actions
- 434
- 2022
- Total actions
- 760
- Standalone actions
- 462
- 2023
- Total actions
- 784
- Standalone actions
- 501
- 2024
- Total actions
- 583
- Standalone actions
- 431
- 2025
- Total actions
- 456
- Standalone actions
- 303
| Fiscal year | Total actions | Standalone actions |
|---|---|---|
| 2021 | 697 | 434 |
| 2022 | 760 | 462 |
| 2023 | 784 | 501 |
| 2024 | 583 | 431 |
| 2025 | 456 | 303 |
Where did regulatory defense work go in 2026?
The agencies moved resources more than they cut them. In May 2025 the Justice Department's Criminal Division narrowed its white-collar priorities to areas like health care fraud and trade fraud. We think some of the work that fed law firms in the last cycle went with it.
The SEC's fiscal 2025 release says about two-thirds of its standalone actions charged individuals. The FTC's 2026 to 2030 strategic plan, finalized in April 2026, calls protecting children online one of the most important consumer protection issues of our time.
SEC public-company enforcement and big merger review both slowed, and you can measure both. Labor antitrust is active. The Justice Department won its first wage-fixing conviction at trial in April 2025, and the FTC's plan names a Joint Labor Task Force. The FTC also amended its COPPA Rule in 2025.
Which regulatory practices are growing in 2026?
Children's privacy and data protection, in our searches. Labor and wage-suppression antitrust is active now that the Justice Department has a conviction. AI governance work is growing at the firms we talk to.
We think the firms that pulled back are the ones that scaled pure SEC and merger-review defense hardest in 2022 and 2023. The firms adding people are building investigations and compliance groups, or privacy and AI-governance groups. Corporate clients want proactive risk work more steadily than they need someone to fight an active case.
Which of those does your group do today? I'd ask that before anything else.
Which firms are overstaffed in regulatory practice?
We think it's the ones that added a row of SEC defense laterals between 2022 and 2024. The docket came in well under projection in some areas, and the firm is carrying that cost.
The first response in 2025 was to slow new hiring. Then senior associates moved out of pure enforcement defense. They went into compliance and investigations, or into privacy and AI. Junior-partner promotions thinned in the groups that hired hardest.
If you run a regulatory group, are you still hiring against 2022 enforcement numbers? I'd move senior associates into the work that is growing. Do it before promotions stall and your strongest people start taking calls.
Should a regulatory associate move firms in 2026?
It depends on the group. If you're in a heavy SEC or merger-review practice at a firm that overhired, one of two things is happening. The group is moving people into the growing work. Or it is holding them until enforcement picks back up. Both are happening right now. Which one you're in decides your next two years of assignments and your shot at promotion.
I would ask two questions. How many people in the group moved into privacy or AI work in the last year? How many are still staffed on enforcement defense? If you have depth in privacy or AI, 2026 may look very different from the headline.
Which of those two groups are you in? If you can't tell from the inside, I'd ask the staffing partner directly.