Lexology January 23, 2026
Amid a year of significant disruption, the US Securities and Exchange Commission (SEC) initiated far fewer enforcement actions involving public company financial reporting, accounting irregularities, and issuer disclosures during the 2025 fiscal year. Nevertheless, with many challenges in the rearview mirror, the SEC’s Enforcement Division appears positioned for increased enforcement activity in 2026 – particularly as to public companies and executives in the pharmaceutical, life sciences, and healthcare industries.
Cases that the SEC brought during the transition – including activity in early 2026 – and public commentary reflect a strategy of highly selective enforcement. Although the SEC’s interest in pursuing significant corporate penalties is diminished, its stated emphasis on individual accountability creates heightened risk for individual executives and directors of...
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