SEC Delinquent Filings Actions, Fiscal Year 2025
Actions against public companies and individuals for failing to file required periodic reports — 10-Ks and 10-Qs — with the SEC.
Year-Over-Year
Delinquent filer actions rose from 59 in FY2024 to 84 in FY2025 (up about 42%).
Notable Actions in FY2025
Ponzi scheme affecting roughly 2,700 investors and $400 million in losses.
SOURCE ↗Alleged Ponzi scheme affecting roughly 300 investors and more than $140 million.
SOURCE ↗$198 million crypto and forex fraud scheme with more than $57 million misappropriated.
SOURCE ↗What Changed in FY2025
Under Acting Chairman Mark Uyeda and then Chairman Paul Atkins, the Commission explicitly stepped back from the prior administration’s approach — characterizing roughly 95 off-channel-communications actions and $2.3 billion in associated penalties as a misallocation of Commission resources — and redirected toward fraud causing direct investor harm and individual accountability, with individuals charged in about 9 of 10 standalone actions.
Delinquent-filings actions are the SEC's most mechanical enforcement category and, for that reason, the one most useful as a pure base-rate signal rather than a fact-specific liability question. These are periodic sweeps against public companies and individuals who failed to file required 10-Ks or 10-Qs, and the SEC has run them at a fairly predictable cadence for years, revoking the registration of chronically delinquent issuers in batches. There is no contested merits question in the overwhelming majority of these matters — the filing either happened on time or it did not — which means the category behaves less like discretionary enforcement and more like an administrative compliance mechanism with enforcement teeth.
That mechanical quality has a direct duration implication: delinquent-filings matters resolve faster, on average, than any other SEC enforcement category, because there is little for either side to litigate once nonfiling is established. For a company that has fallen behind on periodic reporting — frequently a shell company, a small-cap issuer in financial distress, or a foreign private issuer navigating cross-border reporting timelines — the realistic exposure is registration revocation on a compressed timeline rather than a prolonged multi-year investigation. That is a materially different risk profile than the standalone-action or insider-trading categories, and treating it identically in a portfolio-level exposure model understates how quickly this specific risk resolves.
For insurers and funders with exposure to small-cap or distressed issuers, the delinquent-filings count is also a useful leading indicator of which companies are heading toward a liquidity or governance crisis before any other enforcement signal appears — a company that misses periodic filing deadlines is disclosing operational distress well before a standalone fraud investigation would surface the same underlying problem. Reading delinquent-filings volume alongside standalone-action volume in the same fiscal year gives a more complete picture of where SEC enforcement capacity is being allocated between compliance mechanics and substantive misconduct.
The resolution path here is narrow and largely predictable — registration revocation, sometimes preceded by a reinstatement opportunity if filings are brought current — which makes this category one of the cleaner applications of a calibrated duration-and-resolution model. Criterica Intelligence frames delinquent-filings data as an early operational-distress signal, not a discretionary enforcement risk, for the companies, insurers, and funders that need the earliest possible read on issuer health.
See How SEC Patterns Inform Duration IntelligenceDelinquent filer actions: 84, per SEC FY2025 enforcement results addendum (as of 2026-04-07).
Delinquent filer actions rose from 59 in FY2024 to 84 in FY2025 (up about 42%).
Paramount Management Group, LLC, et al.: Ponzi scheme affecting roughly 2,700 investors and $400 million in losses.
Under Acting Chairman Mark Uyeda and then Chairman Paul Atkins, the Commission explicitly stepped back from the prior administration’s approach — characterizing roughly 95 off-channel-communications actions and $2.3 billion in associated penalties as a misallocation of Commission resources — and redirected toward fraud causing direct investor harm and individual accountability, with individuals charged in about 9 of 10 standalone actions.
Figures on this page are drawn from official agency publications, cited individually below, and reflect the agency’s own reporting as of the date shown for each figure. They are not Criterica Intelligence model outputs, are not predictions, and are not a measure of any party’s legal exposure or liability. Agencies periodically revise prior-year figures; where a revision is known, both figures are shown with their sources. This page does not constitute legal, investment, or compliance advice.