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SEC hits the brakes on accounting and auditing enforcement

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The Securities and Exchange Commission dramatically pulled back on accounting and auditing enforcement last year after two years in a row of increases under former SEC chair Gary Gensler, according to a new report.

The report, released Wednesday by Cornerstone Research, found that enforcement activity plummeted during Gensler’s final year leading the SEC before he stepped down on President Trump’s Inauguration Day. The report found that the SEC initiated 45 accounting and auditing enforcement actions in fiscal year 2024, a 46% decrease from FY 2023 and the lowest number since 2021. Approximately half of all the actions (22) were initiated in the fourth quarter of the fiscal year, and more than one-third were initiated in September, the last month of the SEC fiscal year. On the other hand, monetary penalties reached their highest levels since 2021.

The report echoes the findings of a report released last week by the Brattle Group that found a dropoff in enforcement activity against auditors by both the SEC and the Public Company Accounting Oversight Board in the second half of last year. The Supreme Court ruled in June against the SEC in the case of SEC v. Jarkesy, giving defendants the right to a jury trial rather than a hearing before the SEC’s in-house administrative law judges. The Cornerstone report noted that the SEC dismissed six administrative proceedings after the Jarkesy decision.

“In addition to a decrease in enforcement activity, the SEC dismissed six administrative proceedings in FY 2024 after the U.S. Supreme Court’s decision in SEC v. Jarkesy on June 27, 2024,” said Jean-Philippe Poissant, a report coauthor and cohead of Cornerstone Research’s accounting practice, in a statement Wednesday. “In contrast, the SEC imposed more than $770 million in monetary penalties in FY 2024, a 32% increase from FY 2023 and the highest total since 2021.”

The report also found that the number of actions initiated against U.S. respondents declined 56% in FY 2024, while those initiated against non-U.S. respondents increased 18%. The number of actions referring to an announced restatement and/or material weakness in internal control in FY 2024 was only nine, a whopping 78% decline from the 41 such actions in the prior two fiscal years.

The number of actions alleging violations of internal accounting controls decreased to its lowest level since FY 2021. Nonmonetary sanctions were imposed against 67% of the 33 individual respondents who settled their cases with the SEC in FY 2024. The SEC acknowledged that 25% (15 firms and two individuals) of the 67 respondents who settled with the commission in FY 2024 offered cooperation, undertook remedial efforts, and/or self-reported to the SEC, slightly down from 26% in FY 2023.

The report also compares the Gensler period (FY 2021–FY 2024) to a comparable period under Jay Clayton (FY 2017–FY 2020), who chaired the SEC during the first Trump administration. During the Gensler period, the SEC initiated an average of 60 enforcement actions per year, compared to 74 during the Clayton period. Settled actions declined under Gensler, dropping nearly 20% to an average of 66 settled actions per year, compared to 80 under Clayton. Trump has nominated Paul Atkins, a former SEC commissioner, to be the next chair, succeeding Gensler. In the meantime, the SEC is now being led by acting commissioner Mark Uyeda.

“Looking back to the last eight years, our analysis shows that enforcement actions with accounting and auditing allegations were less of a priority than other emerging allegations under Chair Gensler,” said Simona Mola, a report coauthor and principal at Cornerstone Research, in a statement. “In the four fiscal years of the Gensler period, the SEC accounting and auditing enforcement activity overall declined relative to the Clayton period in terms of total number of actions initiated or settled. The average total settlement amount per year during the Gensler period also declined to $647 million, down from $796 million imposed during the Clayton period.”

There were 75 total respondents in accounting and auditing enforcement actions initiated in FY 2024, a major decline from 111 respondents in FY 2023 and below the four-year averages under both Clayton (122) and Gensler (90).

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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