A Sharp Decline in SEC Whistleblower Awards? Don’t Let the Accounting Fool You

Whistleblower Blog

DATE

January 21, 2026

While we eagerly await the Securities and Exchange Commission’s 2025 Annual Report to Congress on the Dodd-Frank Whistleblower Program, we already know a lot about what that report is going to say. Despite some recent concerns about the health of the Program, we expect quite a bit of good news for past and future whistleblowers.

To be sure, the FY2025 “awards issued” number is down to a multi-year low of approximately $60 million. That annual figure has grabbed headlines, especially when compared with the eye-popping results of almost $600 million in FY2023 and $255 million in FY2024. But this is decidedly not a ‘sky is falling’ moment. In fact, the SEC’s 2025 Agency Financial Report (AFR) tells a far different story. In the AFR, which sets out the Commission’s overall financial and operational performance during the fiscal year, the SEC paid whistleblowers $171 million in 2025. That includes $110.3 million for amounts awarded before 2025 and $59.9 million for awards made in FY2025.

More importantly, the AFR suggests time will favor the brave. The range of what the SEC refers to as “probable” awards already in the pipeline is between some $218 million to $654 million. The significant range in the probable awards reflects the 10% – 30% the Commission can, by statute, award an eligible whistleblower.

What accounts for this discrepancy between awards paid and “probable” future awards? For one thing, SEC investigations, determining award eligibility, and processing awards are herculean efforts. Yet according to the AFR, SEC headcount is down 17% since the start of the fiscal year. With thousands of tips to assess, the SEC has had to do more with less. Bottlenecks will happen. It looks like one of those bottlenecks is, unfortunately, in the whistleblower award process. That said, with new senior enforcement staff in place, hopefully this logjam will start to break and FY2026 will return to better results and more positive headlines. In the meantime, the Commission needs whistleblowers more than ever, particularly those who come forward with submissions that report, with strong evidentiary support, major fraud. This is a shared fight, and the SEC knows it.

In addition to these “probable” future awards, there are other reasons for optimism:

The Commission remains focused on fraud. In addition to several media statements that investor protection and the fight against fraud remain a priority, Chair Atkins underscored this point in his AFR opening message: “Investor protection—holding accountable those who lie, cheat, and steal—is vital to our mission, for while capital markets thrive on many factors, they endure on trust.”
Legislative fixes may be on the way. The bipartisan SEC Whistleblower Reform Act of 2025 would speed claim processing and expand whistleblower protections—both critical for maintaining confidence and reducing award cycle payment delays.
The SEC continues to staff top enforcement positions, including Judge Margaret Ryan as Director of the Division of Enforcement and Paul Tzur and David Morrell as Deputy Directors. These seasoned authorities will surely drive renewed enforcement efforts into 2026.

So, while we await the 2025 Office of the Whistleblower annual report, and fully expect a sharp decline in awards from the 2024 numbers, we remain optimistic that whistleblower submissions already in process will be rewarded as Congress intended.

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Dave Jochnowitz

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