On February 12, 2026, the Securities and Exchange Commission (SEC) released its Annual Report to Congress on the Dodd-Frank Whistleblower Program for Fiscal Year 2025, which detailed the millions of dollars awarded to nearly 50 individual whistleblowers who reported corporate misconduct and assisted with the ensuing government investigations. This year’s report highlighted important enforcement activity, but with some notable shifts compared to prior years.
How much did the SEC pay whistleblowers and how did that compare to prior years?
In FY2025, the SEC awarded more than $60 million to 48 whistleblowers. This was a notable decline from the $255 million awarded in FY2024. Nevertheless, actual disbursements made in FY2025 remained significant. According to the SEC’s 2025 Agency Financial Report (AFR), which set out the Commission’s overall financial and operational performance during the fiscal year, the SEC paid whistleblowers $171 million in 2025. That included $110.3 million for amounts awarded before 2025 and $59.9 million for awards made in FY2025.
More important, as we noted in an earlier article A Sharp Decline in SEC Whistleblower Awards? Don’t Let the Accounting Fool You, the SEC reported in the AFR that the range of “probable” awards in the pipeline is $218 million to $654 million, depending on the percentage the Commission awards to eligible whistleblowers. Alongside the SEC’s announcement that it made 82 Preliminary Determinations recommending awards, we are optimistic about the Program’s impact in the year ahead.
Why the slow down in SEC whistleblower awards?
Apart from the shift in enforcement priorities that is common under a new Administration, across the board, federal law enforcement is working to do a whole lot more with a whole lot less. In FY2025, as the SEC tackled a 17% decline in headcount, the whistleblower office fielded 27,000 tips, an 8% increase over the prior year. Sifting through submissions, assigning to enforcement staff, commencing an investigation, embarking on award determinations and processing payouts and appeals…it’s an enormous undertaking. That said, the agency recently has brought on senior enforcement staff and we are confident the office will announce more recoveries in the months ahead.
What does the backlog in awards mean for whistleblowers?
As the eyes and ears of federal law enforcement, the Commission needs whistleblowers more than ever. Given the logjam, the submissions most likely to garner investigative attention address significant securities violations, with evidentiary documents and other items that materially strengthen a case.
There are two important caveats here. First, timing matters. Wherever possible, whistleblowers should provide early and actionable intelligence so the SEC can take swift action to protect investors. In FY2025, the Commission reduced eight awards for an unreasonable delay in reporting. By comparison, in the prior year, the Commission reduced three awards for an unreasonable delay.
Second, gathering evidence is a complex undertaking that is fraught with risk. It is advisable to speak to an experienced SEC whistleblower attorney who can help navigate this tricky terrain to best position a case for review.
What are the most common securities violations that whistleblowers reported last year?
In FY 2025, the Commission received approximately 27,000 whistleblower tips. The most common complaint categories reported by whistleblowers were Manipulation (28%), Offering Fraud (27%), Corporate Disclosures and Financials (11%), and Cryptocurrencies and Crypto Asset Securities (7%).
This was relatively similar to the prior year, in which the most common complaint categories reported by whistleblowers were Manipulation (37%), Offering Fraud (21%), Initial Coin Offerings and Crypto Asset Securities (8%), and Corporate Disclosures and Financials (8%).
Where are the whistleblowers?
While the majority of SEC whistleblower tips originated in the United States (the SEC did not specify which states generated the highest number of submissions), international whistleblowers continued to observe and report financial fraud. In FY 2025, the foreign jurisdictions producing the highest number of tips were Canada, the United Kingdom, Italy, Germany, and China. In the prior year, the foreign countries from which the highest number of tips originated were Canada, the United Kingdom, India, Australia, and Germany. Domestically, the states from which the highest number of tips originated were South Carolina, Florida, California, Texas, and New York.
Should you have additional questions about the FY2025 SEC Whistleblower Program results, we’re here to help. The attorneys in our Whistleblower and Retaliation practice combine decades of experience defending employees from retaliation and prosecuting SEC whistleblower cases, including many that have established precedent, and resulted in record-setting whistleblower awards. Please feel free to contact our practice leaders, Tammy Marzigliano and Dave Jochnowitz, for more information.
