On June 2, 2026, the SEC published a Draft Strategic Plan for fiscal years 2026 through 2030 and opened it for public comment through July 2, 2026. A strategic plan does not change any rule on its own, but it tells public companies where the agency is headed and which initiatives the Chairman intends to push forward. Not surprisingly, this one signals a clear focus on “modernizing and simplifying disclosure practices,” “enabling new capital-raising pathways,” and returning the SEC’s “enforcement approach to Congress’ original intent.”
What the Plan Says
Chairman Paul Atkins frames the plan around the SEC’s original three-part mission: protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. The plan builds on three goals.
- Renew the regulatory policy focus. The SEC wants clear, fit-for-purpose rules that support innovation and capital formation while deterring misconduct. It promises to modernize and simplify disclosure, expand access to private markets, and open new capital-raising pathways for entrepreneurs and small businesses. It also commits to update outdated rules that inhibit early-stage fundraising, streamline disclosure, refresh shelf registration, and enhance Regulation A.
- Shift regulatory practices. The SEC plans to engage more with businesses and industry groups. It will refocus enforcement on clear violations of established law, especially fraud and manipulation, rather than expanding its reach through ad hoc actions. It also commits to retrospective reviews of existing rules.
- Optimize operations. The SEC will reorganize internally, modernize legacy technology like EDGAR, and expand its responsible use of artificial intelligence.
How It Compares to the Prior Plan
The contrast with the FY 2022–2026 strategic plan adopted under Chair Gary Gensler is instructive. The mission statement stayed the same, and both plans stress technology, data, and the need to keep pace with changing markets. The priorities, though, have moved:
| Theme | FY 2022–2026 (Gensler) | FY 2026–2030 (Atkins) |
|---|---|---|
| Lead goal | “Protect the investing public against fraud, manipulation, and misconduct” | “Renew our regulatory policy focus to support innovation, capital formation, market efficiency, and investor protection” |
| Disclosure | “Modernize design, delivery, and content of disclosures” to reflect investor demand for information on “issuers’ climate risks, cybersecurity hygiene policies, and their most important asset: their people” | “Modernizing and simplifying disclosure practices”; “regulatory burdens must be carefully calibrated to avoid needless friction in the marketplace” |
| Capital Raising | “enhance transparency in private markets and modify rules to ensure that core regulatory principles apply in all appropriate contexts” | “facilitating access to public markets, modernizing outdated rules that inhibit early-stage fundraising, streamlining disclosure requirements, updating shelf registration processes, and enhancing Regulation A” |
| Enforcement | “The SEC must work to ensure the law is enforced aggressively and consistently” | “The focus must be on clear violations of established law—particularly fraud and manipulation—rather than on expanding regulatory reach through ad hoc enforcement actions” |
| Workforce/Operations | “Support a skilled workforce that is diverse, equitable, and inclusive and is fully equipped to advance agency objectives” | “Optimize our operational efficiency by enhancing our organizational structure, modernizing our technology, and fostering employee performance and accountability” |
Already Underway: Recent SEC Activity
The SEC has already begun its review of existing rules and acting on rulemaking aspects of the plan. The following are just some of the proposals and comment requests the Commission has published, with a focus on those that bear on public company disclosure and capital raising.
- Executive compensation disclosure (request for comment). In May 2025, the SEC announced a roundtable and requested public comment on the executive compensation disclosure requirements in Item 402 of Regulation S-K. For more on this topic, see our related client alert, available here (some aspects of executive compensation disclosure were addressed in the filer status reform noted below).
- Regulation S-K overhaul (request for comment). In January 2026, the SEC launched a comprehensive review of Regulation S-K and requested public comment on how to refocus disclosure on material information.
- Semiannual reporting (proposed rule). In May 2026, the SEC proposed letting domestic issuers replace quarterly Form 10-Q reports with a new semiannual Form 10-S. For more on this topic, see our related blog post, available here.
- Registered offering reform (proposed rule). In May 2026, the SEC proposed broadening Form S-3 shelf eligibility, replacing the WKSI framework and modernizing Form S-1. For more on this topic, see our related blog post, available here.
- Filer status reform (proposed rule). In May 2026, the SEC proposed collapsing five filer categories into two and raising the large accelerated filer threshold from $700 million to $2 billion. For more on this topic, see our related blog post, available here.
- IPO modernization (request for comment). In May 2026, the SEC requested public comment on ways to modernize the IPO process, including reforms to the Securities Act communication (or “gun-jumping”) rules and steps to ease non-traditional paths to going public such as direct listings.
- Climate disclosure rescission (proposed rule). In May 2026, the SEC proposed to rescind the 2024 climate disclosure rules in their entirety, calling them beyond its authority and unsound as policy.
These are not the only examples. The SEC has, among other actions, cleared the way for mandatory arbitration provisions, cut the minimum equity tender offer period to 10 business days for cash offers at a fixed price and rescinded its settlement “gag rule.” The SEC has also stepped back from the Rule 14a-8 no-action process, a step-back framed as temporary through September 30, 2026, though Chair Atkins has said “a fundamental reassessment of Rule 14a-8 is in order,” indicating the SEC could make the current hands-off approach permanent, amend the underlying rules, or repeal Rule 14a-8 entirely. Chairman Atkins and Division of Corporation Finance Director Moloney have indicated that still more proposals are on the way.
The 2025 concept release on the definition of “foreign private issuer” (FPI) sits somewhat apart from these other initiatives by raising the specter of potential regulatory tightening for this subpart of the issuer population. The SEC recently referred to its evaluation of the FPI definition as “ongoing” and spoke about the future completion of its “more comprehensive review of the FPI framework,” so we expect to see some rulemaking also in this area.
Takeaway
While the Draft Strategic Plan itself confirms the direction the SEC is already headed, the individual rulemaking proposals, each with its own comment period, offer public companies the most direct opportunity to weigh in on the specific issues of greatest interest to them. More broadly, boards and finance teams should continue monitoring the pace of rulemaking and working to understand how these proposals interact. The individual pieces are moving quickly, and their cumulative effect on disclosure obligations and capital-raising strategies will become clearer as more of them reach final form.