2026 Comment letters report
The regulatory landscape is shifting and the SEC's comment letter process is one of the clearest signals of where scrutiny is focused. This report, powered by Ideagen Audit Analytics' proprietary comment letter database, tracks a decade of conversations between the SEC and registrants. It breaks down the issues that repeatedly trigger reviews, how that focus is changing and what it means for your disclosures going forward.
Whether you advise public companies, assess regulatory risk or prepare filings yourself, this is the data that keeps you ahead. Download the full report to see exactly where the SEC's focus is landing and what it means for you.
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Non-GAAP metrics remain firmly in the spotlight
Non-GAAP measures has led all issues for the majority of the past decade. The SEC continues to challenge how companies reconcile, label and present these metrics, and the scrutiny shows no signs of easing.
Comment letter conversations are taking longer to resolve
The average length of a comment letter conversation reached a 10-year high in 2025. More complex issues and wider gaps between company and SEC staff perspectives are driving reviews that take longer, and cost more to navigate.
The SEC is now looking beyond your filings
Earnings calls and investor presentations are increasingly part of the SEC's review process. If the metrics you discuss publicly don't match what's disclosed in your filings, you may already be on their radar.
Segment reporting is the disclosure issue to watch
Financial statement segment reporting jumped to the top of the accounting issues list in 2025, nearly doubling its historical share. Companies are still adapting to the new requirements under ASU 2023-07, and the SEC is actively reviewing compliance.
2026 Comment letters report
Download the full report today.