
The U.S. federal government officially shut down one month ago on October 1, 2025, after lawmakers failed to reach a funding agreement. The Securities and Exchange Commission (SEC) has since entered a period of severely limited operations, creating uncertainty for public companies, issuers, and compliance professionals.
While the SEC’s systems remain operational and continue to accept filings—including registration statements, periodic reports, and prospectuses—most staff functions are paused. The Division of Corporation Finance and other divisions will not review filings, provide comments, or respond to no-action or interpretive requests. The SEC will also be unable to declare registration statements effective during the shutdown. However, days during the shutdown continue to count as “business days” under SEC rules, meaning filing deadlines remain in effect.
With staff unavailable, routine regulatory support and interpretive guidance are on hold. Legal and compliance teams should exercise heightened caution and consult external counsel before proceeding with capital-raising activities. Investor relations and communications teams should proactively address stakeholder concerns about potential delays in approvals, licensing, or inspections, as well as any impacts on earnings or cash flow. Transparent disclosure and board oversight are critical, especially for companies relying on government contracts or regulatory sign-offs.
• Maintain timely filings despite limited SEC availability.
• Avoid material updates or offerings without ensuring compliance with disclosure obligations.
• Develop contingency and communication plans for extended disruptions.
• Monitor the SEC’s website for status updates and emergency contacts.
While shutdowns are typically temporary, the 2025 impasse highlights the need for companies to stay agile, transparent, and prepared for regulatory slowdowns that can affect both compliance timelines and market confidence.
For more information, visit the official SEC release of the updated Q & A regarding operations during the shutdown here.