On September 4, 2025, the SEC’s Spring 2025 “Unified Agenda of Regulatory and Deregulatory Actions” was released, accompanied by a statement from Chairman Paul S. Atkins.

In his statement, Chairman Atkins affirmed that the Spring 2025 agenda, his first as Chairman, reflects a “new day” at the SEC and represents the SEC’s renewed focus on innovation, capital formation, efficiency and investor protection. For those who have followed previous statements made by Chairman Atkins and his predecessor, then-Acting Chairman Mark T. Uyeda, the areas of focus in the updated agenda will come as no surprise. Namely, the Spring 2025 agenda includes potential rule proposals related to the regulatory framework for offers and sales of crypto assets to provide greater certainty to the market. This follows the establishment of a Crypto Task Force earlier this year as well as other actions to advance a regulatory framework for crypto assets, including the recently announced SEC “Project Crypto” and coordination among the SEC and the CFTC.

In addition, the Spring 2025 agenda covers the following topics, among others:

• Enhancement of Emerging Growth Company Accommodations and Simplification of Filer Status for Reporting Companies – potential amendments to current rules to expand accommodations available to emerging growth companies and to rationalize filer statuses to simplify the categorization of companies and reduce compliance burdens.
• Updating the Exempt Offering Pathways – potential amendments to current rules to facilitate capital formation and simplify the pathways for raising capital for, and investor access to, private businesses.
• Shelf Registration Modernization – potential amendments to current rules to modernize the shelf registration process to reduce compliance burdens and further facilitate capital formation.
• Rationalization of Disclosure Practices – potential amendments to current rules to rationalize disclosure practices to facilitate material disclosure by companies and shareholders’ access to such information.
• Shareholder Proposal Modernization – potential amendments to Exchange Act Rule 14a-8 to reduce compliance burdens for companies and account for developments since the rule was last amended.
• Rule 144 Safe Harbor – potential amendments to Rule 144, which had initially been proposed on January 19, 2021, to increase availability of the rule’s safe harbor. A second public comment period is scheduled to open in the spring of 2026.
• Foreign Private Issuer Eligibility – potential updates to the definition of a foreign private issuer (FPI) to account for developments within the FPI population and to better represent the issuers that the SEC intended to benefit from current FPI accommodations. In June 2025, the SEC issued a concept release soliciting public comment on the FPI definition.

With the exception of the Foreign Private Issuer Eligibility and Rule 144 Safe Harbor rulemakings, as discussed above, each topic is scheduled to open for initial public comment in the spring of 2026.

Equally noteworthy is what was withdrawn from the prior agenda. Referring to the misalignment between these proposals and the goal that regulation should be “smart, effective, and appropriately tailored within the confines of [the SEC’s] statutory authority,” Chairman Atkins confirmed the withdrawal of a number of items from the prior administration, including the proposed rules on Corporate Board Diversity, Human Capital Management Disclosure, and Regulation D and Form D Improvements, along with others.

The Spring 2025 agenda and related statement by Chairman Atkins emphasize the SEC’s continued focus on crypto assets and deregulation and simplification of rules that may have previously been burdensome on companies or not tailored to maximize investor protection.