Marking the first comprehensive update in eight years, the SEC’s Division of Enforcement (the Division) released a revised edition of its Enforcement Manual (the 2026 Manual). SEC Chairman Paul Atkins called the update a “long-overdue step,” and Division Director Margaret Ryan said the changes are intended to “ensure greater uniformity” and “reflect the Division’s best practices.” Although the 2026 Manual has many changes from the previous version, some will have a greater impact. In this article, we highlight the most significant revisions and discuss their practical implications.

New York recently expanded its algorithmic pricing laws, now requiring retailers to disclose when prices are set with algorithmic software based on consumers’ personal data.The so-called practice of surveillance pricing entails adjusting prices charged for goods and services according to monitored personal data.

Following the August 5, 2024, decision in United States v. Google where the D.C. District Court found Google to be a monopolist, Judge Amit Mehta issued what would end up being the first remedies opinion on September 2, 2025. The decision establishes a six-year framework designed to promote competition in the general search engine market.