Make IPOs Great Again: What the SEC’s New Agenda Means for Small Companies Considering Going Public
In late 2025, SEC Chairman Paul S. Atkins signaled a major shift in the Commission’s policy agenda with a clear goal: “Make IPOs Great Again.” Chairman Atkins’ remarks, delivered at events such as the New York Stock Exchange and the Weinberg Center for Corporate Governance, were focused squarely on rejuvenating U.S. capital markets and reversing the long-standing decline in the number of publicly listed companies.
Why This Matters to You
Today’s public markets look very different from the markets of two or three decades ago. In 1997, there were roughly 7,800 U.S. exchange-listed companies; by 2025, that number had dropped to about 4,700. Meanwhile, many growing businesses are opting to stay private far longer — or indefinitely — due to the time, cost, and complexity associated with a traditional IPO.
If you’re a founder, CEO, or principal at a company that could benefit from access to public equity capital, Chairman Atkins’ agenda signals potential regulatory changes that could reduce barriers to going public, and reshape how IPOs are structured and executed.
The Three Pillars of “Make IPOs Great Again”
1. Tailored, Material Disclosure Requirements
A central theme in the Chairman’s agenda is scalability. Atkins has emphasized that the SEC’s disclosure rules have grown excessively complex, often requiring the same expansive disclosure from a company with a $250 million market value as from an enterprise many times larger.
Under the revitalization plan, the SEC is exploring:
Revisiting thresholds that distinguish between large and small filers so that disclosure requirements are scaled by size and maturity.
Rebuilding the IPO “on-ramp” established in the JOBS Act to allow newly public companies to phase into full compliance over a longer, predictable timeline — not just a single year.
A renewed focus on financial materiality, with the goal of ensuring that companies disclose what’s truly important to investors and avoid over-burdening them or issuers with immaterial information.
For a company considering an IPO, these changes MAY translate into lower costs and faster execution IF the proposed reforms ultimately translate into rule changes.
2. De-Politicizing Shareholder Engagement
Chairman Atkins has also voiced concern that corporate governance engagements such as proxy contests and shareholder proposals have become overly “politicized,” distracting management teams and increasing compliance costs without meaningful benefit to most shareholders.
The proposed reforms aim to realign proxy processes with core corporate matters such as director elections and major corporate decisions, rather than a wide array of social or activist proposals that may have little relevance to the company’s strategic direction.
For IPO aspirants, a clearer, more predictable governance landscape can mean reduced risk and greater confidence from institutional and retail investors alike.
3. Litigation Reform to Reduce Frivolous Claims
Perhaps one of the most cited concerns among executives contemplating public markets is securities litigation risk. Chairman Atkins’ agenda includes reforms targeted at:
Reducing frivolous securities lawsuits that can be highly disruptive and expensive for emerging public companies; and
Preserving avenues for meritorious claims so that investor protections remain meaningful.
While substantive litigation reform often requires coordination with Congress or judicial interpretation, increased clarity around the SEC’s position may shape how courts and defense counsel approach securities litigation going forward.
Practical Considerations for Companies Thinking About an IPO
While Chairman Atkins’ agenda may not yet be fully implemented as formal rulemakings, several near-term developments are worth watching:
Regulation S-K Overhaul: The SEC announced that it is soliciting public comments on comprehensive reforms to Regulation S-K — the core disclosure framework for public companies — with a focus on materiality and investor relevance.
Definition of Small Company: A reexamination of what constitutes a small or emerging company for regulatory purposes could materially affect disclosure burdens.
IPO On-Ramp Extensions: Allowing a longer transition period for newly public companies could make the timing and cost of an IPO more predictable and investor-friendly.
As a securities transactions attorney, I encourage companies considering a public offering to actively monitor these developments because policy changes could influence the timing, structure, and cost of an IPO more dramatically than in recent years.
Conclusion: A Potential Turning Point for Public Capital Formation
Chairman Atkins is pushing a meaningful conversation at the SEC: one that seeks to reinvigorate the U.S. public markets by tailoring disclosure obligations, refining corporate governance norms, and addressing litigation risk.
For founders and executives evaluating the transition from private to public, understanding the substance and direction of these regulatory proposals is critical. By aligning your IPO planning with potential reforms — particularly around material disclosures and compliance timelines — you position your company to seize the public markets opportunity as these policies take shape.
If your company is exploring the possibility of an IPO and wants expert guidance through the evolving SEC landscape, let’s talk.