Regulation Crowdfunding has moved roughly $2.9 billion into more than 6,000 U.S. companies since 2016. Every one of those issuers took on an ongoing disclosure obligation the day its offering closed, and half are no longer meeting it. Of the 5,383 issuers whose first annual report on Form C-AR has come due, 50.6% have filed one.
That number gets cited as evidence of mass non-compliance. Part of it is. But a new analysis built on CCLEAR, reconciled against the Commission’s own EDGAR filing manifests, finds that the headline figure blends several very different populations, and that the pattern underneath it runs in a direction almost nobody reports. Compliance rises in lockstep with the size of the investor base, from 33.4% among issuers with fewer than 100 investors to 89.0% among those with 1,000 or more, while silence falls the other way, from 45.9% to 7.8%. The gradient survives every control tested. It holds across vintage years, across platforms, and across instrument types. Whatever is failing in this market is failing least where the most investors are relying on the disclosure.
The report also identifies a conflict in the rules that has not been resolved in published guidance. Rule 202(b) reads as termination by operation of law once its conditions are met. Rule 203(b)(3) reads as an election the issuer perfects by filing a Form C-TR within five business days. Which reading governs determines whether roughly a thousand issuers are compliant or delinquent right now, and counsel advising those companies are making the call today without an answer. EDGAR records terminations by 842 issuers market-wide through year-end 2025, fewer than the 1,082 issuers in this cohort alone that filed exactly one annual report and had fewer than 300 investors.
An edited version of the report was published by Financial Poise on September 14, 2026, and is available here (link the words “available here” to the Financial Poise URL).
The full report, the methodology, and the data licensing terms are at cclear.ai/research/after-the-raise.
