After the Raise
What Form C-AR Filing Data Reveals About Regulation Crowdfunding's Ongoing Reporting Regime
Sherwood Neiss.
Published by Crowdfund Capital Advisors, September 2026
Data source: CCLEAR
Financial Poise — An edited version of this report was first published by Financial Poise on September 14, 2026. Used with permission of Financial Poise™, www.financialpoise.com. The version here is the author's original manuscript.
Abstract
Regulation Crowdfunding has moved roughly $2.9 billion into more than 6,000 U.S. companies since 2016, and every one of those issuers took on an ongoing disclosure obligation the day its offering closed. Half are no longer meeting it. This report examines the filing record of the 5,383 issuers whose first annual report on Form C-AR has come due, reconciled against the Commission's own EDGAR filing manifests, and finds that the headline non-compliance figure blends several distinct populations: issuers that lawfully exited under Rule 202(b)(2) after a single filing, an undetermined number of debt issuers whose obligation may have ended on repayment, companies that no longer exist, and genuine delinquency. It also identifies an unresolved conflict between Rule 202(b) and Rule 203(b)(3) over whether the reporting obligation terminates automatically or only on the filing of a Form C-TR, a question that determines the compliance status of roughly a thousand issuers today.
Key findings
- Of the 5,383 Reg CF issuers whose first annual report has come due, 50.6% have filed one.
- 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 market is failing least where the most investors are relying on the disclosure.
- The gradient is not an artifact of vintage, platform, or instrument. Standardizing every investor-size bucket to the pooled vintage distribution moves the four rates only from 33.4, 57.7, 76.2 and 89.0 to 33.0, 57.2, 75.1 and 86.0, and the pattern holds within individual intermediaries.
- Rule 202(b) reads as termination by operation of law once its conditions are met, while Rule 203(b)(3) reads as an election the issuer perfects by filing Form C-TR within five business days. The two have not been reconciled in published guidance, and the answer determines whether roughly a thousand issuers are compliant or delinquent right now.
- EDGAR records Form C-TR 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. Most issuers relying on the exit condition are not filing the notice that Rule 203(b)(3) requires.
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License the underlying data
The findings in this report are drawn from CCLEAR, Crowdfund Capital Advisors' proprietary database of the Regulation Crowdfunding market, tracked continuously since the market's first filings in May 2016. CCLEAR is not a public dataset. Researchers and institutions who want to replicate, extend, or build on this analysis can license access to the underlying offering-level data.
Contact: data@cclear.ai