HIPAA Enforcement Tracker: Every OCR Penalty and Settlement, 2016 to 2026
HIPAA enforcement by the HHS Office for Civil Rights reached a record 25 actions in 2025, and 17 of those 25 were announced as ransomware, hacking, phishing, or Security Rule cases. Penalties are also getting smaller: the median verified amount fell from $1,600,000 in 2016 to 2019 to $240,000 in 2024 to 2026, a decline of 85%.
Every amount checked against the HHS source document · Ledger last checked October 2026
How has HIPAA enforcement changed?
OCR now brings more cases with smaller amounts. Between 2016 and 2019, the median verified HIPAA settlement or penalty was $1,600,000 (n=39). Between 2024 and 2026, it was $240,000 (n=37). Total dollars collected peaked in 2018 at $25,635,400, the year of the $16 million Anthem settlement, while 2025 produced the most actions on record with $8,580,316 in verified amounts.
Part of the volume increase comes from OCR initiatives that target specific obligations at scale, first patient right of access and, more recently, ransomware and Security Rule cases. These initiatives produce many smaller resolutions rather than a few large ones.
Is ransomware driving HIPAA enforcement?
Increasingly, by OCR’s own announcements. The first enforcement action with “ransomware” in its HHS title was announced on 2023-10-31. Since then, 14 actions have named ransomware. In 2025, 17 of 25 actions were announced as ransomware, hacking, phishing, or Security Rule cases.
Year-by-year summary
| Year | Actions | With verified amount | Total verified | Median | Security-named |
|---|---|---|---|---|---|
| 2016 | 12 | 10 | $21,919,600 | $2,200,000 | 1 |
| 2017 | 10 | 10 | $17,250,418 | $2,300,000 | 0 |
| 2018 | 8 | 8 | $25,635,400 | $999,000 | 0 |
| 2019 | 11 | 11 | $15,285,000 | $1,600,000 | 0 |
| 2020 | 15 | 14 | $13,418,400 | $160,000 | 2 |
| 2021 | 10 | 9 | $5,650,000 | $70,000 | 1 |
| 2022 | 7 | 4 | $1,218,640 | $300,640 | 1 |
| 2023 | 14 | 13 | $2,966,500 | $80,000 | 3 |
| 2024 | 15 | 11 | $8,723,265 | $250,000 | 8 |
| 2025 | 25 | 20 | $8,580,316 | $225,000 | 17 |
| 2026 | 6 | 6 | $2,007,250 | $450,000 | 2 |
“Security-named” counts actions whose HHS title names ransomware, phishing, hacking, cybersecurity, malware, a malicious insider, or the Security Rule. Older HHS titles named causes less consistently, so this column is not comparable across the full period.
The ledger: every action since January 2024
Each entry links to the HHS source document. Rows with a red edge were announced as security cases.
The full ledger back to 2008 is in the downloadable dataset below.
Frequently asked questions
How many HIPAA enforcement actions were there in 2025?
25, the highest annual count on the HHS OCR resolution agreements and civil money penalties list.
What is the average HIPAA penalty?
The median verified amount for 2024 to 2026 was $240,000. Medians are more representative than averages because a few large settlements skew the mean.
What is the largest HIPAA settlement?
Anthem’s $16 million settlement in October 2018, after what HHS described as the largest health data breach in history, which exposed the electronic protected health information of almost 79 million people.
Does OCR penalize ransomware victims?
OCR has resolved 14 investigations naming ransomware since October 2023. In the three ransomware resolution documents we could read in full, OCR cited the Security Rule risk analysis requirement rather than the attack itself.
How often does OCR announce enforcement actions?
Irregularly; 2025 averaged about two a month.
Where does this data come from?
The HHS Office for Civil Rights list of resolution agreements and civil money penalties, and the agreement documents linked from it.
Why are some amounts “not quantified”?
Some source pages have moved to an archive service, some are scanned images, and some announcements bundle several cases. We report an amount only when it appears in an HHS source we could read.
Is this legal advice?
No. It is a record of public enforcement data.
Methodology
Source. HHS Office for Civil Rights, “Resolution Agreements and Civil Money Penalties” list, retrieved October 2026, and each linked agreement or press release. 162 enforcement entries were extracted after removing one regulatory fact sheet and one duplicate listing of the same Montefiore settlement.
Amounts. An amount is recorded only if it appears in an HHS headline or in the binding text of the linked document (“Resolution Amount”, “Settlement Amount”, or “agreed to pay”). Proposed penalties later reduced or settled were replaced with the final amount. Amounts not found in a readable HHS source are marked “not quantified”.
Not quantified since 2024 (8): 2025-07-07 HHS’ Office for Civil Rights Settles HIPAA Privacy and Security Rule I; 2025-01-15 HHS Office for Civil Rights Settles HIPAA Case Against Memorial Health; 2025-01-08 HHS Office for Civil Rights Settles HIPAA Security Rule Investigation ; 2025-01-07 HHS Office for Civil Rights Settles 9th Ransomware Investigation with ; 2025-01-07 HHS Office for Civil Rights Settles 8th Ransomware Investigation with ; 2024-12-10 HHS Office for Civil Rights Settles with Health Care Clearinghouse, In; 2024-11-26 HHS Office for Civil Rights Settles with Holy Redeemer Family Medicine; 2024-04-01 HHS OCR Imposes a CMP on NJ Nursing Facility for Failing to Provide Ti.
Limitations. The list covers formal resolutions and penalties only; most OCR investigations close with technical assistance and do not appear. Medians exclude unquantified actions. Headline-based categories understate security cases in earlier years.
Update cadence. This ledger is rechecked when OCR announces new actions. Last checked October 2026.
Cite as:The Uptime Report. "HIPAA Enforcement Tracker: Every OCR Penalty and Settlement, 2016 to 2026." October 2026. https://theuptimereport.com/hipaa-enforcement-tracker-2026/
References
- HHS OCR, Resolution Agreements and Civil Money Penalties. Accessed October 2026.
- HHS OCR, Anthem resolution agreement. Accessed October 2026.
- HHS, The HIPAA Security Rule. Accessed October 2026.
- Individual agreement documents, linked in the ledger above. Accessed October 2026.
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