In a filing with the Securities and Exchange Commission Thursday, Dell said it has learned that "several" of its former employees have been notified of the possible action and others could too.
It did not name the employees.
Dell first disclosed an internal investigation into its accounting in 2006, saying it was notified in August 2005 of an SEC inquiry related to its revenue recognition and financial reporting.
In 2007, it said it would restate more than four years of financial results with lower earnings after the probe found that its employees had misled auditors and manipulated results to meet performance targets.
Dell, which is based in Round Rock, Texas, said Friday it continues to cooperate with the SEC and has had "preliminary discussions" about a possible settlement that would likely include paying penalties.
