The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu The leading online blog in the fields of corporate governance and financial regulation. Sat, 04 Apr 2026 11:30:51 +0000 en-US hourly 1 https://wordpress.org/?v=6.5.8 https://corpgov.law.harvard.edu/wp-content/uploads/2024/02/cropped-photography-4-e1706898544564-1-32x32.png Tracking Shareholder Proposals and Company Exclusions: Pre-Season Observations – The Harvard Law School Forum on Corporate Governance https://corpgov.law.harvard.edu 32 32 Tracking Shareholder Proposals and Company Exclusions: Pre-Season Observations https://corpgov.law.harvard.edu/2026/03/22/tracking-shareholder-proposals-and-company-exclusions-pre-season-observations/?utm_source=rss&utm_medium=rss&utm_campaign=tracking-shareholder-proposals-and-company-exclusions-pre-season-observations https://corpgov.law.harvard.edu/2026/03/22/tracking-shareholder-proposals-and-company-exclusions-pre-season-observations/#respond Sun, 22 Mar 2026 11:30:06 +0000 https://corpgov.law.harvard.edu/?p=179845?d=20260320161843EDT Posted by Courteney Keatinge, and Dimitri Zagoroff, Glass Lewis, on Sunday, March 22, 2026
Editor's Note:

Courteney Keatinge is the Vice President of ESG Research and Dimitri Zagoroff is a Senior Editor at Glass Lewis. This post is based on their Glass Lewis memorandum.

Key Takeaways

  • In November 2025, the SEC’s Division of Corporation Finance announced it would no longer provide responses to most no-action requests to exclude shareholder proposals.
  • Based on early incoming data, the number of shareholder proposals going to a vote in January and February 2026 is down from last year, while the number of exclusion notices filed is roughly the same.
  • The absence of SEC no-action relief may have encouraged some companies to be more cautious about what proposals they exclude, and their basis for exclusion.
  • Investors are pushing back on proposal exclusion via litigation – and getting results.
  • Compared to 2025, more of the shareholder proposals that have gone to a vote cover environmental and social topics.

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