Monthly Archives: June 2026

Considerations for Shareholder Proposals in a Post-Rule 14a-8 World

Elizabeth Ising, Ronald Mueller, and Julia Lapitskaya are Partners at Gibson, Dunn & Crutcher LLP. This is a post by Ms. Ising, Mr. Mueller, Ms. Lapitskaya, and Michael Svedman.

Over the last year, the Securities and Exchange Commission (SEC) has indicated[1] its intent to engage in rulemaking regarding Rule 14a-8 under the Securities Exchange Act of 1934, as amended (“Rule 14a-8”), which governs when a public company is required to include a shareholder’s proposal and supporting statement in its proxy statement and include the proposal on its proxy card.[2]

While SEC amendments to Rule 14a-8 historically focused on procedural and substantive requirements, recent comments by SEC Chairman Paul Atkins have questioned the role of the rule in the context of state corporate law.[3] Moreover, the statutory basis for the rule itself has come under question, particularly to the extent that it has produced a body of federal “common law” on “proper” proposal subject matters. Coupled with an executive order issued by President Donald Trump in December 2025 directing the SEC, among other things, to review all rules and guidance relating to Rule 14a-8,[4] these comments raise the possibility that the SEC will seek to rescind Rule 14a-8.[5] As a result, shareholder proponents and companies are increasingly evaluating the prospect of a world where shareholder proposals are submitted outside of the Rule 14a-8 framework.

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Investor Activists Are Now Targeting Your AI Strategy

Julia Dixon is Vice President at Edelman Smithfield. This post is based on an Edelman Smithfield memorandum by Ms. Dixon, Patrick Ryan, Lex Suvanto, Christine O’Brien, and Stacy Turnof.

Artificial intelligence is emerging as a new attack theme for shareholder activists. What many companies frame as a long-term innovation story is increasingly being viewed by activists as a short-term lever to drive unlock cost savings, improve productivity and accelerate growth. Activists are now targeting companies that are not moving fast enough to capture these benefits and not sufficiently communicating their efforts to the market.

Early signs of this were visible during the 2026 proxy season as several activists made AI-related themes a central topic in their campaigns. In February, Starboard Value sent a letter to TripAdvisor arguing that the company should move faster to deploy AI capabilities, noting “we have repeatedly communicated that the status quo pace of change is unacceptable in an environment where speed matters and where incumbents are at risk of being disintermediated.”

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We’re Not Rolling the Dice in Nevada

Craig Randall is General Counsel at RA Capital Management. This post is based on his RA Capital memorandum.

As General Counsel of a life sciences investment fund, I’m routinely asked by company founders if they should incorporate somewhere in the US other than Delaware. That is not a question I really had to think about until a couple of years ago, when the “Dexit” crusade really got started. And it accelerated when a very prominent venture capital firm announced last year that it had moved its management company to Nevada and urged others to follow in its footsteps.

Our answer remains: Delaware – without any disclaimers or reservations. Our management company is domiciled in Delaware, and we still think Delaware is the best place for high growth, venture-backed companies to incorporate.

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ESG and Anti-ESG Shareholder Proposals in 2026

Jennifer Zepralka is a Partner, and Ali Perry and Liz Walsh are Counsels at Mayer Brown LLP. This post was prepared for the Forum by Ms. Perry, Ms. Walsh, Ms. Zepralka, Milly Kim, and Anna Pinedo.

In many ways, the 2026 proxy season has been markedly different than prior seasons, due, in no small part, to the November 2025 decision by the U.S. Securities and Exchange Commission (“SEC”) Staff not to provide substantive guidance on the grounds on which a company could omit a shareholder proposal under most prongs of Rule 14a-8 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”).  This change in the SEC’s approach created a new dynamic between companies and proponents, including with respect to the level of engagement between the parties and the factors a company must consider in determining whether to include a proposal in its proxy statement.  What is not different from the 2025 proxy season, though, is the prevalence of “anti-ESG” shareholder proposals submitted to public companies.  These proposals are generally critical of, or question the value of, company policies or initiatives related to environmental, social or governance (“ESG”) factors, including how the company discloses, reacts to and manages ESG-related risks and policies, such as, for example, risks related to carbon emissions, as well as policies addressing diversity, shareholder rights and corporate social responsibility.[1]  As of the midpoint of the 2026 proxy season, “anti-ESG” proposals are very common, just as they have been in recent years.

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The 2026 Proxy Season in Progress

Blair Jones and Austin Vanbastelaer are Managing Directors and Nathan Grantz is a Consultant at Semler Brossy.

Introduction

At first blush, this appears to be just another proxy season. The overall failure rates for the Russell 3000 and S&P 500 companies in Say on Pay, director election, and equity plan proposal votes remain low. Vote results are roughly in line with recent historical outcomes, and proxy advisors and large investor stewardship groups largely align on the pay-related topics that should receive low vote support. Some may have anticipated greater disruption, given that the leading proxy advisory firms, ISS and Glass Lewis, have been facing increasing political and governance pressures. Additionally, several prominent investors have opted to disregard their recommendations and establish their own review processes.

Our findings suggest a more nuanced picture than a simple story of proxy advisor decline. On one hand, it appears increasingly acceptable for companies to receive an ‘Against’ recommendation from ISS on share request proposals without risking a failed vote, a meaningful shift from prior seasons. On the other hand, granting one-time awards to Named Executive Officers (NEOs) remains a lightning-rod issue, drawing direct investor scrutiny that operates largely independent of proxy advisors. Where low Say on Pay results do occur, we continue to observe reduced vote support for compensation committee chairs, reinforcing that director accountability remains a live mechanism even as its use stays selective READ MORE »

Director Elections: All Quiet on the Proxy Front, but Will It Last?

Rajeev Kumar is a Senior Managing Director at Georgeson, and Meighan McGowan is the Head of Business Development for Investor Engagement North America at Computershare.

For many US public companies, the 2026 proxy season has been notably calm in two areas that boards and management teams watch closely: director elections and ‘say on pay’.

Director nominees continue to receive strong shareholder support, and executive compensation programs have been passing at high rates. At first glance, the results suggest that investors remain broadly supportive of management on these core annual meeting items.

That conclusion is accurate, but incomplete.

The evolving dynamics of proxy voting. The underlying voting environment is changing – from changes in proxy advisor models to investor stewardship practices and fresh regulatory approaches.

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Weekly Roundup: June 5-11, 2026


More from:

This roundup contains a collection of the posts published on the Forum during the week of June 5-11, 2026


Chancery Holds Specific Oral Statements About Post-Closing Plans May Exceed Mere Puffery




Corporate M&As and Labor Market Concentration: Efficiency Gains or Power Grabs?



Excessive Executive Compensation: Investor Guidance


Too Liable To Regulate: The Hidden Costs of Fossil Fuel Decommissioning and Remediation



Shareholder Activism – 2026 Mid-Year Review


Lessons from ExxonMobil


The 2026 Proxy Season: Shareholder Proposal Trends


2026 Proxy Season Trends: The Fracturing of Shareholder Power


2026 Proxy Season Trends: The Fracturing of Shareholder Power

Arthur B. Crozier is Executive Chair, Gabrielle E. Wolf is a Senior Director, and Jonathan L. Kovacs is a Director at Innisfree M&A Incorporated.

Introduction

The 2026 proxy season confounded many of the assumptions that issuers, activists, and advisors have relied upon for more than a decade. While headlines suggest a retreat of shareholder activism and a rollback of ESG‑driven governance, the reality is more complex—and, in many respects, more destabilizing. Rather than a return to management dominance or a recalibration of investor priorities, the current environment reflects a fracturing of shareholder voting blocs.

For years, issuers and proxy solicitors could model vote outcomes with relative confidence around a handful of predictable centers of gravity: proxy advisor benchmark policies, the cohesive stewardship practices of the largest passive asset managers, and a stable framework for shareholder proposal adjudication. In 2026, those anchors are loosening. Legal challenges, regulatory intervention, political scrutiny, and market‑driven adaptation are simultaneously eroding the influence of proxy advisors, splintering passive investor voting blocs, and decentralizing stewardship decision‑making.

This article examines the most consequential developments of the 2026 proxy season and considers what this fractured landscape means for issuers navigating an increasingly unpredictable voting environment.

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The 2026 Proxy Season: Shareholder Proposal Trends

Jennifer Zepralka is a Partner, and Ali Perry and Liz Walsh are Counsels at Mayer Brown LLP. This post was prepared for the Forum by Ms. Zepralka, Ms. Perry, Ms. Walsh, Anna Pinedo, and Milly Kim.

The 2026 proxy season thus far has been out-of-the-ordinary, impacted by regulatory and policy developments that required companies and shareholders to adapt their shareholder proposal and engagement strategies. As a result of these unusual circumstances, particularly when coupled with uncertainty about the evolving role of the Securities and Exchange Commission (“SEC”) and potential rule changes on the horizon, it is somewhat difficult to rely on this year’s shareholder proposal experience as a reliable indicator of future trends. Nevertheless, examination of the proposals submitted and voted upon this season can still provide useful insights into the topics of greatest interest to shareholders and can help guide public companies’ engagement efforts and priorities.

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Lessons from ExxonMobil

Katherine Terrell Frank and Meredith Jeanes Lyons are Partners and Robert L. Kimball is a Senior Partner at Vinson & Elkins LLP.

After 144 years of legal domicile in New Jersey, ExxonMobil Corporation, which has been physically headquartered in Texas since 1989, is consolidating its legal and physical homes to Texas. With approximately 71 percent of votes cast in favor at its 2026 annual meeting, Exxon’s reincorporation to Texas reflects the Lone Star State’s growing competitiveness as a corporate law jurisdiction and demonstrates that reincorporation into Texas may be an achievable result for widely-held public companies. Exxon Chairman and Chief Executive Officer Darren Woods explained that Texas has cultivated a policy and regulatory environment that enables companies to focus on creating shareholder value rather than navigating unnecessary red tape and political interference.[1]

Boards considering reincorporation into Texas should carefully consider the corporate governance and shareholder outreach strategies employed by Exxon and other successfully redomiciled public companies. Because proxy advisors have generally opposed reincorporation to Texas, favorable votes for reincorporation are not guaranteed for corporations that lack a controlling shareholder or a large, friendly voting block. Successful reincorporations will require companies to work well in advance of shareholder meetings to solicit investor feedback, determine an acceptable Texas corporate governance structure, and educate voters on the benefits of reincorporation.

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