Jason Holt is a Senior Analyst, Sam Purcell is a Senior Analyst, and Dimitri Zagoroff is a Senior Editor at Glass, Lewis & Co. This post is based on their Glass Lewis memorandum.
Key Takeaways
- Amid a multi-year decline in shareholder proposal volumes, the SEC’s decision to step away from the no-action process appears to have buoyed the number of proposals going to a vote this year.
- Issuers have been increasingly sophisticated in targeting proposal exclusions, with individual activist proponents much more likely to get pushback than institutional investors.
- The mix of different topical categories covered by shareholder proposals targeted for exclusion largely mirrored that of proposals that went to a vote.
- A major dropoff in compensation proposals, along with continued declines in E&S, contributed to increasing focus on governance topics.
- So-called “anti-ESG” proponents were active across the board, submitting more environmental and social proposals while also contributing to a wave of requests for the separation of chair and CEO roles.
How has the SEC’s new approach to no-action requests[1] impacted the shareholder proposal landscape? It’s a question that Glass Lewis has monitored all year.
With the 2026 U.S. proxy season now complete, some notable trends have emerged. In the third instalment of our series on shareholder proposals and company exclusions, we share what we’ve observed at meetings held through June 30.

