How to apply to become a UK Stewardship Code 2026 signatory
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How to submit your Stewardship Report
Submitting your Report
The next application window will be 30 April 2026 for Asset Managers and Service Providers and 31 May 2026 for Asset Owners.
The application form will open on 1 April 2026.
Both the application form and Report must be received by the FRC by the relevant deadline.
Once the report has been assessed by the FRC and the applicant has been accepted as a Code signatory, the report will be a public document. The signatory must also make it available on their website within one month of being notified by the FRC, but they are free to publish it at any point before then.
Application
In 2026, organisations will have to submit a Stewardship Report, explaining how they have applied the UK Stewardship Code 2026 over a 12-month period.
The Stewardship Report includes both Policy and Context Disclosures and an Activities and Outcomes Report for all applicants in 2026.
The FRC will consider only the content submitted to us within the Stewardship Report in our assessment. The Report must be reviewed and approved by the applicant’s governing body, and signed by the chair, chief executive or chief investment officer.
All applicants must submit a report that covers a 12 month period ending no earlier than a year before the relevant application deadline. In the case of previously unsuccessful applicants, to ensure an appropriate reporting period, your reapplication may need to cover a different 12-month period to the one that you submitted for your original application. Many applicants choose to report to the most recent calendar year, or to their own financial year.
For the next assessment period in spring, applications from asset managers and service providers will be due by 30 April 2026 and applications from asset owners will be due by 31 May 2026.
For asset managers and service providers applying to the 30 April 2026 application deadline, submissions must cover a 12-month period starting on or after 1 May 2024 and ending on or after 30 April 2025.
For asset owners applying by the 31 May 2026 application deadline, submissions must cover a 12-month period starting on or after 1 June 2024 and ending on or after 31 May 2025.
| Reporting Period | 30 April Application Deadline 2026 (AMs and SPs only) | 31 May Application Deadline 2026 (AOs only) | 31 October Application Deadline 2026 |
|---|---|---|---|
| 1 April 2024 - 31 March 2025 | Not Accepted | Not Accepted | Not Accepted |
| 1 July 2024 - 30 June 2025 | Accepted | Accepted | Not Accepted |
| 1 January 2024 - 31 December 2024 | Accepted | Accepted | Not Accepted |
| 1 October 2024 - 30 September 2025 | Accepted | Accepted | Accepted |
| 1 January 2025 - 31 December 2025 | Accepted | Accepted | Accepted |
| 1 April 2025 - 31 March 2026 | Accepted | Accepted | Accepted |
Format
All applicants in 2026 should address the 2026 Code in full and include both a Policy and Context Disclosure and an Activities and Outcome Report. They may choose to submit their Stewardship Report as a separate Policy and Context Disclosure and Activities and Outcomes Report or combined into a single comprehensive submission as they prefer.
In future years, signatories may decide to submit only the annual Activities and Outcomes Report. The Policy and Context Disclosure must be submitted to the FRC every fourth year, at a minimum.
If their Policy and Context Disclosure remains accurate, signatories need only submit the Activities and Outcomes Report in the two intervening years. In the fourth year, signatories must submit both a Policy and Context Disclosure and Activities and Outcomes Report.
For example, if an applicant submits their first Policy and Context Disclosure in 2026, they will need to submit their next Policy and Context Disclosure by 2029 at the latest. If a first-time applicant is unsuccessful in their application and would like to apply again, they will need to submit a full report covering both a Policy and Context Disclosure and an Activities and Outcome Report in their next application.
| Year | Submission Requirement |
|---|---|
| 2026 | Policy & Context + Activities & Outcomes |
| 2027 | Activities & Outcomes Only |
| 2028 | Activities & Outcomes Only |
| 2029 | Policy & Context + Activities & Outcomes |
| 2030 | Activities & Outcomes Only |
| 2031 | Activities & Outcomes Only |
Assessment
Reports submitted to the FRC are assessed against the Code in a way that is proportionate to the organisation’s size and type. This assessment is then reviewed and discussed among FRC staff to ensure it is fair and appropriate. A sample of reports reflecting a range of applicants are reviewed by the FRC’s panel of independent advisors to ensure consistency.
New applicants must not refer to themselves as a signatory to the UK Stewardship Code 2026 before their application has been accepted and the result published.
Where an existing signatory who has been a successful applicant to the UK Stewardship Code 2020 applies to become a signatory to the Code in 2026, they will remain on the signatory list until the 2027 application period provided that they submit their report to the FRC during the relevant application window in 2026.
Who should apply to become a signatory to the Code?
Asset owners such as pension schemes, insurers, foundations, endowments and sovereign wealth funds. Guidance from The Pensions Regulator encourages defined benefit and defined contribution pension schemes to become signatories to the Code. Guidance from the Department for Levelling Up, Housing and Communities) recommends that administering authorities in the Local Government Pension Scheme become signatories to the Code.
Asset managers (investment managers) that manage assets on behalf of UK clients or invest in UK assets. FCA-regulated asset management firms covered by the FCA Conduct of Business Sourcebook (COBS) Rule 2.2.3 are required to disclose the nature of their commitment to the Code or where they do not commit to the Code, their alternative investment strategy.
Service providers such as investment consultants, proxy advisors, pension lawyers and data and research providers that support asset owners and asset managers to exercise their stewardship responsibilities. Fiduciary managers will need to fulfil reporting expectations relevant to their role from both the Code for asset owners and asset managers and Code for service providers.
Which should apply if your UK business is a separate legal entity within a global organisation?
Organisations should in the first instance seek to apply the Code across their business and report as a single global organisation. Where an organisation is unable to do so, the UK entity may report. A clear explanation for this and the scope of the information included in the Report should be provided.
Notifying the FRC that you will apply to become a signatory
The FRC encourages any organisations that intend to apply to become signatories to the Code to notify us of their intention to do so at [email protected]