How to report on the UK Stewardship Code 2026
7 minute read
UK Stewardship Code 2026 for asset owners and asset managers
The UK Stewardship Code 2026 has 6 Principles for asset owners and asset managers. Applicants report against these Principles in their annual Activities and Outcomes Report. All applicants are also required to submit a Policy and Context Disclosure every four years.
Disclosures for asset owners and asset managers
| Disclosure |
|---|
| A - Organisation, investment beliefs and stewardship approach |
| B - Governance and resources |
| C - Policies, processes and review |
| D - Conflicts of interest |
| E - Dialogue with clients and/or beneficiaries |
Principles for asset owners and asset managers
| Principles |
|---|
| 1 - Integrating stewardship and investment |
| 2 - Promoting well-functioning markets |
| 3 - Engagement |
| 4 - Exercising rights and responsibilities |
| 5 - Selection and oversight of managers |
| 6 - Monitoring service providers |
Policy and Context Disclosure
This includes information about the organisation, its governance and resourcing, linking to relevant policies. Applicants are required to submit a Policy and Context Disclosure to the FRC every 4 years, or when there have been changes at an organisation such that their Policy and Context Disclosure no longer aligns with their Activities and Outcomes Report.
Activities and Outcomes Report
Applicants are required to submit an Activities and Outcomes Report to the FRC every year to demonstrate how they have applied the Principles through the activities they have undertaken in the preceding year and the outcomes of these activities. The FRC will assess the Activities and Outcomes Report each year.
Report submission
Applicants are required to submit:
- A Policy and Context Disclosure every four years. A signatory may choose to submit their Policy and Context Disclosure more frequently, but it is not required.
- An Activities and Outcomes Report annually.
Applicants may also choose to present the Policy and Context Disclosure and the Activities and Outcomes Report either as separate documents or combined in a single comprehensive submission.
If they choose to submit a combined report, they are not required but may choose to update their reporting on Policy and Context in years two and three. They may also choose to report Principle-by-Principle or take a more narrative approach.
Both reports must be reviewed and approved by the applicant’s governing body and signed by the chair, chief executive officer or chief investment officer.
Structure of reporting
To become a signatory, all organisations are required to submit a Policy and Context Disclosure as well as an Activities and Outcomes Report.
| Disclosures (A-E) | The Disclosures indicate areas of information that help readers to understand more about the organisation and provide context for their reporting. |
|---|---|
| ‘Disclosure requirements’ | Each of the Disclosures is further broken down into aspects that applicants should report against to ensure the necessary information is included. |
| Principles (1-6) | The Principles indicate practices that reflect effective stewardship. |
|---|---|
| ‘How to report’ prompts | Each Principle has concise, high-level prompts for signatories to use to explain how they have applied the Principle. These prompts indicate information that we would expect organisations to include in their annual Activities and Outcomes Report and form the basis of the FRC’s assessment of reporting. |
| Guidance | Guidance for reporting against the Policy and Context Disclosure and the Activities and Outcomes Report is optional and is published separately. Good reporting can be achieved without using the guidance. |
|---|
Application of Principles for asset owners and asset managers
Asset owners and asset managers have different rights, responsibilities and influence within the investment chain, and in exercising stewardship.
All organisations should apply and report on Principles 1, 2 and 6.
Organisations should apply and report on the Principles to the extent that they are relevant to their activities.
Organisations managing assets directly should report on Principles 3 and 4. They are not required to report on Principle 5.
Organisations using external managers should report on Principle 5. They are not required to report on Principles 3 and 4 but are encouraged to do so if they use external managers and also engage with issuers or participate in voting. Where an organisation uses an external manager and retains voting rights, they should report on Principle 4.
| Principle | Investing directly | Using external managers |
|---|---|---|
| Principle 1: integrating stewardship and investment | Required | Required |
| Principle 2: promoting well-functioning markets | Required | Required |
| Principle 3: engagement | Required | Optional |
| Principle 4: exercising rights and responsibilities | Required | Optional |
| Principle 5: selection and oversight of managers | Not required | Required |
| Principle 6: monitoring service providers | Required | Required |
UK Stewardship Code 2026 for Service Providers
The UK Stewardship Code 2026 for Service Providers focuses on the activities of proxy advisors, investment consultants and engagement service providers.
The structure of the Code is the same as that for asset owners and asset managers; a Policy and Context Disclosure and an Activities and Outcomes Report. There are four Disclosures and four Principles. There is also optional guidance provided to support service providers’ reporting.
Disclosures for service providers
| Disclosures |
|---|
| A- Organisation and services |
| B - Governance and resources |
| C - Policies, processes and review |
| D - Conflicts of interest |
Principles for service providers
| Principles |
|---|
| 1 - Communicating with clients |
| 2 - Proxy advisory services |
| 3 - Investment consultant services |
| 4 - Engagement provider services |
Application of Principles for service providers
Service providers should apply and report on the Principles to the extent that they are relevant to their activities.
| Principles | Applies to |
|---|---|
| Principle 1: communicating with clients | All service providers |
| Principle 2: proxy advisory services | Proxy advisors |
| Principle 3: investment consultant services | Investment consultants |
| Principle 4: engagement provider services | Engagement service providers |
Guidance
We are introducing guidance to assist applicants with reporting to the UK Stewardship Code 2026. This contains non-prescriptive suggestions for some of the information organisations may wish to include in their reporting. The guidance is not additive and should be used as a tool to help consider what information may be useful to help the reader understand an organisation’s approach to stewardship.
Frequently Asked Questions
I’m an existing signatory to the UK Stewardship Code 2020 and usually submit my report in the Spring application window – when should I submit my report?
You should submit your report to the 2026 Code in the Spring 2026 application window.
To support a smooth transition to the updated UK Stewardship Code, 2026 will be treated as a transition year. All existing signatories submitting a renewal application will remain on the signatory list throughout this period. This approach recognises that these organisations have already met the requirements to become a signatory of the 2020 Code and encourages them to embrace the updated, more flexible reporting framework without an immediate assessment of their reporting by the FRC.
New applicants in 2026—those not listed as signatories to the 2020 Code in 2025—will still be subject to the full assessment process. Further support and feedback will be provided through a range of channels, including publications, webinars, and one-to-one engagement.
The assessment process will resume in 2027.
I’m an existing signatory to the UK Stewardship Code 2020 and usually submit my report in the Autumn application window – when should I submit my report?
Your first report under the UK Stewardship Code 2026 will be in Autumn 2026. Because 2026 is a transition year for existing signatories, you will remain on the signatory list until Autumn 2027.
How often should the Policy and Context Disclosure be submitted?
The Policy and Context Disclosure is where signatories provide contextual information about their organisation, including their governance, resourcing and relevant policies. It must be submitted to the FRC every fourth year, at a minimum. If the Policy and Context Disclosure no longer aligns with the content of the Activities and Outcomes Report, then an updated version should be submitted to the FRC at the signatory’s next, usual reporting window.
Once an organisation has been accepted as a Code signatory, its Policy and Context Disclosure will become a public document, and the signatory must also make it available on their website for the duration that the Disclosure is still applicable.
Can I include case studies of engagements conducted on my behalf by my external managers?
Applicants are encouraged to include case studies conducted on their behalf by external managers. It is helpful to the reader if applicants provide context such as linking any case studies to their stewardship approach, explaining why they have selected them and if they have discussed them with their external manager.
The Code requires signatories to apply stewardship across all asset classes and geographies. How should this be reported on?
Reporting should be proportionate, with examples reflecting the breakdown of assets under management by asset class and geography reported in the Policy and Context Disclosure. For example, if an organisation is invested 50% in equities and 50% in fixed income, examples in the report are expected to evidence approaches in both asset classes, not just equity. Where this is not the case, an explanation should be given.
What does ‘apply and explain’ mean for the Principles in the Activity and Outcome Report?
The Principles are fundamental to effective stewardship. Organisations are expected to apply all relevant Principles in a way that aligns with their specific policies and processes, and to clearly explain how they have done so over a 12-month period.
Should policy documents and voting records be included within the Report?
Applicants are encouraged to cross-reference content between their Policy and Context Disclosure and their Activities and Outcomes Report, where these are published separately, or link between sections within their report to connect related information and avoid duplication.
Applicants must include sufficient information to address the 2026 Code in their report. They may include links to external, publicly available documents to provide additional context for readers, but this will not form part of the FRC’s assessment of reporting.
When linking to additional documents, signatories should provide a short summary of the information being cross-referenced and ensure that all cross-referenced information is publicly available.
Is cross-referencing permitted in reporting?
Reporting should provide enough information to enable the reader to have a good understanding of the application of the Code without having to refer to information elsewhere. Applicants are not required to provide the full text of policy documents or complete voting records. They should provide a summary with enough information that readers can understand the key elements without compromising the readability of their reporting. Applicants can also link to publicly available documents to provide additional information. Where documents are referred to, these should be easily accessible and linked to from the Report.
Is the guidance a de facto reporting requirement?
No. The guidance is not a set of reporting requirements. It is intended to support applicants in preparing their reports by providing practical, non-prescriptive suggestions for signatories to consider. The guidance is optional and should be viewed as a helpful resource rather than a mandatory framework.
Applicants should determine how they structure and present information and whether they use the guidance to assist in drafting their report. Its purpose is to offer flexibility and encourage organisations to report in a way that best reflects their own stewardship approach.
Will signatories receive feedback on their submission during the transition year to help ensure alignment with the 2026 Code?
We are actively exploring ways to provide useful feedback to signatories during the transition year on the quality of their reporting to the 2026 Code. Our aim is to offer insights and additional materials that will benefit all applicants, whether through podcasts, webinars, individual feedback letters or other avenues.
Will my Stewardship Report be made public?
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 and be listed on the UK Stewardship Code Signatories webpage. Signatories must also make it available on their website within one month of being notified by the FRC of their successful application.