How to report on the UK Stewardship Code 2026
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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. We have published the guidance in draft form initially and welcome suggestions for the guidance - please send your comments to [email protected] before 31 August 2025. The guidance will be finalised in the autumn.
Frequently Asked Questions
I’m an existing signatory to the UK Stewardship Code 2020 and usually submit my report in the Spring application window – how should I 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 – how should I report?
You should submit your report to the 2020 Code in the Autumn 2025 reporting window. 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.
Do I have to submit a new Policy and Context Disclosure if the information contained in the previous Disclosure has changed?
Where the Policy and Context Disclosure no longer aligns with the information contained in the Activities and Outcomes Report, applicants are expected to submit a new Policy and Context Disclosure.
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.
Can I cross-reference to external information in my Stewardship Report?
Applicants must include all information necessary for their report. Applicants may cross-reference to external, publicly available documents to provide additional information for readers, but this will not form part of the FRC’s assessment of reporting.
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.
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.
Should policy documents and voting records be included within the Report?
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.
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.