Atkins reports that 2026 shareholder proposal season trends remained consistent with prior year despite changes.
“As one law firm recently reported, “Despite the heightened drama of the 2026 shareholder proposal season…the year-over-year trends remained largely consistent with the prior year.””
Atkins says the Division will also stop responding to Rule 14a-8(j) notices with non-objection letters.
“It also will no longer respond to notices filed under Rule 14a-8(j) with a letter indicating that it will not object if a company omits a proposal from its proxy materials.”
Atkins notes that the SEC stopped responding to most no-action requests during the 2025-2026 proxy season as an experiment.
“Last November, the Division of Corporation Finance announced that it would not respond to companies’ no-action requests during the 2025-2026 proxy season, other than requests submitted under Rule 14a-8(i)(1).”
Atkins concludes SEC staff interposition between companies and shareholder proponents is unnecessary for resolving proposal inclusion.
“But my greatest takeaway is that the Commission staff’s interposition between companies and shareholder proponents is unnecessary to effectively and efficiently resolve whether shareholder proposals should be included in proxy statements.”
Atkins announces the Division's shareholder proposal email address is no longer functional.
“Companies should submit those notices using the online Shareholder Proposal Form . In addition, the Division’s shareholder proposal email address is no longer functional.”
Atkins reports one individual was proponent for approximately 41 percent of voted shareholder proposals this season.
“This past season, one —yes, one—individual was the sole or lead proponent for approximately 41 percent of the shareholder proposals that were voted upon.”