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In response to regulatory pressures in the US and shifting stewardship priorities among their clients including in respect of ESG matters, in October 2025, both Glass, Lewis & Co. (Glass Lewis) and Institutional Shareholder Services Inc. (ISS) announced a shift in their global proxy voting policies away from standardized benchmark proxy voting recommendations to customized recommendations tailored to each investor's priorities, including in respect of DEI and environmental matters.
Glass Lewis shifts from standard to custom proxy advice
On October 15, 2025, Glass Lewis announced that it will discontinue its benchmark proxy voting guidelines beginning with the 2027 proxy season. Instead of issuing a single, standardized proxy voting recommendation, Glass Lewis will provide client-specific recommendations, either using an investor's own "client custom policies" or one of Glass Lewis's "thematic voting policies." Benchmark recommendations will still apply for the 2026 proxy season.
Over the next two years, Glass Lewis will transform how it delivers proxy voting recommendation through two main approaches:
- Client-customized voting frameworks: Glass Lewis will tailor recommendations to each investor's "individual...philosophies and stewardship priorities," enabling clients to vote in line with their own policies. This will be implemented through:
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- (i) Custom policy guidelines: clients provide their own voting policies, applied alongside Glass Lewis analysis; or
- (ii) Specific thematic policies: pre-packaged Glass Lewis policies, such as ESG (for ESG-focused investors or funds) or Anti-ESG (for clients skeptical of politicized DEI/ESG initiatives), providing a clear stance on sustainability or DEI issues.
- Multiple perspective approach: Glass Lewis will replace single benchmark recommendations with "multiple perspectives" reflecting diverse client priorities, ranging from management-leaning to governance-focused, enabling clients to guide their voting decisions.
ISS makes a similar shift toward customized recommendations
On October 30, 2025, ISS opened its public comment period for proposed 2026 Benchmark Voting Policy updates, with final changes expected by the end of November 2025. These updates will generally apply to shareholder meetings on or after February 1, 2026.
The proposed updates focus on ISS's US Proxy Voting Guidelines for Environmental and Social (E&S) shareholder proposals in the US and globally, covering four key topics: diversity and equal opportunity, political contributions, human rights and climate change. ISS plans to move from a presumption of "support" to a "case-by-case" evaluation for E&S proposals, adding a factor to consider whether the proposal addresses "substantive matters" affecting "shareholder' interests... and rights."
To support institutional investors' evolving needs for flexible stewardship tools, ISS introduced two governance research services on October 7, 2025:
- (1) Gov360: a data-only platform providing impartial research and analytics on global portfolio company shareholder meetings, without issuing recommendations; and
- (2) Custom Lens: a service providing tailored recommendations based on client-defined policies.
While ISS has not abandoned its benchmark policy, these initiatives signal a clear shift towards flexibility and client-customization, distinguishing its approach from Glass Lewis.
Impact of changes in proxy voting by Glass Lewis and ISS
Kingsdale Advisors has noted these by Glass Lewis and ISS are more than policy changes, but rather represent a "structural transformation" in how proxy advice is developed and delivered, moving toward a "decentralized, data-driven, and investor-led" model. The end of standardized benchmark recommendations is expected to fragment voting behavior and make outcomes in board elections and shareholder proposals (including E&S proposals) less predictable, increasing reliance on internal governance frameworks of individual investors. As client-customized voting policies become the norm, companies will face greater uncertainty, with voting patterns and outcomes varying across individual investors.
Kingsdale Advisors notes that with DEI and board diversity policies no longer applied through uniform benchmarks, voting outcomes on diversity will now primarily reflect the priorities of investors who explicitly value diversity factors, reducing consistency and pervasiveness previously provided by benchmark guidelines.
For Canadian issuers, neither ISS nor Glass Lewis has proposed changes to domestic benchmark policies. However, global developments, particularly on ESG proposals, may have indirect implications.
Thank you to Kristina Zaytseva, articling student, for her contributions to this article.
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