The Financial Reporting Council (the FRC) published the UK Stewardship Code 2026 (the 2026 Code) on 3 June 2025, replacing the current UK Stewardship Code 2020 (the 2020 Code).
The 2026 Code has been finalised following industry engagement that began with preliminary discussions in February 2024, followed by formal consultation between 11 November 2024 and 19 February 2025. The process involved over 1,500 stakeholders and incorporated insights from four years of reporting under the previous 2020 Code.
Timing
The 2026 Code takes effect from 1 January 2026. The 2026 Code will have two application windows to submit reports;
- spring 2026, with applications from (a) asset managers and service providers due by 30 April 2026 and (b) asset owners due by 31 May 2026; and
- autumn 2026, with all applications due by 31 October 2026.
Organisations that are current signatories to the 2020 Code and that are scheduled to report in the 2025 autumn cycle are expected to submit their stewardship reports in accordance with the Principles and reporting expectations of the 2020 Code by the deadline of 31 October 2025.
Stewardship reports submitted in 2026 will need to be in accordance with the new 2026 Code framework. However, the FRC has stated that 2026 will serve as a 'transition year' in order to allow signatories to adapt to the new 2026 Code. During this transition period, all existing signatories submitting a renewal application will remain on the signatory list following their 2026 application without an immediate assessment of their reporting by the FRC. The FRC recognises that these organisations have already met the requirements to become a signatory of the 2020 Code and is aiming to encourage organisations to "embrace the updated, more flexible reporting framework". The assessment process will resume in 2027.
New applicants in 2026—those not listed as signatories to the 2020 Code in 2025—will still be subject to the FRC's full assessment process.
What's New?
The 2026 Code introduces a revised definition of 'stewardship', defining it as "the responsible allocation, management and oversight of capital to create long-term sustainable value for clients and beneficiaries". This replaces the 2020 Code definition of stewardship which is "the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society" which had given rise to questions as to whether signatories were required to actively demonstrate the delivery of wider "benefits for the economy, environment and society".
To become a signatory to the 2026 Code, all organisations (asset owners, asset managers and service providers) are required to submit a Policy and Context Disclosure, as well as an Activities and Outcomes Report as part of their annual submission.
The Policy and Context Disclosure asks for factual information and should describe an organisation's stewardship policies, governance structures and other contextual information. Given this information typically remains stable over time, organisations only need to submit the Policy and Context Disclosure every four years, (or when there have been changes such that an organisation's Policy and Context Disclosure no longer aligns with its Activities and Outcomes Report).
The Activities and Outcomes Report, which is updated annually, explains how organisations have applied the Principles of the 2026 Code over a 12-month period. The FRC is clear that the annual submission should focus specifically on stewardship activities conducted during the reporting year and their outcomes.
In terms of other key changes, the 2026 Code:
- features fewer Principles and shorter 'how to report' prompts instead of detailed reporting expectations – with the FRC stating that this is to help eliminate 'box-ticking' approaches to reporting against the Principles. The FRC further adds that early evidence suggests signatories may be able to reduce reporting volume by 20-30%;
- has a more flexible reporting structure: Signatories can submit separate Policy and Context Disclosures and Activities and Outcomes Reports or combine them into a single document. As noted above, the Policy and Context Disclosure will only need to be submitted once every four years; and
- has targeted Principles: The 2026 Code includes dedicated Principles for different types of signatories, including asset owners, asset managers, and for the first time, specific Principles for proxy advisors, investment consultants and engagement service providers.
Guidance
To assist applicants with reporting under the 2026 Code, FRC has published Guidance (available here). Initially released in draft form and open to comment until 31 August 2025, the guidance will be finalised later in 2025.
The FRC makes it clear that the Guidance is not prescriptive, it is optional and contains suggestions for some of the information organisations may wish to include in their reporting to help explain their approach to stewardship. The Guidance covers both the Policy and Context Disclosure and the Principles of the Activity and Outcomes Report.
Conclusion
Currently, there are nearly 300 signatories to the 2020 Code, representing around £50 trillion in assets under management. Although the FRC sees 2026 as a transition year, applicants and current signatories are advised to start familiarising themselves with the content and requirements of the 2026 Code.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
