Pensions UK publishes 2026 Stewardship and Voting Guidelines

The latest updates respond to a year marked by increased geopolitical uncertainty, growing scrutiny of ESG, and a noticeable erosion of shareholder rights across key global markets. Recent experiences, including a rise in AI-related resolutions, escalating cybersecurity incidents, and reduced formal voting rights under revised UK Listing Rules, have highlighted the need for investors to adapt their stewardship approaches.

The 2026 guidelines retain the broad structure of previous years but include enhanced narrative, updated voting recommendations and a new section on key emerging themes from the 2025 voting season to help pension schemes navigate a more complex landscape.

Key changes in the 2026 report

• AI and cybersecurity: Strengthened narrative on what good company behaviour looks like and strengthened voting recommendations. This reflects the increasing number of cybersecurity incidents and how their impact has been more damaging as well as the significant increase in AI related resolutions during the 2025 season.

• Governance: A change in narrative to reflect that while governance scrutiny is rising, shareholders do have less ability to influence. This leads to a greater focus on potential collaborative stewardship options and emerging industry initiatives.

• Climate and sustainability: The narrative has been revised to consider policy developments throughout 2025 as well as the global political backlash against ESG. The guidelines reaffirm the importance of acting on financially material environmental risks while recognising that investor expectations must remain evidence-based and resilient amid shifting sentiment.

• Social factors and workforce: This section has been refreshed to reflect the increasing prominence of social issues, from workforce wellbeing and fair pay structures to supply-chain labour practices. Updated expectations help schemes identify where poor management of social risks may translate into material financial impacts.

• Equality, Diversity and Inclusion (EDI): The guidelines reinforce Pensions UK’s commitment to EDI as a driver of stronger outcomes. Investors are encouraged to scrutinise transparency on workforce and board diversity, data disclosure and progress against clear objectives.

• Emerging trends: A new framing section highlights the most significant developments from the 2025 voting season, including declining support for Say-on-Climate votes, creeping dissent on governance flashpoints, and the expanding risk focus on AI and cyber. Its purpose is to give schemes a forward-looking view of where stewardship priorities are likely to shift next.

• Pass-through voting: The guidelines introduce pass-through voting as one option for schemes seeking to exercise shareholder rights directly. We recognise that while the model may benefit some investors, it will not be appropriate or operationally feasible for all.

Supporting tools and industry initiatives

Alongside the guidelines, Pensions UK continues to play a leading role in strengthening stewardship in practice. These includes:

• The launch of our vote reporting template developed in collaboration with the Vote Reporting Group, which aims to standardise manager disclosures and enhance comparability for asset owners. Schemes are encouraged to adopt the template from Q1 2026.

• Signing up as an active supporter of the Governance for Growth Investor Campaign (GGIC), which champions the evidence-based case that strong governance and preserved shareholder rights underpin, rather than hinder, sustainable UK growth.

George Dollner, Head of Strategic Policy at Pensions UK, said: “Stewardship is becoming more challenging, not less. Around the world we’re seeing a steady erosion of the rights that allow investors to influence companies, even as new risks such as AI and cybersecurity grow more complex. Our 2026 guidelines reflect this reality: they provide clearer expectations, stronger escalation pathways, and a greater focus on collaboration to help schemes navigate a tougher environment.

“While the levers of influence may be shifting, our purpose remains the same - to help pension savers achieve better outcomes through strong, resilient and evidence-based stewardship.”

Mark Smith, Head of Media Relations

020 7601 1726 | [email protected]

Cali Sullivan, Senior PR Manager
020 7601 1761 | [email protected]