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UK Stewardship Code 2026: reporting structure and a learning case

The voluntary UK Stewardship Code 2026 applies from 1 January 2026. Its reporting structure separates policy and context from activities and outcomes.

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Identify the current framework

The FRC uses apply-and-explain principles for asset owners and managers, with separate principles for service providers. Its scope includes investment consultants, proxy advisers and engagement providers. This page describes that UK framework; it does not present it as a compulsory rule for every investor worldwide.

Distinguish the two reporting parts

FRC reporting structure
PartPurpose and frequency
Policy and Context DisclosureOrganisation, governance and policies; normally every fourth year, or when relevant changes make it inconsistent with the activities report
Activities and Outcomes ReportApplication of principles through the previous year’s activities and outcomes; annually

Evaluate an activity-only response

In this fictional case, an asset owner delegates issuer dialogue to a manager. The owner receives a list of ten meetings and labels the whole engagement programme successful. To assess that conclusion, ask what the meetings sought to change, what responses occurred and what evidence supports the claimed result. Ten meetings with no change could justify continued work; one meeting with a documented change could resolve a narrowly defined objective. The count does not settle either conclusion.

Build a more informative case record

For the exercise, take one objective and record the initial issue, requested change, response, evidence, status and next decision. Compare that record with the original meeting list. The additional fields allow a reader to assess the stated objective, while a bare list supports only a claim that meetings occurred. This is an illustrative learning record, not an FRC application form.

Further references