New streamlined UK Stewardship Code reduces reporting burden for signatories

The Financial Reporting Council (FRC) has published its revised UK Stewardship Code 2026 which focuses on value creation, reducing burdens and enhanced engagement between market participants.

Voluntary code of practice

The Stewardship Code is a voluntary code of practice for asset owners, asset managers and service providers (such as investment consultants, proxy advisors and data and research providers). It establishes a structure of key principles for signatories to report against. The Stewardship Code was first published by the FRC in 2010.

The publication of the new Stewardship Code on 3 June follows the FRC's 2024 consultation and extended review of the Stewardship Code 2020.

What are the principle changes?

The principle changes are as follows:

• Simplified definition of stewardship. The new enhanced definition of stewardship focuses on the principle of stewardship as the creation of long-term sustainable value for clients and beneficiaries. This is a less prescriptive definition than the previous Stewardship Code, as it removes the explicit reference to "sustainable benefits for the economy, the environment and society".
• Streamlined and tailored principles. The FRC has significantly reduced the number of principles, halving the number applicable to asset owners and managers. In addition, certain principles are now targeted to specific signatories.
• New flexible structure of reporting. Signatories will be required to structure their reporting into two parts which can be submitted separately, or combined into a single document.
• New supplementary guidance. The FRC has signalled it will provide supplementary guidance to assist signatories in reporting. This guidance is currently in draft form and organisations may send comments before 31 August.

Taken together, these changes are aimed at facilitating signatories to produce the same high-quality reporting with greater flexibility and relevance to their organisations, business models and strategy.

How to report to the Stewardship Code

To become a signatory to the revised Stewardship Code, applicants will be required to report to the FRC by way of a policy and context disclosure and an activities and outcome report.

The policy and context disclosure details the organisation's structure, governance, resourcing and policies and is submitted in the initial application and every fourth year thereafter, unless there have been changes at the organisation that require a revised disclosure.

The activities and outcome report is submitted annually and requires signatories to demonstrate their policies in action, citing outcomes against the Stewardship Code's core principles. The applicable principles vary depending on whether signatories are asset owners and managers or service providers.

Applying to the Stewardship Code

There are two application windows to submit reports.

Spring 2026 application window:

• asset managers and service providers can apply by 30 April 2026.
• asset owners can apply by 31 May 2026.

Autumn 2026 application window:

• all applications will be due by 31 October 2026.

Osborne Clarke comment

The revised Stewardship Code introduces significant changes aimed at enhancing the quality and relevance of reporting for asset owners, asset managers and service providers. These modifications are designed to reduce the reporting burden while ensuring that the stewardship activities are meaningful and aligned with the organisation's strategy and business model. Importantly, it emphasises genuine engagement and value creation, preventing the reporting process from becoming a mere box-ticking exercise.

Applicants will need to submit their reports within the specified application windows – and may also wish to review the draft guidance, and submit comments to stewardshipcode@frc.org.uk before 31 August.