A new study from ISS Corporate Solutions Inc. reveals a significant shift in shareholder proxy activity, with a notable increase in proxy omissions following the U.S. Securities and Exchange Commission’s (SEC) recent bulletin altering prior guidance.
According to the study, nearly 25% of submitted shareholder proposals were omitted from corporate ballots in 2025—up from just under 15% in the previous year. ISS-Corporate attributes this unprecedented rise to a February 2025 SEC bulletin, which now requires shareholders to demonstrate the economic and strategic relevance of their proposals to the company.
The bulletin, issued by the SEC’s Division of Corporation Finance, reversed guidance from the previous administration that had emphasized broader societal impacts in the review process. With the shift, companies have found it easier to exclude proposals, especially those related to environmental and social topics.
“This policy change significantly reshaped the shareholder proposal landscape,” said Jun Frank, Global Head of Compensation and Governance Advisory at ISS-Corporate. “Proponents are becoming more selective about both the topics and the companies they target.”
The study analyzed shareholder activity among Russell 3000 companies, revealing that submitted proposals dropped from 906 in the first half of 2024 to 782 in the first half of 2025. The sharpest decline was seen in ESG-related proposals, while “anti-ESG” resolutions reached a record 122 submissions.
Despite these shifts, proposals related to corporate governance remain the most common. Meanwhile, shareholder support for executive pay packages slightly declined, with median support among Russell 3000 companies falling from 94.7% to 94.3%, even as median CEO compensation hit an all-time high.
The findings come at the height of the U.S. corporate annual meeting season, with approximately 5% of Russell 3000 companies holding meetings this week.
