- Sustainability Reporting, Proxy Reporting
The 2025–2026 proxy season has introduced a significant shift in the governance landscape for U.S. public companies.
In November 2025, the U.S. Securities and Exchange Commission (SEC) announced that it would no longer issue no-action letters related to most shareholder proposal exclusions under Exchange Act Rule 14a-8 for the current proxy season.
This thought piece examines the evolving landscape following the SEC’s announcement, highlights early litigations, and provides recommendations to mitigate risks.