Asset owners and asset managers
Policy and Context Disclosures A–E, and Principles 1–6 in the annual report, applied by investment model.
Principles 1, 2 and 6 for everyone.FRC · Stewardship · Requirements
Stewardship Code reporting requirements in the UK: two reports, one voluntary code
The Stewardship Code reporting requirements in the UK are set by the FRC’s UK Stewardship Code 2026, which an investor meets only if it chooses to become a signatory.
A signatory files an annual Activities and Outcomes Report and, at least every fourth year, a Policy and Context Disclosure, and the FRC assesses them.
Beside the voluntary Code sits one legal duty for asset managers: the FCA’s COBS 2.2.3R disclosure.
In one table
Stewardship Code reporting requirements, one line each
Each requirement with the FRC or FCA document it comes from, as at 11 October 2026.
The Code itself, its six Principles and its history are on the UK Stewardship Code page.
| Requirement | Who | When | Source |
|---|---|---|---|
| Activities and Outcomes Report on the Principles over 12 months | Every applicant and signatory | Annually, in a window | FRC, How to report |
| Policy and Context Disclosure (A–E, or A–D for service providers) | Every applicant and signatory | On first application, then at least every fourth year | FRC, How to apply |
| Governing-body approval; signature by chair, CEO or CIO | Every applicant | Before submission | FRC, How to report |
| Report covering 12 months ending no earlier than a year before the deadline | Every applicant | Each submission | FRC, How to apply |
| Submit by the window deadline | All applicant types | Next: 31 Oct 2026 | FRC, How to apply |
| Publish the report on own website | Accepted signatories | Within one month of FRC notice | FRC, How to apply |
| Do not claim signatory status before acceptance | New applicants | Until the result is published | FRC, How to apply |
| Disclose commitment to the Code or alternative strategy | FCA firms managing investments for non-natural professional clients | Ongoing, on the website | COBS 2.2.3R |
| Engagement policy and annual implementation, or explain | Asset managers investing in regulated-market shares | Annually | COBS 2.2B.5R |
The other UK regimes are on the UK sustainability reporting requirements hub.
Who reports
Who signs up, and who has a legal duty anyway
The FRC’s application page names three groups who should apply: asset owners, asset managers and service providers.
Asset owners include pension schemes, insurers, foundations, endowments and sovereign wealth funds.
The FRC notes that The Pensions Regulator’s guidance encourages pension schemes to become signatories, and that government guidance recommends it for Local Government Pension Scheme administering authorities.
Asset managers are those managing assets for UK clients or investing in UK assets.
Service providers are investment consultants, proxy advisors and engagement service providers, a distinct category in the 2026 Code.
A global group should report once as a single organisation where it can, and a UK entity may report alone with an explanation of its scope.
On 9 July 2026 the FRC listed 290 signatories: 197 asset managers, 74 asset owners and 19 service providers.
An investor or a firm that serves investors
Service providers
Disclosures A–D, and Principles 1–4: communicating with clients, proxy advice, investment consulting, engagement services.
Principle 1 for all; 2–4 by service.FCA-regulated asset managers
Whether or not they sign, COBS 2.2.3R requires a website disclosure of their commitment to the Code or their alternative strategy.
A legal duty, separate from signatory status.What is reported
Stewardship Code reporting requirements: the two reports
The Policy and Context Disclosure gives the context: the organisation, its governance and resourcing, and links to its policies.
Each of its Disclosures breaks down into disclosure requirements the applicant should report against.
The Activities and Outcomes Report shows how the Principles were applied through the year’s activities and what came of them.
Each Principle carries “how to report” prompts, which the FRC says form the basis of its assessment.
Reporting should cover all asset classes and geographies proportionately, with examples reflecting the breakdown given in the Policy and Context Disclosure, or an explanation.
Policy documents and full voting records need not be reproduced, but the report must stand on its own without the reader having to follow links.
The FRC’s guidance is optional, and the FRC says it is not a de facto reporting requirement.
| Policy and Context Disclosure | Activities and Outcomes Report |
|---|---|
| A · Organisation, investment beliefs and stewardship approach | 1 · Integrating stewardship and investment |
| B · Governance and resources | 2 · Promoting well-functioning markets |
| C · Policies, processes and review | 3 · Engagement |
| D · Conflicts of interest | 4 · Exercising rights and responsibilities |
| E · Dialogue with clients and/or beneficiaries | 5 · Selection and oversight of managers |
| — | 6 · Monitoring service providers |
By investment model
Which Principles an organisation reports on
| Principle | Investing directly | Using external managers |
|---|---|---|
| 1 · Integrating stewardship and investment | Required | Required |
| 2 · Promoting well-functioning markets | Required | Required |
| 3 · Engagement | Required | Optional |
| 4 · Exercising rights and responsibilities | Required | Optional (report if voting rights are retained) |
| 5 · Selection and oversight of managers | Not required | Required |
| 6 · Monitoring service providers | Required | Required |
Service providers report Principle 1, communicating with clients, and then the Principle for their service: 2 for proxy advisors, 3 for investment consultants, 4 for engagement service providers.
“Apply and explain” means applying every relevant Principle in line with the organisation’s own policies and explaining how it did so over 12 months.
When
Windows, deadlines and valid reporting periods
The Code has two application windows a year, and the FRC set three 2026 dates on its Code page.
Asset managers and service providers applied in the spring window by 30 April 2026, and asset owners by 31 May 2026.
All applicants may use the autumn window, which closes on 31 October 2026.
A report must cover 12 months ending no earlier than a year before the deadline, so for 31 October 2026 the period must start on or after 1 November 2024 and end on or after 31 October 2025.
Many applicants report on the calendar year or their own financial year.
Both the application form and the report must reach the FRC by the deadline, and the report must be a PDF or Word file of no more than 20 MB.
The FRC had not published its 2027 dates on the pages read on 11 October 2026.
| 12-month period | For the 31 Oct 2026 deadline |
|---|---|
| 1 Apr 2024 – 31 Mar 2025 | Not accepted |
| 1 Jul 2024 – 30 Jun 2025 | Not accepted |
| 1 Oct 2024 – 30 Sep 2025 | Accepted |
| 1 Jan 2025 – 31 Dec 2025 | Accepted |
| 1 Apr 2025 – 31 Mar 2026 | Accepted |
| 1 Oct 2025 – 30 Sep 2026 | Accepted |
The four-year cycle
An annual report, and a disclosure every fourth year
Every applicant in 2026 filed both reports, as one document or two.
In the two years after, a signatory whose Policy and Context Disclosure is still accurate files only the Activities and Outcomes Report.
In the fourth year it files both again, so a first filing in 2026 means the next disclosure by 2029 at the latest, per the FRC’s submission table.
If the organisation changes so that the disclosure no longer matches its annual report, it files an update at its next usual window.
An unsuccessful first-time applicant reapplies with a full report covering both parts.
- 2026
Both reports
Policy and Context Disclosure plus Activities and Outcomes Report. - 2027
Activities and Outcomes only
If the Policy and Context Disclosure is still accurate. - 2028
Activities and Outcomes only
Same condition. - 2029
Both reports
The fourth-year Policy and Context Disclosure is due.
Signatory status
How the FRC assesses a report
The FRC assesses each report against the Code in a way that is proportionate to the organisation’s size and type.
The assessment is reviewed and discussed among FRC staff, and a sample of reports across applicant types goes to the FRC’s panel of independent advisors for consistency.
Only what is in the submitted report counts, and links to external documents add context without forming part of the assessment.
A new applicant must not call itself a signatory to the 2026 Code until its application is accepted and the result published.
In the 2026 transition year existing signatories that submitted in their usual window stayed on the list without an immediate assessment, and the FRC says assessment resumes in 2027.
The FRC’s Head of Stewardship said on its podcast that the only way to get the transition year wrong was not to submit anything.
Once accepted, the report is public on the FRC’s signatories page, and the signatory must publish it on its own website within one month.
The legal duty
COBS 2.2.3R: comply or explain for asset managers
COBS 2.2.3R reads: a firm, other than a venture capital firm, which is managing investments for a professional client that is not a natural person must disclose clearly on its website, or in another accessible form, the nature of its commitment to the FRC’s Stewardship Code or, where it does not commit to the Code, its alternative investment strategy.
The rule requires a disclosure, not a signature, so a manager can comply without being a signatory.
It came in with the FCA’s Stewardship Code Instrument 2010, and the FRC’s application page refers to it directly.
A separate rule, COBS 2.2B.5R, implements the Shareholder Rights Directive: managers investing in shares traded on a regulated market publish an engagement policy and an annual account of how it was implemented, or a clear and reasoned explanation of why not.
That annual account includes a general description of voting behaviour, the most significant votes and the use of proxy advisors.
Pension trustees have their own statutory hooks: the statement of investment principles covers voting and engagement under regulation 2(3)(c), and large schemes carry the climate duty in SI 2021/839, explained on the pension scheme climate reporting requirements page.
Not required
What the Code does not ask
It does not make any investor a signatory by law, and losing or failing to gain signatory status is reputational, not a penalty.
It does not ask for a Policy and Context Disclosure every year.
It does not make the FRC’s guidance a requirement; good reporting can be achieved without it.
It does not require full policy documents or complete voting records in the report.
It does not trigger the FCA’s SDR naming rules by using “sustainable” in its definition of stewardship, as the FCA and FRC say on the SDR regime page.
Requirements still quoted that no longer apply
Reporting to the 2020 Code’s structure — reports from 2026 address the 2026 Code’s six Principles and two reports.
Proxy advisors and consultants reporting as asset managers — service providers have their own four Principles.
A full report every year — the Policy and Context Disclosure is due at least every fourth year.
The other regimes
Stewardship, SDR and company reporting
The Stewardship Code governs how investors act; the FCA’s Sustainability Disclosure Requirements govern how their products are named, labelled and reported, on the SDR reporting requirements page.
The companies stewards engage with report under UK SRS, published by the Department for Business and Trade on 25 February 2026 as voluntary standards.
The FCA’s PS26/19 puts listed companies in UKLR 6, 14, 15, 16 and 22 on a comply-or-explain basis across UK SRS, for accounting periods beginning on or after 1 January 2027, set out on the UK SRS reporting requirements page.
A signatory reporting on engagement in 2028 will be reporting on conversations held against those first disclosures, and on the transition plans described on the transition plan reporting requirements page.
Sector by sector, the investment regimes sit on UK sustainability reporting by sector, and the wider picture on the ESG reporting requirements page.
What is changing
Open items, labelled as such
The FRC has said it will publish insights on the quality of 2026 reporting later in the year, following its July announcement.
The 2027 application windows were not on the FRC pages read on 11 October 2026.
Full assessment of existing signatories resumes in 2027, which is the first real test of reports written to the 2026 Code.
Check yourself
Six statements on Stewardship Code reporting
Each answer names the FRC or FCA source it turns on.
The documents are collected on the FRC’s stewardship hub.
The Code’s content and history are on the UK Stewardship Code 2026 page.
True or false?
A signatory must submit a Policy and Context Disclosure every year.
Every organisation applies and reports on Principles 1, 2 and 6.
Losing signatory status is a legal penalty.
COBS 2.2.3R requires FCA-regulated asset managers to become signatories.
The FRC assesses documents linked from a stewardship report.
A report for the 31 October 2026 deadline may cover the calendar year 2025.
0 of 6 answered.
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Frequently asked
Stewardship Code reporting requirements, answered
Is reporting to the UK Stewardship Code a legal requirement?
No. The Code is a voluntary FRC code on an “apply and explain” basis, and organisations report to it to become or remain signatories.
The legal duty beside it is the FCA’s COBS 2.2.3R, which requires certain asset managers to disclose the nature of their commitment to the Code or their alternative investment strategy.
Who should report to the UK Stewardship Code?
The FRC names asset owners such as pension schemes, insurers, foundations, endowments and sovereign wealth funds; asset managers that manage assets for UK clients or invest in UK assets; and service providers — investment consultants, proxy advisors and engagement service providers.
What are the two reports under the 2026 Code?
The Policy and Context Disclosure, covering the organisation, its governance and resources, policies, conflicts and client dialogue, filed at least every fourth year; and the Activities and Outcomes Report, filed every year, showing how the Principles were applied in the preceding 12 months and with what outcomes.
What goes in the Policy and Context Disclosure?
For asset owners and managers, five Disclosures: A, organisation, investment beliefs and stewardship approach; B, governance and resources; C, policies, processes and review; D, conflicts of interest; and E, dialogue with clients and beneficiaries.
Service providers report four: organisation and services, governance and resources, policies, and conflicts.
How often is the Policy and Context Disclosure due?
Every fourth year at a minimum, or sooner if the organisation changes so that the disclosure no longer aligns with its Activities and Outcomes Report.
A signatory that files one in 2026 must file the next by 2029.
Can the two reports be combined?
Yes.
The FRC allows separate documents or a single combined submission, and a combined reporter is not required to update the Policy and Context part in years two and three.
Around a quarter of signatories filed separately in 2026, according to the FRC.
When is the next Stewardship Code deadline?
The FRC’s next application deadline is 31 October 2026, for asset managers, asset owners and service providers.
The report must cover a 12-month period starting on or after 1 November 2024 and ending on or after 31 October 2025.
What were the 2026 spring deadlines?
Asset managers and service providers by 30 April 2026, and asset owners by 31 May 2026.
The autumn window, for all applicants, closes on 31 October 2026.
Who must approve a stewardship report?
Both reports must be reviewed and approved by the applicant’s governing body and signed by the chair, chief executive or chief investment officer.
How does the FRC assess a stewardship report?
Against the Code, proportionately to the organisation’s size and type, reviewed among FRC staff, with a sample of reports reviewed by the FRC’s panel of independent advisors for consistency.
Only the content submitted in the report is considered; linked documents do not form part of the assessment.
What happened in the 2026 transition year?
Existing 2020 Code signatories that submitted a renewal in their usual 2026 window stayed on the signatory list without an immediate assessment.
New applicants faced the full assessment.
The FRC says assessment resumes in 2027, and autumn-window signatories remain listed until autumn 2027.
Which Principles must an asset owner report on?
All organisations apply and report on Principles 1, 2 and 6.
One investing directly reports on Principles 3 and 4, not 5.
One using external managers reports on Principle 5, and on Principle 4 if it retains voting rights; Principles 3 and 4 are otherwise optional for it.
What does COBS 2.2.3R require?
A firm, other than a venture capital firm, managing investments for a professional client that is not a natural person must disclose clearly on its website, or in another accessible form if it has none, the nature of its commitment to the FRC’s Stewardship Code or, where it does not commit to the Code, its alternative investment strategy.
Is the Stewardship Code the same as the SRD engagement policy?
No. COBS 2.2B, implementing the Shareholder Rights Directive, requires certain asset managers investing in shares on regulated markets to publish an engagement policy and an annual account of how it was implemented, including voting, or a clear and reasoned explanation of why not. It is a separate FCA rule on a comply-or-explain basis.
When does a stewardship report become public?
Once the FRC has accepted the applicant as a signatory, the report is listed on the FRC’s signatories page and the signatory must publish it on its own website within one month of being notified.
The Policy and Context Disclosure must stay on the website while it applies.
Can a UK entity of a global group report on its own?
The FRC asks organisations first to apply the Code across the business and report as a single global organisation.
Where that is not possible, the UK entity may report, with a clear explanation and a statement of the report’s scope.
Does the 2026 Code’s use of “sustainable” trigger the SDR naming rules?
No. The FCA and the FRC say the definition of stewardship does not conflict with the SDR naming and marketing rules, which apply only where sustainability terms describe the sustainability characteristics of a product.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 17 sources fromFinancial Reporting CouncilFinancial Conduct Authoritylegislation.gov.uk
- Financial Reporting CouncilUK Stewardship Code 2026
The Code, its application from 1 January 2026 and the two 2026 application windows.
- Financial Reporting CouncilHow to report on the UK Stewardship Code 2026
Disclosures A–E, Principles 1–6, the service-provider set, approval and signature, publication.
- Financial Reporting CouncilHow to apply to become a UK Stewardship Code 2026 signatory
The 31 October 2026 deadline, valid reporting periods, the four-year cycle and the assessment.
- Financial Reporting CouncilUK Stewardship Code 2026 Guidance
Optional, non-prescriptive reporting guidance, last updated 30 October 2025.
- Financial Reporting CouncilFRC publishes guidance to support Stewardship Code reporting (30 October 2025)
The guidance finalised after a call for comments.
- Financial Reporting CouncilFRC overhauls the Investor Stewardship Code (3 June 2025)
Publication, the new definition of stewardship and the effective date.
- Financial Reporting CouncilUK Stewardship Code signatories
The live list, updated 9 July 2026, with links to each report.
- Financial Reporting CouncilLatest UK Stewardship Code signatories confirmed during transition to the 2026 Code (9 July 2026)
290 signatories: 197 asset managers, 74 asset owners, 19 service providers.
- Financial Reporting CouncilStewardship
The FRC’s stewardship hub and earlier editions.
- Financial Reporting CouncilIn Conversation: UK Stewardship Code 2026 — what you need to know (4 September 2025)
The FRC’s Head of Stewardship on the transition year.
- Financial Conduct AuthorityFCA Handbook, COBS 2.2.3R
Disclosure of the nature of a firm’s commitment to the Stewardship Code, or its alternative strategy.
- Financial Conduct AuthorityFCA Handbook, COBS 2.2B — SRD requirements
The engagement policy and annual implementation disclosure, or a reasoned explanation.
- Financial Conduct AuthorityConduct of Business Sourcebook (Stewardship Code) Instrument 2010, FCA 2010/57
The instrument that introduced the COBS disclosure rule.
- Financial Conduct AuthoritySustainability Disclosure Requirements (SDR) regime
The FCA and FRC on “sustainable” in the Code’s definition and the SDR naming rules.
- legislation.gov.ukOccupational Pension Schemes (Investment) Regulations 2005, regulation 2
Trustees’ statement of investment principles, including voting and engagement policy.
- legislation.gov.ukOccupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
The separate statutory climate duty on large schemes.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
The issuer-side UK SRS disclosures stewards engage on from 2027.
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