The UK Stewardship Code 2026
The FRC's UK Stewardship Code 2026 — published on 3 June 2025 and in effect from 1 January 2026 — is the current edition, superseding the 2020 Code. It is a voluntary, 'apply and explain' reporting framework for asset owners, asset managers and, newly, service providers. Being a signatory is a reputational mark the FRC grants, not a legal duty.
It is the 2026 Code now — the 2020 Code is superseded
Published in June 2025, effective from January 2026, with a new definition of stewardship.
518 The UK Stewardship Code 2026is the current edition: the FRC published it on 3 June 2025 and it took effect on 1 January 2026, superseding the 2020 Code. It is a voluntary code of reporting principles for investors; organisations become “signatories” by submitting a stewardship report that the FRC assesses against the Code. The 2026 revision redefines stewardship around the creation of long-term sustainable value for clients and beneficiaries, and is designed to streamline reporting and reduce burden relative to the 2020 Code.
- 3 JUN 2025UK Stewardship Code 2026 published
- 1 JAN 20262026 Code takes effect; 2020 superseded
Asset owners, managers and service providers — two report types
A new signatory category, and a split between a periodic policy disclosure and an annual outcomes report.
519The 2026 Code applies to asset owners, asset managers and — new in this edition — service providers (proxy advisors, investment consultants and engagement service providers), brought in as a distinct signatory category. Signatories report against the Code’s principles, with the 2026 structure separating a Policy and Context Disclosure (required roughly once every four years) from an annual Activities and Outcomes Report; the two may be combined into one document.
Policy once, outcomes annually
The Policy and Context Disclosure is required roughly once every four years, while the Activities and Outcomes Report is annual — a deliberate change from the 2020 Code to cut the burden of rewriting the full policy narrative each year, while keeping an annual account of what stewardship actually achieved.
Voluntary and reputational — not a statute
Signatory status is a mark, sought for reputational and commercial reasons, not a legal obligation.
520 The Stewardship Code is voluntary. Signatory status is a mark the FRC grants after assessing a report; it is sought for reputational and commercial reasons — asset owners often expect their managers to be signatories — not because the law compels it. The Code operates on an “apply and explain” basis and sits alongside, but is separate from, the FCA’s stewardship expectations and the wider Sustainability Disclosure Requirements.
What is the UK Stewardship Code 2026?
It is the current edition of the Financial Reporting Council's UK Stewardship Code — a voluntary code of reporting principles for investors.
The FRC published it on 3 June 2025 and it took effect on 1 January 2026, superseding the 2020 Code.
Organisations become 'signatories' by submitting a stewardship report that the FRC assesses against the Code.
The 2026 revision redefines stewardship around the creation of long-term sustainable value for clients and beneficiaries, and is designed to streamline reporting and reduce burden relative to the 2020 Code.
Is the UK Stewardship Code mandatory?
No.
It is a voluntary code, not a statute.
It operates on an 'apply and explain' basis and sits alongside — but is separate from — the FCA's stewardship expectations and the wider Sustainability Disclosure Requirements.
Signatory status is a mark the FRC grants after assessing a report, sought for reputational and commercial reasons (asset owners often expect their managers to be signatories), not because the law compels it.
The consequence of not meeting the Code is loss of, or failure to gain, signatory status — which is reputational, not a legal penalty.
Who does the 2026 Code apply to?
Asset owners, asset managers, and — new in this edition — service providers, meaning proxy advisors, investment consultants and engagement service providers, brought in as a distinct signatory category.
Do not assume the 2020 Code's structure or the categories of signatory still apply; the 2026 Code changed both the definition of stewardship and the way signatories report.
How do signatories report under the 2026 Code?
The 2026 structure separates a Policy and Context Disclosure — required roughly once every four years — from an annual Activities and Outcomes Report, and the two may be combined into a single document.
This is a deliberate change from the 2020 Code, intended to reduce the reporting burden by not requiring the full policy narrative to be rewritten every year while keeping an annual account of what stewardship activity actually achieved.
How is this different from the 2020 Stewardship Code?
The 2020 Code is superseded by the 2026 Code from 1 January 2026.
The 2026 revision changes the definition of stewardship (centring it on long-term sustainable value for clients and beneficiaries), streamlines reporting into a periodic Policy and Context Disclosure plus an annual Activities and Outcomes Report, and adds service providers as a signatory category.
A page, policy or checklist written against the 2020 Code's definition or reporting structure is out of date.
Is the Stewardship Code a sustainability or ESG reporting requirement?
It is an investor-stewardship code rather than a sustainability-reporting standard, though the two overlap: stewardship includes how investors consider material environmental, social and governance issues in managing assets.
It is not the same as company-level sustainability reporting such as the UK Sustainability Reporting Standards, the FCA's SDR, or TCFD — it is a voluntary code about how investors exercise stewardship, administered by the FRC.
Related guides & references
UK Sustainability Reporting by Sector
The directory of industry-specific reporting regimes, including the finance and investor rules
Pension Scheme Climate Reporting (TCFD)
The mandatory trustee climate duty that asset-owner signatories to the Code often also face
FCA Sustainability Disclosure Requirements
The FCA's regulatory regime for firms and products — separate from the voluntary Code
ESG Reporting in the UK
Where investor stewardship sits within the wider ESG and sustainability-reporting landscape