Investor stewardship · FRC · apply and explain
The UK Stewardship Code 2026: voluntary, and reported every year
The UK Stewardship Code 2026 is the FRC’s voluntary code for those investing on behalf of savers and pensioners, published on 3 June 2025 and in effect from 1 January 2026.
It has six “apply and explain” Principles for asset owners and asset managers, and a separate set for service providers, according to the Code page.
Signatory status is granted by the FRC after it assesses a report; it is a mark, not a licence.
The current edition
The 2026 Code replaced the 2020 Code
The FRC’s stewardship pages record the Code’s history: a first edition in 2010, then editions in 2012 and 2020.
The UK Stewardship Code 2026 was published on 3 June 2025 after a consultation that ran from 11 November 2024 to 19 February 2025, and it took effect on 1 January 2026.
Its central change is a definition: stewardship is now about “the creation of long-term sustainable value for clients and beneficiaries”.
The FRC also set out to streamline reporting and reduce the burden on signatories compared with the 2020 Code.
A stewardship policy, checklist or report template written against the 2020 Code’s definition or reporting structure is therefore out of date from 1 January 2026.
- 2010First edition
Followed by editions in 2012 and 2020.
- 11 Nov 2024Consultation opens
Closed 19 February 2025.
- 3 Jun 2025UK Stewardship Code 2026 published
- 1 Jan 2026In effect
The 2020 Code is superseded.
- 31 Oct 2026Autumn application window closes
Who signs
Asset owners, asset managers, and now service providers
The 2026 Code covers asset owners and asset managers, and brings proxy advisors, investment consultants and engagement service providers in as a distinct signatory category.
The FRC’s 9 July 2026 announcement said 191 organisations, including six new asset managers, met the conditions to be signatories to the 2026 Code.
The total of 290 includes organisations that remain signatories from their last successful application under the 2020 Code, which is how the transition works.
The same announcement reported that about 70% of signatories cut the length of their reports, by an average of 20%, and that around a quarter submitted their two reports as separate documents.
Those are the FRC’s own figures, dated; the live list is on its site.
The six Principles
Which Principles you apply depends on how you invest
The FRC’s reporting guide sets out six Principles for asset owners and asset managers, and a table of which are required for an organisation that invests directly and which for one that uses external managers.
Principle 1 reads: signatories integrate stewardship and investment to deliver long-term sustainable value for their clients and beneficiaries.
Principle 6 reads: signatories monitor and hold to account stewardship service providers.
Engagement and the exercise of rights (Principles 3 and 4) are required for direct investors and optional for those investing through managers.
Selecting and overseeing managers (Principle 5) is the reverse: required where external managers are used, not required for a direct investor.
The FRC’s instruction is simple at the top: all organisations should apply and report on Principles 1, 2 and 6.
The finder applies the table to your investment model; the FRC’s 2026 guidance explains what good reporting against each looks like.
Principle finder · UK Stewardship Code 2026
The FRC: “All organisations should apply and report on Principles 1, 2 and 6.”
Every signatory files an annual Activities and Outcomes Report, and a Policy and Context Disclosure every fourth year or when its policies change.
Both are approved by the governing body and signed by the chair, chief executive or chief investment officer.
The autumn 2026 window closes on 31 October 2026.
Source: FRC, How to report on the UK Stewardship Code 2026, and the Code page.
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The FRC’s table
Required, optional, not required
| 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 |
| 5 · Selection and oversight of managers | Not required | Required |
| 6 · Monitoring service providers | Required | Required |
Reporting
Two reports, one annual, one every fourth year
Every signatory files an annual Activities and Outcomes Report: what it did as a steward in the year, and what came of it.
The Policy and Context Disclosure goes to the FRC every fourth year, or sooner if the organisation changes so that its disclosure no longer matches its Activities and Outcomes Report.
The two may be combined in one document, and the FRC says many signatories in 2026 chose a single report structured to separate the two.
Both must be reviewed and approved by the applicant’s governing body and signed by the chair, chief executive or chief investment officer.
In the 2026 transition, existing signatories submitting a renewal stay on the signatory list throughout, while new applicants go through the full assessment.
The last window of the year closes on 31 October 2026.
| Group | 2026 deadline |
|---|---|
| Asset managers and service providers (spring) | 30 April 2026 |
| Asset owners (spring) | 31 May 2026 |
| All applicants (autumn) | 31 October 2026 |
Status
Voluntary code, two legal duties beside it
The Code itself is voluntary: it operates on an “apply and explain” basis, and nothing in law makes an investor a signatory.
Two separate legal duties refer to stewardship all the same.
The first is the FCA’s COBS 2.2.3R: a firm, other than a venture capital firm, managing investments for a professional client that is not a natural person must disclose the nature of its commitment to the FRC’s Stewardship Code, or its alternative investment strategy.
That rule came in with the Stewardship Code Instrument 2010; it requires a disclosure, not a signature.
The second is for pension trustees: under regulation 2(3)(c) of the Investment Regulations 2005 a statement of investment principles covers their policy on voting and engagement, and regulation 2(4) counts climate change among the financially material considerations.
Large schemes also carry the statutory duty in SI 2021/839, explained on pension scheme climate reporting; it is mandatory where the Code is not.
The FCA’s product and entity rules are a third, distinct regime, on the Sustainability Disclosure Requirements page.
The regulators coordinate through the Stewardship Regulators Group, which the FRC chairs.
Being a signatory is a mark the FRC grants, sought for reputational and commercial reasons.
Losing it is reputational, not a legal penalty, and it is not a regulatory authorisation.
The other FRC code
The Corporate Governance Code is for companies, not investors
Searches for the Stewardship Code often turn up questions about the UK Corporate Governance Code, which is the code for the companies investors hold.
The FRC’s 2024 Corporate Governance Code has applied to financial years beginning on or after 1 January 2025, with Provision 29 applying from 1 January 2026.
Provision 29 asks the board to declare the effectiveness of material controls, and extends those controls to reporting, including narrative and ESG reporting.
It applies to companies in the commercial companies and closed-ended investment funds listing categories, wherever they are incorporated.
There is no 2026 Corporate Governance Code, and the Code deliberately contains no sustainability reporting requirement: the FRC said the Listing Rules and the Companies Act already require climate disclosures.
Where it fits
Stewardship and company sustainability reporting
Stewardship is what investors do with the information companies publish, so the two regimes meet.
From 2027 the companies most investors engage with report against UK SRS on a comply-or-explain basis under the FCA’s final rules in PS26/19, and the UK SRS and the FCA page sets out what they must disclose or explain.
A signatory reporting on engagement in 2028 will be reporting on conversations held against those first disclosures.
The wider picture, from ratings to frameworks, is on ESG reporting in the UK.
Membership bodies for the investment community, such as UKSIF, are described on sustainability reporting for membership organisations.
The Code is one of several sector regimes collected on UK sustainability reporting by sector.
Frequently asked
The UK Stewardship Code, answered
Is the UK Stewardship Code compulsory?
No. It is a voluntary code administered by the Financial Reporting Council, on an “apply and explain” basis.
Organisations choose to become signatories by submitting reports the FRC assesses.
Two separate legal duties refer to stewardship: FCA rule COBS 2.2.3R makes certain asset managers disclose their commitment to the Code or their alternative strategy, and pension trustees state their voting and engagement policy in their statement of investment principles.
What is a stewardship code?
A set of principles for investors on how they look after the assets they manage for clients and beneficiaries — engaging with companies, voting, and overseeing managers and service providers.
The UK’s is set by the FRC; the 2026 edition centres stewardship on the creation of long-term sustainable value for clients and beneficiaries.
What is the UK Stewardship Code 2026?
The current edition of the FRC’s Code, published on 3 June 2025 and in effect from 1 January 2026.
It superseded the 2020 Code, which followed editions in 2010 and 2012.
It has six Principles for asset owners and asset managers and a separate set for service providers.
What changed from the 2020 Code?
Three things in particular.
Stewardship is redefined around long-term sustainable value for clients and beneficiaries.
Reporting splits into an annual Activities and Outcomes Report and a Policy and Context Disclosure filed every fourth year or on change.
And service providers — proxy advisors, investment consultants and engagement service providers — are a distinct signatory category.
What are the six Principles?
For asset owners and asset managers: integrating stewardship and investment; promoting well-functioning markets; engagement; exercising rights and responsibilities; selection and oversight of managers; and monitoring service providers.
Which are required depends on whether the organisation invests directly or through external managers, but the FRC says all organisations should apply and report on Principles 1, 2 and 6.
When are UK Stewardship Code applications due?
For 2026 the FRC set three dates: asset managers and service providers by 30 April 2026, asset owners by 31 May 2026, and all applications in the autumn window by 31 October 2026.
Existing signatories renewing during the transition stay on the list throughout; new applicants go through the full assessment.
How many signatories does the UK Stewardship Code have?
On 9 July 2026 the FRC said the Code had 290 signatories: 197 asset managers, 74 asset owners and 19 service providers.
That total includes organisations remaining signatories from their last successful application under the 2020 Code; 191 organisations met the conditions for the 2026 Code.
What are the key changes to the UK Corporate Governance Code in 2026?
The 2024 Corporate Governance Code has applied to financial years beginning on or after 1 January 2025.
Provision 29, the board’s declaration on the effectiveness of material controls, including controls over narrative and ESG reporting, applies to financial years beginning on or after 1 January 2026.
There is no 2026 Corporate Governance Code, and the Code contains no sustainability reporting requirement.
Is the Stewardship Code an ESG reporting requirement?
No. It is a code about how investors exercise stewardship, which may include environmental, social and governance matters.
Company sustainability reporting is a separate subject: listed companies report against UK SRS on a comply-or-explain basis under the FCA’s rules from 2027, and asset managers face the FCA’s Sustainability Disclosure Requirements.
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.
- Financial Reporting CouncilFRC overhauls the Investor Stewardship Code (3 June 2025)
Publication on 3 June 2025, effect from 1 January 2026, the new definition of stewardship, and the consultation.
- Financial Reporting CouncilUK Stewardship Code 2026
“Apply and explain” Principles for asset managers and owners, and separate Principles for service providers.
- Financial Reporting CouncilHow to report on the UK Stewardship Code 2026
The six Principles, the required and optional table, the two reports, approval and signature, and the 2026 windows.
- Financial Reporting CouncilUK Stewardship Code 2026 Guidance
The FRC’s guidance on applying the Principles.
- Financial Reporting CouncilStewardship
Earlier editions (2010, 2012, 2020) and the Stewardship Regulators Group, which the FRC chairs.
- Financial Reporting CouncilLatest UK Stewardship Code signatories confirmed during transition to the 2026 Code (9 July 2026)
The FRC’s own signatory counts, and what the first 2026 reports looked like.
- Financial Conduct AuthorityFCA Handbook, COBS 2.2.3R
A firm managing investments for a professional client discloses its commitment to the Code or its alternative strategy.
- Financial Conduct AuthorityConduct of Business Sourcebook (Stewardship Code) Instrument 2010, FCA 2010/57
The instrument that introduced the disclosure rule.
- legislation.gov.ukOccupational Pension Schemes (Investment) Regulations 2005, regulation 2
Trustees’ statement of investment principles: voting and engagement policy, and financially material ESG considerations.
- legislation.gov.ukOccupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021
The separate statutory climate duty on large schemes’ trustees.
- Financial Reporting CouncilUK Corporate Governance Code 2024
Applies from 1 January 2025, Provision 29 from 1 January 2026, and no sustainability reporting requirement.
- Financial Conduct AuthorityPS26/19: Aligning listed issuers' sustainability disclosures with international standards
The issuer-side disclosures investors will engage on from 2027.
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