Courtesy of Proxy Analytics, the data below summarizes no-action and shareholder proposal activity for the current proxy season through April 30 compared to prior seasons. For purposes of this analysis, each proxy season runs from July 1 – June 30. Proposals tracked are based on several sources including proxy statements, no-action letters, and pre-proxy publicly available information. Note that approximately 90% of shareholder meetings are held during the first six months of the calendar year.
No-action letters
Based on publicly available information, a record 374 no-action request letters have been submitted this season. The overall grant rate is 69.8% (compared to 68% last season) based on 278 no-action responses, with 18 currently pending and 69 withdrawn.
Shareholder proposals
At 852 tracked proposals, shareholder proposal volume is down approximately 13% year-over-year and 15% relative to full season 2024.
The average support for shareholder proposals overall is 22.4% compared to 22.9% for full season 2024, with Proxy Analytics expecting potential reduced support as the season unfolds, as was the case in 2024.
Average support levels for E&S shareholder proposals overall and by category, as well as Governance and Compensation proposals, are depicted here: