29 April 2026
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An early snapshot of how investors are responding to the 2026 UK Stewardship Code is beginning to emerge just as another proxy season gets under way. A report released this month, based on a March roundtable at King’s College London, suggests that while the Code has clarified the purpose of stewardship, it has not eased the practical frictions that shape how it is delivered under pressure.
The roundtable, held on 6 March at The Dickson Poon School of Law, brought together asset owners, asset managers, regulators, corporates, advisers and academics to explore what the revised Code has changed inpractice, and what it has not. Rather than re‑litigating the text of the Code, discussions focused on how stewardship is now being interpreted and constrained across the investment chain.
The conclusion was not that stewardship has been reinvented. It was that long‑standing tensions around fiduciary duty, impact and execution are becoming harder to manage at a time of tighter timelines, higher scrutiny and growing political and regulatory sensitivity.
The most widely welcomed change in the 2026 Code is its revised definition of stewardship, reframed around the creation of long‑term sustainable value for clients and beneficiaries. For many investors, this has strengthened the legal and practical defensibility of stewardship by anchoring it more explicitly in fiduciary duty.
Yet there was little evidence at the roundtable of a step‑change in behaviour. Continuity with the 2020 Code, combined with the early stage of implementation, means most stewardship practices remain broadly intact. Clarification of purpose has not translated into greater consensus on scope.
Minerva’s Stewardship Code briefing highlights why this remains contentious. The removal of explicit references to environmental and social outcomes has been welcomed by some as a refocus on financial materiality but criticised by others as narrowing the perceived boundaries of legitimate stewardship. Even with softened supporting language from the FRC, uncertainty persists over how far stewardship extends when financial impacts are indirect, systemic or long‑dated.
That ambiguity was evident at the roundtable. Fiduciary duty was widely accepted as the foundation of stewardship, but opinions diverged on whether it primarily enables action or constrains it. Climate change was broadly accepted as financially material at portfolio level. Beyond that,confidence fell away.
Early findings from Minerva’s upcoming 2026 Horizon Scanning Survey help explain this divergence. In our analysis we found that asset owners tend to emphasise systemic and long‑term risks, while asset managers place greater weight on operational, regulatory and implementation risk. These differences are not ideological, but instead reflect mandates, time horizons and accountability; and they continue to shape how stewardship priorities are set in practice.
A second theme running through the roundtable was the dominance of what can be measured.
As expressed by attendees of the roundtable, voting remains the most visible and auditable expression of stewardship even though it captures only part of its substance. Engagement, escalation and outcomes are harder to observe, harder to compare and harder to evidence, despite often being where influence is greatest. Participants expressed concern that expanding reporting requirements continue to reward activity that is easiest to document rather than activity that is most impactful.
The 2026 Code attempts to address this through its revised reporting structure, separating periodic policy disclosures from annual reporting on activities and outcomes. In principle, this should shift attention towards results rather than process. In practice, Minerva’s analysis suggests it introduces a new execution risk if the link between stated policy intent and day‑to‑day stewardship decisions is not actively maintained.
Minerva’s survey reinforces this point; both asset owners and asset managers consistently cite execution frictions, not lack of intent, as the main constraint on effective stewardship over their voting. Tight voting deadlines, late or incomplete disclosures and fragmented voting infrastructure compress decision‑making and push teams towards standardisation, particularly during peak season.
The result is not surprising. Voting frameworks are generally more mature and consistent than engagement and escalation, not because investors believe voting matters more, but because itis easier to codify, monitor and defend. Engagement remains more siloed, less scalable and harder to link systematically to outcomes.
Misalignment across the stewardship ecosystem was a recurring theme of the Roundtable. Asset owners, asset managers, consultants, service providers and companies operate under different incentives, reporting pressures and time horizons. In this context, the Stewardship Code is seen less as a differentiator of quality and more as a coordinating baseline.
The 2026 Code arguably formalises this reality by differentiating reporting expectations depending on whether assets are managed internally or delegated, and on the role played by service providers. While this reflects real differences in authority and capability, it also embeds variation in how stewardship is defined and evidenced across the investment chain.
Minerva’s own survey findings suggest asset owners are increasingly responding by seeking tighter alignment mechanisms. These include clearer mandate specifications, more explicit escalation expectations and, in some cases, directed or split voting arrangements. Asset managers, meanwhile, are operating under rising political, legal and regulatory scrutiny, reinforcing a more cautious and defensible approach to voting and engagement.
Service provider concentration adds a further constraint. A highly concentrated proxy voting and stewardship services market, combined with high switching costs, risks entrenching standardisation at the point when investors are seeking more judgement‑led, differentiated outcomes.
System‑level stewardship featured prominently in the roundtable discussions. There was broad agreement that many of the most significant risks investors face operate at portfolio or system level rather than company by company, and that stewardship has a legitimate role where risks are non‑diversifiable and financially material.
Climate change was the most frequently cited example. Beyond that, uncertainty about boundaries remains a brake on action. How far can asset managers acting under delegated mandates credibly engage beyond individual companies? Where does legitimate stewardship end and contested advocacy begin?
Minerva’s analysis suggests that the tighter fiduciary framing of the 2026 Code, while helpful in some respects, may narrow the range of system‑level action investors feel able to defend, particularly in a more politicised environment. In practice, this is already shaping priorities.
Survey respondents report concentrating on issues with the clearest financial rationale and the most workable pathways for influence. Climate transition, shareholder rights and core governance controls dominate. Other themes fall away, not necessarily because they lack importance, but because the execution and defensibility risks are higher.
Taken together, the roundtable report, Minerva’s Stewardship Code briefing and early signals from our Horizon Scanning Survey point in the same direction.
Stewardship under the 2026 Code is more formalised and more scrutinised, but not necessarily more aligned. Purpose has been clarified without settling scope. Reporting has been streamlined without removing incentives to prioritise what is most visible. Fragmentation across the investment chain has been acknowledged without yet being resolved.
The immediate challenge for asset owners and managers is therefore not to redefine stewardship again, but to make clearer choices. That means sharper mandates, realistic expectations about operational constraints, and greater discipline over which issues genuinely justify escalation.
Without that clarity, stewardship risks remaining procedurally robust but strategically uneven. In the near term, the most practical progress is likely to come from the market itself, through closer scrutiny of industry codes, service‑provider practices and mandate conventions, with the harder test coming later as EU reforms to the Shareholder Rights Directive, determine whether stewardship frameworks can be better aligned across jurisdictions without adding to fragmentation in practice.
Alex Whitebrook
