UKSIF response: FRC’s UK Stewardship Code 2026 Guidance

We welcome the opportunity to provide feedback on the recently published draft guidance for the UK Stewardship Code 2026. It is broadly positive to see the Financial Reporting Council (FRC) opt to produce this very helpful guidance, which we hope can be valuable in supporting UKSIF’s members to report on their stewardship-related policies, activities, and outcomes over the coming months during the transition to the new Code.

We hope that the Stewardship Code guidance, which in its current draft form has generally been well-received by our members, can help meaningfully reduce the potential reporting burden incurred in the short-term for signatories and the additional costs associated with the new reporting requirements.

We would highlight upfront our broad overall support for the FRC’s draft Code guidance as currently published, which contains a number of important points and strengths. These include the following: the relatively flexible language it has adopted that complements the new Code’s principles, the direct references to systemic risks (e.g. guidance that signatories describe efforts to mitigate these risks to deliver good client outcomes), the inclusion of dedicated guidance on stewardship ‘case studies’, the recognition of the role of stewardship played across different asset classes beyond listed equities, among other areas.

We would like to see the finalised guidance help reinforce the Code’s expectations to signatories and prospective signatories that a high-quality standard for investor stewardship practice and stewardship reporting under the revised Code remains in place in the UK’s market. This will be a very important message to convey to our industry, given the perception from some of our members that the revised Code has, in some respects, experienced some dilution in terms of its overall ambition and role as an effective accountability mechanism for good stewardship among investors.

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