SEC's Shareholder Activism Role After the '26 Proxy Season

Sidley Austin examines how SEC staff's reduced substantive review of Rule 14a-8 exclusion requests and evolving stewardship practices have reshaped the activism and engagement landscape for boards. The shift places more weight on direct, well-prepared investor dialogue and clear board rationale. Directors should reassess engagement strategies and disclosure practices in response to this less predictable regulatory environment.