The updated Code promotes greater transparency and accountability in the way investors engage with companies and manage assets on behalf of clients and beneficiaries, particularly in a period marked by heightened uncertainty.
In response to the 2008 global financial crisis and recommendations from the Walker Review, which recommended greater shareholder engagement and accountability to help prevent corporate governance failures, the FRC released the first UK Stewardship Code in July 2010.
The investment market has changed significantly since that inaugural publication, with major revisions of the Code made in 2012, 2020 and 2024, each evolving to include stronger expectations on ESG integration, transparency and outcomes-focused reporting.
More recently, the FRC ran a public consultation on proposed revisions from November 2024 to February 2025, involving extensive stakeholder engagement and feedback from over 1,500 participants.
This 2026 iteration aims to streamline reporting requirements, clarify stewardship objectives, and enhance transparency across the value investment chain. The new Code is set to take effect from 1st January 2026 with the remainder of 2025 to be served as a transition year.
The new definition of Stewardship: the updated Code redefines stewardship as “the responsible allocation, management, and oversight of capital to create long-term sustainable value for clients and beneficiaries" – importantly, doing so “without compromising the ability to do so in the future”. While this marks a shift from the 2020 Code, which explicitly referenced the environment and society, the new language reflects a more pragmatic and materiality–aligned approach to stewardship, focusing on tangible value creation.
Streamlined reporting requirements:
Collaborative Regulatory Approach
The FRC has worked closely with other regulators, including the Financial Conduct Authority (FCA), The Pensions Regulator (TPR), and the Department for Work and Pensions (DWP), to ensure the revised Code aligns with broader regulatory objectives and avoids duplication.
The UK Stewardship Code operates as part of a comprehensive regulatory framework alongside the FCA's oversight of financial markets, the Pensions Regulator's protection of member interests, and the DWP's pension scheme regulations.
Establishing itself as a global benchmark for best practice, the UK Stewardship Code drives transparency and accountability in the investment chain. It currently has nearly 300 signatories who represent around £50 trillion in assets under management (AUM).
However, the Code matters beyond finance, because it acts as a lever for systemic change, channelling private capital towards companies and activities that contribute positively to People, Planet and Prosperity. By holding investors and companies to higher standards of transparency, accountability and long-term, the Code supports a healthier society. Its newly released 2026 edition only builds on this success while responding to feedback from signatories and the wider investment and corporate issuer community.
Black Sun Global supports the FRC’s newly released 2026 UK Stewardship Code as it is rooted in our commitment to responsible business practices, expertise in ESG advisory, active participation in corporate governance initiatives, and alignment with the Code's goals of enhancing transparency and reducing reporting complexities.
To assist applicants with reporting to the UK Stewardship Code, the FRC has published a draft form guidance and welcomes input from stakeholders before the end of August 2025.
This guidance will be finalised in the autumn and will provide useful tips and examples to support effective implementation, particularly for those managing non-equity asset classes.
If you would like to speak to one of our experts about the wider impacts of the code, or about any aspects of your corporate disclosure please get in touch.
Read the UK Stewardship Code 2026 and its Feedback Statement.
UK Stewardship Code 2026: at a glance.
Read the Guidance introduced to assist applicants reporting to the UK Stewardship Code 2026.
Register your place at the FRC’s webinar on the UK Stewardship Code 2026, taking place at 3pm on Wednesday 18 June.
Black Sun Global is a stakeholder advisory and engagement agency that's been driving transformation and positive change for ambitious brands for more than 20 years. With deep expertise in disclosure and reporting, ESG, sustainability, and digital engagement, we reshape how organisations connect with customers, investors, employees, and the wider world.
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