FRC confirms final 2020 signatories as industry transitions to the 2026 Stewardship Code

The UK's Financial Reporting Council has confirmed the final cohort of organisations accepted under the UK Stewardship Code 2020. In total, 291 organisations, representing £57.3 trillion in assets under management, now make up the complete list of 2020 signatories - bringing that framework to a definitive close.

The announcement marks more than an administrative milestone. It signals the end of one stewardship reporting era and the full transition to the UK Stewardship Code 2026, which came into force on 1 January 2026.

The transition is already underway

The FRC has confirmed that no further applications will be assessed under the 2020 Code. Organisations not included in the final list can only seek signatory status under the revised 2026 framework.

While 2026 functions as a transition year - allowing existing signatories to renew under the 2020 Code during the year - the direction of travel is clear. The expectations, structure, and purpose of stewardship reporting have materially changed, and firms will need to adapt accordingly.

The scale of that transition is significant. The final signatory cohort includes 197 asset managers, 75 asset owners, and 19 stewardship service providers. Collectively, these organisations manage £57.3 trillion in assets - equivalent to approximately two-thirds of global GDP - underscoring the systemic importance of stewardship outcomes under the new framework.

What is fundamentally different about the 2026 Code

The 2026 Code is not simply a lighter version of its predecessor. Its changes reflect a deliberate shift in regulatory intent.

Key structural differences include:

• A streamlined framework, with Principles reduced from 12 to 6 and an estimated 20–30% reduction in reporting volume

• Multi-year policy reporting, with Policy & Context Disclosures required every four years rather than annually

• A stronger focus on outcomes, placing greater weight on demonstrating the impact of stewardship activities over time

• Expanded scope, introducing dedicated Principles for proxy advisers and stewardship service providers

• A refined definition of stewardship, explicitly focused on long-term sustainable value creation for clients and beneficiaries

Taken together, these changes move stewardship reporting away from annual policy updates and toward longer-term, evidence-based narratives of stewardship activity and impact.

From reporting frequency to reporting quality

One of the most significant implications of the 2026 Code is operational rather than conceptual.

Four-year policy cycles, combined with annual activity reporting and a heightened emphasis on outcomes, require firms to maintain continuity, consistency, and evidential integrity over much longer time horizons. Engagements often span multiple years, asset classes, and team - yet must ultimately be reported as coherent stewardship stories.

For asset managers, asset owners, and service providers, this creates several practical challenges:

• Tracking engagement activity consistently across time, teams, and asset classes

• Linking individual stewardship actions to longer-term outcomes and objectives

• Coordinating multi-year policy disclosures with annual reporting requirements

• Maintaining the level of transparency and auditability the FRC expects under the new framework

These are not new activities - but under the 2026 Code, the standard of evidence required to support them is higher.

What the regulator is signalling

The FRC developed the 2026 Code following consultation with more than 1,500 market participants. The message emerging from that process is clear: the regulator wants to see genuine stewardship in practice, not well-written policies disconnected from real-world activity.

That places greater importance on systems and processes that can capture stewardship activity as it happens, retain context over time, and support outcome-focused reporting - rather than relying on retrospective, manual collation.

Looking ahead

The confirmation of the final 2020 signatories closes one chapter in the UK’s stewardship journey. The next chapter will be defined by how effectively firms can demonstrate long-term stewardship outcomes under the 2026 framework.

At Impactive, we work closely with stewardship teams navigating this transition, and we are seeing a clear shift toward more structured, outcome-led approaches to engagement tracking and reporting. Firms that invest early in the right infrastructure will be better positioned not only to meet regulatory expectations, but to demonstrate genuine leadership in stewardship.

The UK Stewardship Code has always been about more than compliance. Under the 2026 framework, that principle remains unchanged - but delivering on it now requires a more robust, long-term approach.

The full list of signatories following the Autumn 2025 applications can be found here.

We'd love to hear how you're approaching your engagement tracking. Get in touch for a discovery call.