ESG Litigation & Enforcement Tracking

Executive Orders

Executive Order Targeted Proxy Advisors and Shareholder Proposals

On December 11, 2025, the White House published an Executive Order aimed at proxy advisors and shareholder proposals. Specifically, the Order called out Institutional Shareholder Services (ISS) and Glass Lewis, claiming that the firms “use their substantial power to advance and prioritize radical politically-motivated agendas – like ‘diversity, equity, and inclusion’ and ‘environmental, social, and governance.’” The Order argued that investor returns should be the only priority. The Order directed the chair of the Securities and Exchange Commission (SEC), chair of the Federal Trade Commission, and Secretary of Labor to review and, if necessary, revise regulations and guidance in accordance with the Order’s stated purposes. 

Among other directives, the Order also instructed the SEC chair to consider revising or rescinding rules related to shareholder proposals, including Rule 14a-8, that are inconsistent with the Order’s purpose. Rule 14a-8 has already been the subject of recent reconsideration by the SEC (for example, the chair’s keynote address and the SEC’s updated guidance). Before the Order’s issuance but amid the White House’s continued criticisms, ISS announced policy changes to its advising strategy, including a case-by-case approach to shareholder proposals on diversity and climate change. Glass Lewis similarly updated its advising approach, noting that further updates may be required given the ongoing changes in the shareholder proposal process.

For additional information, please visit our Executive Order Tracker.