ESG Litigation & Enforcement Tracking

2025 Environmental Shareholder Proposal Trends

Early season results show that average support for environmental proposals is approximately 9.6%, continuing a several-year trend of decreased support, and dropping significantly from a 16.9% average in 2024.

As of June 16, 2025, shareholders submitted 140 known environmental proposals, 82 of them climate-related. No environmental proposals received majority support.

Conservative Proposals

• Of the 140 known environmental proposals, 14 were conservative, or anti-ESG, proposals. One emissions-related proposal went to vote but did not pass.
• Although anti-ESG proposals have become more common, average support this year hovered around 1.5%—relatively consistent with anti-ESG support since 2023.
• Nevertheless, 131 anti-ESG proposals have been submitted by shareholders in the 2025 proxy season, an increase of 17% from 2024.
• Over two-thirds of these anti-ESG proposals focused on DEI-related initiatives.

No-Action Letters

As of May 16, 2025, companies submitted 59 requests for no-action relief to the SEC related to environmental proposals. The SEC granted 26 and rejected 21 requests, and the rest were withdrawn. Of those no-action requests granted by the SEC, 85% were due to the “ordinary business” exception.

Anti-ESG proposals account for 22% of no-action requests, but only 15% of all shareholder proposals. Most anti-ESG environmental proposals focused on greenhouse gas emissions and the costs of climate-related risk mitigation efforts.

Moving Forward

Support for environmental proposals declined sharply in 2025. This occurred in the context of a series of Executive Orders targeting expanding domestic energy production and regulations that decrease investment in renewable energy. Company-friendly changes to the SEC’s shareholder proposal rules, a rollback of the climate change rules, and changing executive priorities are likely to shape the coming proxy seasons.

We expect this trend in downward support for environmental proposals to continue in the United States.

2024 Environmental Shareholder Proposal Trends

Summary

Early season results have continued the downward trend in average support for environmental proposals observed since 2021. These results largely reinforce the same shareholder proposal trends from last year.

As of June 30, 2024, approximately 190 known environmental proposals were submitted, 130 of them climate-related. Only three environmental proposals received majority support.

Trends in Proposal Topics

• Of the 189 known environmental proposals, 15 were conservative proposals. 13 went to vote, with average support of 1.9%.
  • 8 companies sought no-action relief from the SEC. The SEC did not concur with 6 requests and concurred with the remaining on procedural grounds because the proposals did not meet the submission threshold.
• Anti-ESG proposals in general have increased by 19% to 112 proposals so far this season.
  • Social proposals make up the vast majority of anti-ESG proposals at 71% (80 out of 112).
  • 60 have gone to vote, with 33 proposals still pending.
  • None of the proposals have received majority support, with average support of 2.8%.

No-Action Letters

In general, the SEC staff “has nearly doubled the number of exclusions” of shareholder proposals compared with 2023. The major increase in exclusions is largely a result of an increase in the number of no-action requests filed by companies.

As of June 14, 2024, companies submitted 44 requests for no-action relief to the SEC related to environmental proposals. The SEC granted 21 of these requests and rejected 14, while 9 were withdrawn. Numerous climate proposals were excluded as “micromanagement,” meaning the proposals were found to be too granular in their requests and were attempting to micromanage company activities.

Moving Forward

With the sustained level of involvement in the proxy process, it is likely that these trends will continue.

We can also expect that attention will shift to implications resulting from the 2024 election and any challenges to the SEC’s climate rule.

2023 Environmental Shareholder Proposal Trends

2023 Social Shareholder Proposal Trends