Five ways to help you report against the updated UK Stewardship Code

The FRC has updated its Stewardship Code for the 2026 reporting season, evolving its guidance to improve efficiency and encourage a freer format. To help you with your own report, we’ve summarised our thoughts on the new process. 

1.    Tell your own story  

We believe case studies are the best way to illustrate your stewardship efforts. These studies should focus on how you invest responsibly and engage with managers, rather than repeating what your managers are doing. But they should also follow a simple formula of what you did and what the beneficial outcomes were for your members. And remember: your case studies don’t need to be restricted to voting and engagement activity. The FRC defines stewardship broadly, including investment allocations – so think bigger when you’re deciding which examples to highlight. 

2.    Be bold  

The updated Code allows more flexibility, both in terms of format and content, and the FRC has been clear that this shouldn’t be considered a tick-box exercise. For the annual activity and outcomes section of the report, this provides an opportunity to experiment – so don't be anchored to simply updating what was written last year.

3.    Make your reporting work for you

Before you begin, think about what you want to get out of your reporting. How and what do you want to communicate?

Remember, it's your story and your report. For example, if you’ve been focusing heavily on risk transfer or reviewing your strategy, this is an activity you should emphasise. Most pension schemes appoint investment managers, so monitoring of delegated activities should be a key theme that comes through in your reporting. We encourage asset owners to log and track progress of their engagement activity, and we think Code reporting is a great opportunity to demonstrate and add structure to this.

For LGPS funds, we see the Code as a useful vehicle for setting out not only your own role, but also your collaborative work with your partner funds and pools – this is especially relevant given the regulatory changes to the sector over the year. Stewardship Code reporting is also an important channel of communication to your members about your oversight and engagement efforts. 

4.    Cut, cut, cut

The FRC’s changes give you the chance to shorten and sharpen your reports. There’s less need for specific data and more scope to get to the point of your story quickly. We encourage you to spend more time articulating meaningful case studies that demonstrate your activity over the year narratively, rather than on information gathering.

5.    Start now 

If you need support, we can help familiarise you with the changes to the Code and what these mean. But starting earlier will give you more time to plan your approach. Having said that, we think reporting this year should be a lighter load overall – and 2027 even more so.

We can assist you with end-to-end support when writing your reports, from initial assessment and drafting to quality assurance and ongoing regulatory advice. Through our responsible investment services, we can also help you demonstrate your commitment by supporting your broader stewardship work.

If you'd like to discuss anything in more detail please don't hesitate to get in touch. 

Important information

This communication has been compiled by Hymans Robertson LLP® (HR) as a general information summary and is based on its understanding of events as at the date of publication, which may be subject to change. It is not to be relied upon for investment or financial decisions and is not a substitute for professional advice (including for legal, investment or tax advice) on specific circumstances.

HR accepts no liability for errors or omissions or reliance on any statement or opinion. Where we have relied upon data provided by third parties, reasonable care has been taken to assess its accuracy; however, we provide no guarantee and accept no liability in respect of any errors made by any third party.