The New Proxy Advisory Landscape and Its Expected Impact on Issuers

The proxy advisory environment is undergoing a significant shift driven by new regulatory pressures in the U.S. and the rapid integration of Artificial Intelligence. As the market moves toward a more fragmented and independent voting ecosystem, issuers must adapt their disclosure and engagement strategies to remain effective.

Heightened U.S. Regulatory Oversight

On December 11, 2025, a presidential executive order initiated a multi-agency review of major proxy advisors like ISS and Glass Lewis.

• Concerns: Federal agencies (SEC, FTC, DOJ, and DOL) are evaluating issues related to antitrust, potential politicization of voting advice, and foreign ownership.
• Impact: Regulators are considering requiring proxy advisors to register as investment advisers and applying anti-fraud provisions to their recommendations.

AI as a Process Accelerator

AI is fundamentally changing how asset managers evaluate disclosures and governance risks at scale.

• Internalization: Major institutions are moving away from external advisors in favor of internal AI platforms. For example, JP Morgan Asset Management transitioned U.S. voting analysis to its "Proxy IQ" platform effective April 1, 2026.
• Reduced "Blind Voting": The use of AI allows investors to move beyond automated third-party recommendations toward proprietary, data-driven voting logic.

Strategic Shifts by Proxy Advisors

In response to market and regulatory pressure, proxy advisors are evolving their business models.

• Glass Lewis: Starting in 2027, Glass Lewis plans to move from a single "house policy" to offering multiple research perspectives, including management-aligned, governance-focused, active owner, and sustainability-focused views.
• ISS: ISS is launching a 2026 AI roadmap, including PolicySteward for automated voting recommendations and an AI assistant named "Stu" to enhance customizable workflows.

What This Means for Issuers

As voting outcomes become harder to predict due to increased customization, issuers should prioritize the following:

• Precise Disclosure: AI tools often parse language literally; meeting materials must be structured, machine-legible, and unambiguous.
• Targeted Engagement: Engagement must be year-round and continuous, focusing on how specific investors encode expectations into their proprietary tools.
• Focus on Executive Pay: Sensitivity around pay remains high, requiring boards to explain one-off awards and structures upfront rather than leaving them to investor inference.

Download our one-page overview for a snapshot of these developments and additional insights. If you are interested in our full report or you would like to discuss in further detail, please contact us.