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ISS Sets 2026 Proxy Rules, Raising the Bar on Voting Rights and Pay

Investor feedback prompted tougher standards across voting rights, director pay, pay-for-performance, equity plans.

Overview

  • The updated ISS benchmark policies apply to meetings on or after February 1, 2026, with no changes to director overboarding limits for 2026.
  • ISS will recommend against directors at companies with any multi-class structure that grants unequal voting rights, treating superior rights in common and preferred shares consistently with limited carve-outs.
  • Scrutiny of non-employee director compensation expands to cover consecutive or non-consecutive patterns of excessive or otherwise problematic pay, with the possibility of an immediate adverse recommendation for particularly egregious cases.
  • The quantitative pay-for-performance horizon extends from three to five years, with qualitative credit for long-term time-based vesting, and ISS introduces more discretion on say-on-pay responsiveness where companies disclose meaningful but unsuccessful engagement under recent SEC 13G/13D guidance.
  • Equity plan evaluations add a scored factor for cash-denominated award limits for directors and a new overriding negative for weak plan features, while environmental and social proposals move to fully case-by-case assessments focused on substantive shareholder interests.