This is a practical guide to what’s changing, how the transition year works, and what good outcomes-led reporting looks like, based on FRC materials published in 2025 (incl. the 03/12/25 webinar and the Code pages). FRC (Financial Reporting Council)
What’s changing: evolution, not revolution
The 2026 UK Stewardship Code keeps the core intent of the 2020 framework, but tightens the emphasis on outcomes and gives more flexibility in how you present your story.
The three shifts to anchor on
| Shift | What it means in practice | What to do now |
| Outcomes-focused reporting | Translate stewardship into action and results, not just policies | Build reporting around decisions, progress, learning, and evidence |
| Clearer reporting structure | Reporting is split into Policy and Context Disclosure plus an annual Activities and Outcomes Report | Decide whether to publish as 1 combined document or 2 separate documents |
| Flexibility by signatory type | FRC recognises different models across asset owners, asset managers, service providers and asset classes | Tailor your narrative to how you actually deliver stewardship |
The Code’s structure is explicitly two-part:
- Policy and Context Disclosure submitted every 4 years (or sooner if your context changes), and
- Activities and Outcomes Report submitted annually.
You can submit them as separate documents or a single combined submission, and you can write principle-by-principle or as a narrative.
Outcomes-focused reporting: what counts as an outcome
The FRC guidance is clear that outcomes are not limited to neat, finished, company-level changes in-year.
Examples of valid outcomes include:
- progress on an engagement that is still ongoing, plus next steps
- lessons learned from an engagement that did not progress
- relationship-building that improves the quality of dialogue
- an investment decision informed by engagement (including hold or avoid, not just buy or sell)
What outcomes reporting is not:
- claiming direct causation from a single conversation
- implying every engagement must produce an external real-world change within the reporting period
2026 is a transition year: what that really means
If you are an existing signatory:
- 2026 will be treated as a transition year.
- Existing signatories submitting a renewal application will remain on the signatory list throughout 2026.
This is designed to encourage you to embrace the updated, more flexible reporting format without the immediate risk that experimentation knocks you off the list.
If you are a new applicant in 2026:
- New applicants (not signatories to the 2020 Code in 2025) are still subject to the full assessment process.
What good looks like: principles that lift quality
1) Proportionality to your asset mix
Your reporting should reflect what you actually manage and where stewardship effort is applied (not just listed equity by default). The guidance explicitly supports reporting across non-listed equity asset classes too.
2) Demonstrate value to beneficiaries
Treat the report as a decision-useful explanation of how stewardship protects and grows long-term value on behalf of end savers, not as a compliance artefact.
3) Connect the dots
Show the chain:
- beliefs and context (Policy and Context)
- priorities and activity (Activities)
- results, progress, decisions, learning (Outcomes)
The FRC guidance explicitly calls for consistency between what you say in Policy and Context and what you demonstrate in the annual report.
4) Use Case Studies Effectively
- Pick case studies that illuminate how stewardship influenced judgement or action
- For asset owners: contextualize manager case studies with your own commentary
- Explain why you’ve included each example
Quick decision framework: one report or two?
You must cover both parts, but you can choose the packaging.
Consider 2 documents if:
- your policies and context are stable and you want a cleaner annual story
- you want the annual report to be tighter and more outcomes-led
Consider a single combined document if:
- your current report is already concise and readable
- your audience prefers one artefact
Either approach is acceptable under the Code.
Key dates to note for 2026 applications:
Two submission windows are set out by the FRC:
- Spring 2026:
- Asset managers and service providers: due 30/04/26
- Asset owners: due 31/05/26
- Autumn 2026:
- All applications: due 31/10/26
Action checklist for 2026 reporting:
Now:
- Read the Code overview and reporting structure
- Read the reporting guidance sections relevant to your signatory type and asset mix
Next 8–12 weeks:
- Decide your reporting format: 1 combined report vs 2 documents
- Identify 5 – 8 outcomes you can evidence (including progress and decision outcomes)
- Pick 3 – 5 case studies that show how stewardship shaped decisions, not just activity
During 2026:
- Use the transition year to improve clarity and readability
- Focus on outcomes and learning, not volume
How Maanch can help signatories deliver Code 2026-ready reporting
If you’re staring down Code 2026 and thinking the hard part isn’t intention, it’s execution, you’re not alone. The shift to outcomes-focused reporting means asset managers need to prove their stewardship influenced decisions, not just that activities happened. But most teams are stuck with:
- Engagement notes scattered across emails, OneNote, and Excel
- No clear link between stewardship activities and investment decisions
- Manual compilation that takes months every year
- Struggle to report proportionately across asset classes
- Case studies that take days to produce and still feel thin on outcomes
Maanch is the stewardship intelligence platform purpose-built for outcomes-focused reporting. Maanch helps teams turn day-to-day activity into clear, outcomes-led reporting without the end-of-year scramble.
By centralising engagement plans, interactions, votes, actions and outcomes in one place, it creates a clean evidence trail you can reuse across submissions. Teams can standardise what gets captured through templates and prompts, tag activity to objectives and themes, and pull proportionate reporting across asset classes and portfolios, so fixed income, private assets and listed equity don’t get treated like afterthoughts.
Crucially, Maanch is built to integrate easily with internal and external data sources, so you can correlate evidence with what your team actually did and what changed. That might include linking holdings and portfolio metadata, vote files, engagement notes, issuer data, controversy signals, and third-party ESG or engagement datasets into a single engagement record. The payoff is simple: a stronger, more defensible outcomes narrative because your activities sit alongside the supporting data trail in one place, ready for reporting and review.
Practically, that means signatories can separate Policy and Context from annual Activities and Outcomes with far less duplication, produce sharper case studies, and show how engagement informed decisions (hold, avoid, escalate, vote) in a way that’s easy for beneficiaries, clients, and portfolio companies to follow.
