How to apply to become a UK Stewardship Code signatory
Published: 24 September 2023
3 minute read
How to submit your Stewardship Report
Before submitting your Report
Please read the following documents:
If you are an existing signatory, please also read:
Interim Changes to Reporting for Stewardship Code Signatories
Submitting your Report
The application window is now closed. The next application window will be 30 April 2025 for Asset Mangers and Service Providers and 31 May 2025 for Asset Owners
When to publish your Stewardship Report 2020 on your website
There are two options available regarding the publication of Reports. Applicants may:
- Publish their Stewardship Report at the same time as they submit it to the FRC; or
- Wait until the FRC have confirmed if they will be signatories before publishing their Report.
Applicants must not refer to themselves as a signatory to the UK Stewardship Code 2020 before their application has been accepted and the result published.
Once an applicant has been accepted as a Code signatory and the Report is approved by the FRC, the Report will be a public document and must also be made available on the signatory’s website.
Application
Organisations will have to submit a final annual Stewardship Report explaining how they have applied the Code over a 12-month period. The Report must be reviewed and approved by the applicant’s governing body, and signed by the chair, chief executive or chief investment officer.
All organisations, regardless of whether they are a first-time applicant, a reapplicant, or a signatory applying to renew their status, must submit a report that covers a 12-month period ending no earlier than a year before the relevant application deadline. In the case of some reapplicants, to ensure an appropriate reporting period your reapplication may need to cover a different 12-month period to the one that you submitted for your original application. Many applicants choose to report to the most recent calendar year, or to their own financial year.
The next spring assessment period will have two deadlines. Applications from asset managers and service providers will be due by 30 April 2025. Applications from asset owners will be due by 31 May 2025.
All applications submitted for the 31 October 2024 application deadline must cover a 12-month period starting on or after 1 November 2022 and ending on or after 31 October 2023.
| Reporting Period | 31 October Application Deadline 2024 | 30 April Application Deadline 2025 (AMs and SPs only) |
31 May Application Deadline 2025 (AOs only) |
|---|---|---|---|
| 1 January 2023 - 31 December 2023 | Accepted | Not accepted | Not accepted |
| 1 April 2023 - 31 March 2024 | Accepted | Not accepted | Not accepted |
| 1 July 2023 - 30 June 2024 | Accepted | Accepted | Accepted |
| 1 October 2023 - 30 September 2024 | Accepted | Accepted | Accepted |
| 1 January 2024 - 31 Decemer 2024 | N/A | Accepted | Accepted |
| 1 April 2024 - 31 March 2025 | N/A | Accepted | Accepted |
Assessment
Reports submitted to the FRC are read in full and assessed against the Principles and reporting expectations of the Code in a way that is proportionate to the organisation’s size and type. This assessment is then reviewed and discussed among FRC staff to ensure it is fair and appropriate. A sample of reports reflecting a range of applicants are reviewed by the FRC’s panel of independent advisors to ensure consistency.
Both successful and unsuccessful applicants are provided a summary of where their reporting met our expectations and where improvement is required when re-applying to the Code.
Unsuccessful applicants may address the feedback and re-apply in a future reporting window with a valid reporting period (see table above).
Publication
Once the Report has been assessed by the FRC and the applicant has been accepted as a Code signatory, the Report will be a public document. The signatory must also make it available on their website within one month of being notified by the FRC.
On 22 July 2024, the FRC updated the UK Stewardship Code 2020 signatory list. Later applicants to the Code, if successful, will be added to the list. Signatories to the 2020 Code will have to annually update and submit their report to remain on the list.
Who should apply to become a signatory to the Code?
Asset owners such as pension schemes, insurers, foundations, endowments and sovereign wealth funds. Guidance from The Pensions Regulator encourages defined benefit and defined contribution pension schemes to become signatories to the Code. Guidance from the Department for Levelling Up, Housing and Communities) recommends that administering authorities in the Local Government Pension Scheme become signatories to the Code.
Asset managers (investment managers) that manage assets on behalf of UK clients or invest in UK assets. FCA-regulated asset management firms covered by the FCA Conduct of Business Sourcebook (COBS) Rule 2.2.3 are required to disclose the nature of their commitment to the Code or where they do not commit to the Code, their alternative investment strategy.
Service providers such as investment consultants, proxy advisors, pension lawyers and data and research providers that support asset owners and asset managers to exercise their stewardship responsibilities. Fiduciary managers will need to fulfil reporting expectations relevant to their role from both the Principles for asset owners and asset managers and Principles for service providers.
Which should apply if your UK business is a separate legal entity within a global organisation?
Organisations should in the first instance seek to apply the Principles across their business and report as a single global organisation. Where an organisation is unable to do so, the UK entity may report. A clear explanation for this and the scope of the information included in the Report should be provided.
Notifying the FRC that you will apply to become a signatory
The FRC encourages any organisations that intend to apply to become signatories to the Code to notify us of their intention to do so at [email protected]