Over on RealTransparentDisclosure.com, Broc Romanek posted a link to this recent Labrador report reviewing public company ESG proxy disclosure practices in 2025 and offering some thoughts on how to approach those disclosures in 2026.  For 2025, the report says that companies took one of three alternative approaches to ESG proxy disclosure in light of the evolving environment:

– Stay the course and retain a description of their ESG programs. For the companies that retained their disclosure in 2025, many acknowledged a clear tie to their business and long-term value creation.

– Retain some disclosure but reduce the amount of content or modify the description to delete controversial words or programs.

– Delete any ESG disclosure from the proxy statement.

Here’s how Labrador suggests that companies approach these disclosures during the upcoming proxy season:

One thing is certain – the landscape will continue to evolve as the different political parties, special interest groups and other stakeholders work to advance their priorities and search for common ground. At least in the near-term, though, many large investors still prioritize climate risk, environmental stewardship and other issues that have direct financial implications for companies.

In response, we advise that companies still include an oversight section in proxy statements that describe how sustainability-related responsibilities are allocated among management personnel, the Board and its committees. In addition, best practice companies are tying Board oversight of sustainability to the company’s strategy and stakeholder feedback. Any disclosures beyond an oversight description are dependent on a company’s particular circumstances and investor base. In all cases, though, companies should provide enough information about issues that have a direct financial implication to allow stockholders to make an informed decision when voting on a company’s directors.

Companies should always be mindful of the consistency of sustainability-related disclosures between their proxy statement and sustainability reports. Attention should be given to a thoughtful review of a company’s disclosure documents to ensure a consistent and coherent message.

The report also includes numerous sample disclosures from 2025 proxy statements and summarizes the sections of BlackRock, Vanguard and State Street’s proxy voting guidelines relating to their expectations concerning sustainability disclosures.

– John Jenkins