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When Glass Lewis announced an open comment period on the four perspectives that will underpin its research beginning in September 2027, it noted that it will continue to offer its Benchmark Voting Policy Guidelines for the 2027 Proxy Season, to be announced in October, with minimal expected changes (limited to significant regulatory and corporate governance developments). Those Benchmark Voting Policy Guidelines — which will apply to shareholder meetings held from January 1 through August 31, 2027 — were quietly released (I believe) late last week.

When you open the guidelines, you’ll immediately notice that they contain no “Summary of Changes.” That’s because there were no changes to the U.S. guidelines from 2026. The preface to the guidelines explains:

Glass Lewis’ single house policy has traditionally anchored the regional benchmark guidelines. Given Glass Lewis’ announced intention to move away from this single house policy, towards multiple perspectives representing varied viewpoints of its clients, policy development has entered a period of transition. As such, the Glass Lewis 2026 Benchmark Policy Guidelines will remain static for 2027.

Glass Lewis, however, remains committed to keeping policies current during this transition phase by ensuring that any relevant changes to regulation or corporate governance practices are reflected in the Benchmark Policy guidelines. A review of market-level regulatory and best practice changes over the preceding year concluded that these guidelines do not require revision for 2027

I went to the shareholder proposals section to remind myself how Glass Lewis approached the shifting shareholder-proposal environment last year. The document still provides that:

[T]he Benchmark Policy will generally approach these matters with the basic premise that shareholders should be afforded the opportunity to vote on matters of material importance. To be sure, the Benchmark Policy respects the limitations placed on shareholder proponents, as certain shareholder proposals can unduly burden companies or cross the line between the purview of shareholders and that of the board. It also recognizes that not all shareholder proposals serve the long-term interests of shareholders. Nonetheless, the Benchmark Policy views the basic right of shareholders to file proposals as critical to the proper functioning of our system of corporate governance and in the best economic interest of all shareholders.

A number of important corporate governance reforms, such as declassified boards and majority voting, would not have been achieved without shareholders’ willingness and ability to submit proposals, for which they bear the costs and only realize a portion of the benefits. Empirical evidence has shown that even withdrawn shareholder proposals, such as those on executive compensation, can encourage beneficial corporate practices, thereby benefiting all shareholders.

Like last year, it also notes that it will closely monitor regulatory changes and their ramifications and that the benchmark guidelines may be updated prior to or during the proxy season should regulatory changes warrant.

We’ll be posting related resources in our “Proxy Advisors” Practice Area. We’ve also already created the “2027 Resources” subsection of our “Proxy Season” Practice Area, which is always a treasure trove of helpful resources by the time proxy season is in full swing.

– Meredith Ervine