ESG Proposals at Mid-Season 2025: Trends, Turbulence & Triumphs

As the 2025 proxy season passes its high point, several patterns have emerged in the engagement, filing, and voting outcomes of shareholder proposals. Despite continued anti-shareholder narratives  and heightened political and legal scrutiny of Environmental, Social, and Governance (“ESG”) issues, information to date indicates that market participants remain actively engaged on ESG[1] issues, with notable strategic shifts in tactics and tone.

Below is a collection of data compiled from industry publications, proxy advisors, and internal results from my and other shareholder organizations.

Quantitative Snapshot

Decreased E&S Filings: As of June 1, 2025, according to proxy advisor ISS, 324 environmental and social[2] shareholder proposals have been submitted across U.S. public companies, down from approximately 460 in 2024. Roughly 25% have gone to a vote. According to Proxy Preview, proposals have clustered around four core issue areas:

•        Climate Risk & Emissions Disclosure: 85 proposals

•        Diversity, Equity & Inclusion (DEI): 36 proposals

•        Environmental Management: 52 proposals

•        Corporate Political Spending / Lobbying Alignment: 77 proposals

Others address workers’ rights and human rights in supply chains, biodiversity loss, reproductive healthcare access, child safety, and AI governance, among others. A notable new proposal asks an insurance company to address risks related to the ongoing, climate-related insurance crisis. Proposals addressing deep sea mining were added last year.

Targeted Resilience: According to ISS, approximately 79% of companies that received E&S proposals this year have seen similar proposals over the preceding five years, demonstrating consistent investor focus on insufficiently addressed areas of risk.

No-Action Filings Surge: Significantly more issuers filed no-action challenges to shareholder proposals this season. For instance, shareholder representative As You Sow had nearly 30% of its proposals challenged this year, up from 17% in 2024. It is likely that the increase in no-action challenges is at least partially attributable to the change in administration, leading to a perception that new SEC leadership would heighten scrutiny of challenged proposals. In addition, the SEC’s mid-season issuance of Staff Legal Bulletin 14M (SLB 14M) expressly invited—and in fact led to—new challenges.

SLB 14M expanded the bases for excluding shareholder proposals, effectively returning to the more stringent limitations imposed by the first Trump administration, especially with regard to the micromanagement exclusion. SLB 14M was also noteworthy for giving issuers the opportunity to file no-action challenges substantially beyond established deadlines, allowing them to take advantage of the changed guidance. The SEC, however, did not give shareholders the same opportunity to amend their proposals, which were drafted and filed under the prior guidance.

Omissions Rate Decreased to Date: Given the surge in no-action challenges, surprisingly, companies’ rate of no-action wins this year has been approximately 61% across the majority of ESG proposals, less than 2024’s 66% win rate for companies, but still dramatically higher than in years 2022 and 2023. As You Sow won 7 of 15 SEC no-action decisions this year, also a higher rate than last year. Certain substantially similar proposals that were allowed in 2024, however, such as a request for Tesla to adopt a moratorium on deep sea mining, have been successfully blocked by the company this year, indicating a change in interpretation given the new guidance. Similarly, long-established proposals on lobbying disclosures were excluded without warning this year, as were a number of climate-related proposals that closely mirrored those that had survived past challenges.

Overall E&S Vote Support Declines: Ongoing litigation, investigations, and proposed anti-ESG laws and regulations appear to be a substantial factor in the reduced support of environmental and social proposals, as some institutional investors attempt to avoid negative attention from the administration, activist groups, red-state attorneys general, and state and federal legislators. The average vote in favor of ESG proposals is hovering around 17%, down from approximately 22% at the same point in 2024. Climate change votes in particular were lower this year, with one of the highest votes achieved at Pulte Group (24%) in a proposal asking the company to adopt Paris-aligned greenhouse gas goals.

Another factor affecting climate votes is the maturation of the issue, which requires proponents to be more specific in the action sought in proposals—such as seeking full rather than partial Scope 3 disclosures—a need that is in conflict with some voters’ preferences for more generality. Inexplicably, a debate is also occurring over whether to strengthen or abandon climate action and/or goals as warming reaches 1.5 degrees C. The insurance crisis, which threatens to grow into a nationwide mortgage crisis as insurance becomes increasingly unavailable or unaffordable, should underscore the need to double down on climate action to avoid far worse global economic impacts.

Engagement Yields Silent Wins: While average votes for E&S proposals are down, this dip masks a more complex and ultimately encouraging picture: Shareholders remain deeply engaged in addressing ESG issues that create risk and missed opportunities for issuers and investors. Direct engagement with issuers around ESG concerns remains active, even if not trumpeted due to fear of political backlash. As an example, a recent study by Robeco of 300 institutional and wholesale investors noted that, while the policy changes since the Trump election have impacted investment and voting decisions, the importance of climate issues to investors has not declined and nearly two-thirds expect climate change to become central or significant to their investment policies in the next two years. Significantly, the study found that the new administration’s anti-climate policies are driving investors to look for climate-related investment opportunities outside the U.S.

DEI Emerging Triumphant: In a striking rejection to anti-DEI campaigns, investors have overwhelmingly rejected efforts to curb corporate inclusion initiatives. A recent Fortune analysis confirms this pattern, noting that investors are consistently delivering near‑unanimous “no” votes on anti-DEI resolutions. To date, 15 anti‑DEI proposals submitted this season at iconic companies — including Apple, Goldman Sachs, Costco, Levi Strauss, Deere, Berkshire Hathaway, and Disney — have been resoundingly defeated, receiving just 0.5% to 2% support from shareholders. These outcomes underscore an overwhelming consensus among shareholders that diversity and inclusion is a core component of corporate governance and issuer returns. Despite efforts to reframe DEI programs as a political liability, these votes indicate that shareholders understand these programs help attract talent, drive innovation, expand market reach, and lead to financial outperformance.

Overall Anti-ESG Votes Remain Low: Average support for anti-ESG filers was at a low of 1.2% based on votes to date, a number buoyed by higher votes achieved in proposals seeking oversight of use of Artificial Intelligence (AI) at Amazon, Apple, and Microsoft.

Majority Votes on Governance Issues: Governance issues continue to earn relatively high support this year, with majority votes still occurring on political spending resolutions including proposals at CBOE Global Markets, Meritage Homes, Teradyne Inc., Spirit Aero Systems Holdings, and Crown Holdings.

Other Significant Votes: Despite low votes in issue areas coming under direct political attack, a variety of social and even environmental proposals earned greater than 20% support this year. For instance, nearly 29% of shareholders supported a request for a non-interference policy at SkyWest to uphold employee rights to freedom of association and collective bargaining; a civil rights audit proposal at Deere earned 29% support; an EEO-1 report at Planet Fitness earned a 37% vote; a racial equity audit at Bank of Nova Scotia bank received a 38% vote; and a plastics proposal at General Mills earned a 40% vote.

Large Asset Manager Behavior Diverges: Some large asset managers, particularly the ‘Big Three,’ have at times clashed with conservative politicians over anti-ESG attacks, but have also shown dramatically reduced support for ESG proposals, recently voting with management most of the time. On the other hand, many pension funds and other asset owners, while moving away from ESG as an umbrella concept, have demonstrated higher support for issuer action on critical ESG issues, including climate change, and many continue critical engagements with high carbon companies, as demonstrated by CA100+ engagements.

Language Shift from Companies, But Goals Hold: Similarly, while issuers may change how they are presenting ESG issues publicly due to intense political pressure, their underlying actions on critical issues like emissions, supply chain, and equity continue.

For instance, according to a new study from PwC, the vast majority of public companies (84%) are either retaining or ramping up their climate commitments, despite headlines to the contrary and a few high-profile walk-backs. PwC found that companies were more than twice as likely to be accelerating their emission-reduction goals than decelerating them. While many large companies are adjusting climate goals to reflect actual progress,[3] a not unexpected development, the PwC study found that the practice of setting climate goals is progressing down the value chain as companies increase engagement efforts, with smaller companies representing a growing proportion of those introducing new targets. This makes sense when considering the growing economic destabilization associated with climate impacts, the global competitiveness around low carbon products and services, and the opportunity to add value through targeted and efficient climate efforts.

Similarly, while many companies are exploring new language and frameworks to communicate their diversity and inclusion practices, as they navigate the evolving landscape around DEI disclosures and potential federal enforcement of Executive Orders targeting DEI, the majority of companies that we engage with are not changing their commitment to fostering inclusive workplaces. Companies that prioritize inclusivity benefit from higher employee engagement, improved innovation, stronger brand reputation, and improved financial metrics.

What’s Ahead for 2025

While we anticipate these themes to be in the foreground over the next four years, we also expect that the growing threats to shareholder rights and independent investor decision making will begin to be resolved in the courts and in the financial arena, as capital seeks rationality, stability, and markets where independent investment decisions can be made.

Environmental, social, and governance priorities remain firmly rooted in the corporate and investment mainstream because issues like climate risk, resource availability, diversity, and supply chain sustainability are core to protecting shareholder value.

With several high-profile proposals still pending, and court decisions on executive orders and ESG-related rulemaking expected later this year, the second half of the proxy season may begin to reveal new insights. However, as of now, the 2025 season illustrates that the anti-ESG backlash has made an impact, but one that is overstated: investors’ need for disclosure and action on ESG issues is maturing rather than collapsing due to a growing understanding of the materiality of environmental and social risks. While the conversation is evolving, the demand for long-term, sustainable value creation remains firmly rooted in U.S. capital markets.