Apple Shareholders Stunted: Proposals Plummet as SEC Shift Bites
15 January 2026
Just one shareholder proposal has made it to technology giant Apple’s 2026 proxy statement to be voted on at its 24 February AGM, with several resolutions pulled and none on AI for the first time since 2023.
Only a single shareholder proposal has made it to the company’s 2026 AGM marking a significant decline the number compared to previous years, down from four in 2025 and six in 2024. In November, the US Securities and Exchange Commission (SEC) controversially announced that it would not respond to company ‘no action’ requests to exclude shareholder proposals during the 2026 proxy season, as reported by Minerva Analytics. Apple only received assent from the Commission to reject one proposal, while several shareholder resolutions were marked as “withdrawn” within the “No Division Response Forthcoming” section of the SEC’s website, meaning they would not necessarily have been allowed to be excluded. This may signal the start of a trend of declining US shareholder resolutions numbers during the forthcoming proxy season.
Key Client Takeaways:
Shareholder Proposals Sharply Decline
- Apple’s 2026 AGM will feature only one shareholder proposal, a steep drop from previous years, showcasing a marked reduction in shareholder influence compared to 2024 and 2025 in the light of changes from the US SEC. In prior years, multiple proposals achieved more than 30% support, signalling meaningful investor concern.
SEC Shift Empowers Companies
- Changes in the SEC’s handling of ‘no action’ requests have enabled companies to exclude shareholder proposals without formal SEC approval, signalling a broader rollback in shareholder oversight rights which looks set to be prevalent during the 2026 proxy season.
Eschewing AI Accountability
- AI governance has been Apple’s most consistently supported shareholder issue in recent AGMs, yet no AI-related proposals will be voted on in 2026 amid ongoing investor litigation over Apple’s AI disclosures. With engagement channels narrowing, shareholders may be forced to turn to the courts to seek accountability from investee companies.
Shareholders have strongly backed proposals at recent Apple AGMs, with two receiving more than 30% of votes in favour at its 2024 AGM. The proposal which gleaned the greatest support requested the board prepare a report for shareholders on the use of AI, which secured more than 36% of votes in favour. Another AI-focused proposal – requesting the Board to report on ethical AI data acquisition and usage – was the most strongly supported at its 2025 AGM.
Apple has seen multiple shareholder proposals withdrawn following the company filing a ‘no action’ request with the SEC, but without receiving assent from the commission that the company would have been justified to exclude these resolutions. One of these proposals pulled was AI-focused, an issue which has been a focal point for Apple shareholders in recent years. The resolution from UK shareholder advocacy group Tulipshare requested that the company publish a report evaluating how emerging technologies such as AI and increased data centre usage may impact its long-term energy strategy.
In its ‘no action’ request letter, Apple cited micromanagement of the company as a reason for the proposal to be excluded. Fellow US technology company Cadence Design Systems has similarly argued that shareholder proposals have sought to micromanage the company and block them from their 2026 AGM, something strongly rebutted by proponent John Chevedden as reported by Minerva Analytics.
The only proposal from shareholders which will be voted on at Apple’s 2026 AGM on 24 February is from a noted anti-ESG proponent, the National Center for Public Policy Research (NCPPR). The resolution requests that Apple’s board evaluate and report on risks and costs associated with the Company’s China entanglements. The company has recommended that shareholders vote against the proposal.
Similarly to a case at Costco last month, which was reported by Minerva Analytics, Apple has opted to accept the proposal from the NCPPR despite previously submitting a ‘no action’ request with the SEC. Interestingly, the shareholder proposal which Costco chose to include at its 2026 AGM on 15 January was from the same proponent.
As a result of the SEC’s rule change, companies are now being able to block proposals without Commission staff review, something which looks likely to have played a factor in some of the resolutions intended for Apple’s AGM being withdrawn. Even before this, the SEC had adopted a stance which was hostile towards shareholders and favourable towards companies. This included the Commission rescinded Staff Legal Bulletin (SLB) 14L under Rule 14a-8, replacing it with new guidance in SLB 14M, as covered in Minerva Analytics’ Shareholder Proposal Voting Trends Report 2025. This reinstated prior staff guidance on micromanagement, permitting shareholder proposals to be excluded more easily by companies and setting the tone for the SEC’s rolling back of shareholders to hold investee firms to account.
Litigation may well end up being the only recourse for shareholders to hold their investee companies, which risks drawing them into costly court battles to challenge the exclusion of proposals. Apple shareholders have already legally challenged the company on AI, filing a lawsuit in June claiming that it had misled investors over its integration of AI into its digital assistant Siri to boost phone sales.
As reported by Minerva Analytics, this led to a sharp decline in the company’s stock price between June 2024 and June 2025, detrimentally impacting shareholders. Apple’s long-awaited AI-powered upgrade to Siri is reportedly expected to be made available in the coming months. It was announced this week that Apple has formed a multi-year partnership with Google to use some of the key technology from its Gemini AI models to power Siri among other future Apple Intelligence features.
A shareholder proposal from the conservative American Family Association (AFA) which requested the company to prepare a publicly available transparency report on the costs and benefits of the company’s decisions regarding its use of child sex abuse material identifying software was also withdrawn. Apple had filed a ‘no action’ request in October, citing micromanagement as among the reasons for the proposal to be excluded, before reaching an accord with the AFA on the controversial issue the following month.
AI and its use in relation to such material has been placed under scrutiny by the controversial case surrounding X owner and Tesla CEO Elon Musk’s AI tool Grok which has drawn criticism from both UK and US policymakers. Following increasing pressure from across the globe, X has this week announced that Grok not be able to edit photos of real people to show them in revealing clothing in jurisdictions where it is illegal.
This followed the UK communications industries regulator and competition authority Ofcom opening an investigation into X over the use of Grok to create sexualised images of women and children and the UK announcing that it will create a law to make it illegal to produce non-consensual intimate images using AI tools. While Ofcom welcomed X’s announcement, it stressed that its investigation will still run its course.
The National Legal and Policy Center also withdrew a shareholder proposal which requested a report on the financial impact of the company’s renewable energy implementation. In this case, rather than being impacted by the SEC’s change in ‘no action’ stance, the proponent said that it had “reached an agreement with the company to withdraw the proposal in exchange for improving some language in its disclosures”.
You can read more of our articles by clicking here.
Last Updated: 15 January 2026