Overview
- Disney notified the SEC on January 19 that it withdrew its no-action request and will include the disability access proposal in its 2026 proxy materials.
- The resolution, filed by shareholder Erik G. Paul, asks Disney to retain a qualified third party to assess legal, financial, and reputational risks and to provide a public summary and a board briefing.
- Disney had argued to the SEC that the proposal was materially false and misleading, concerned ordinary business, and was already substantially implemented before reversing course.
- The move follows a November 17 SEC policy shift that curtailed staff review of most company attempts to exclude shareholder proposals.
- Inclusion of the proposal triggers a vote but does not change current DAS operations, which were tightened in 2024–2025 through new eligibility processes, reduced party sizes, and an Inspire Health Alliance partnership, as litigation and media scrutiny continue.