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The Order takes aim at the proxy advisory industry, particularly with regard to DEI and ESG.

By Betty M. Huber, Benjamin Rosemergy, Larry Seymour, Bradd L. Williamson, Aryeh Zuber, and Ariel Woldar

Key Points:

  • The Order directs the SEC, FTC, and DOL to increase oversight of proxy advisors and assess their practices under applicable laws.
  • ISS and Glass Lewis have already begun to modify their practices in light of mounting regulatory pressure.
  • The Order could fundamentally reshape the proxy advisory landscape.

On December 11, 2025, President Trump signed an executive order titled “Protecting American Investors from Foreign-Owned and Politically-Motivated Proxy Advisors” (the Order), which explicitly names both Institutional Shareholder Services and Glass Lewis. The Order expresses particular concern that proxy advisors are using their influence over shareholder proposals, board composition, and executive compensation to prioritize “radical politically-motivated agendas,” including diversity, equity, and inclusion and environmental, social, and governance matters. 

For more details see our Client Alert.