Disney Announces It Will Include Shareholder Proposal To Examine DAS Pass In 2026 Voting

After Disney did everything it could to dismiss a shareholder proposal examining and reviewing DAS access criteria, it has now reversed course and is going to put it on the Proxy vote for 2026.

Did the bad PR get to them, because that is their Kryptonite?

What happened?

Previously, we reported that Disney shareholder Erik G. Paul put forth a resolution to the Walt Disney Company asking for an independent review of the DAS (Disability Access Pass). The DAS pass has come under fire in recent years as changes have excluded many who used to receive it.

Paul filed the following, 

“Shareholders request that Disney commission an independent review, conducted by a qualified third party, of the company’s accessibility and disability inclusion practices. This review should assess legal, financial, and reputational risks; evaluate Disney’s policies against international accessibility standards and competitors; and identify opportunities for leadership improvement. Shareholders further request that the Board provide a public summary and internal briefing on the findings to ensure accountability and transparency.”

The Walt Disney Company has come under fire for its revised DAS Pass criteria and interview procedures. Many who arguably need the program are denied and told to trade off or buy Lighting Lane passes. One of the reasons many believe the policies were changed was to reduce DAS passes and promote paid services as a replacement.

Disney immediately sent a request to the SEC asking for his proposal to be excluded, arguing that part of his proposal was “false or misleading” in regard to possible PR and financial impacts, Paul claimed.

Then it turned out that the SEC no longer required companies to request permission to exclude shareholder proposals, and it looked like Disney was going to dismiss it. However, the media got hold of it, and like the time they tried to get the Disney Springs wrongful death trial dismissed, public opinion did not side with the company.

Now they are including it in their Proxy for the annual 2026 meeting.

Here is the letter they sent to investors,

“January 19, 2026

Via Online Shareholder Proposal Form

U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Chief Counsel
100 F Street, NE
Washington, DC 20549

Re: The Walt Disney Company
Withdrawal of No-Action Request Dated November 4, 2025, Relating to a Shareholder Proposal Submitted by Erik G. Paul

Ladies and Gentlemen:

We are writing on behalf of our client, The Walt Disney Company (the “Company”), with regard to our letter dated November 4, 2025 (the “No-Action Request”), concerning the shareholder proposal and supporting statement (collectively, the “Proposal”) submitted by Erik G. Paul. In the No-Action Request, the Company sought concurrence from the staff of the Division of Corporation Finance of the U.S. Securities and Exchange Commission (the “Staff”) that the Company may exclude the Proposal from its proxy statement and proxy in connection with the Company’s 2026 annual meeting of shareholders (the “Proxy Materials”). The Company has determined to include the Proposal in its Proxy Materials and therefore withdraws the No-Action Request.

If the Staff has any questions with respect to the foregoing, please do not hesitate to contact me at lillian.brown@wilmerhale.com or (202) 663-6743.

Best regards,

Lillian Brown

cc:
Jolene Negre, Deputy General Counsel – Securities Regulation, Governance & Secretary
The Walt Disney Company”

I’m sure they will likely say that “The Walt Disney Board recommends you vote ‘NO’ to this proposal at the meeting.

Either way, the proposal is being presented. Most proposals from shareholders are voted down, while Disney’s proposals almost always pass, so I don’t expect a positive outcome. However, here’s hoping one happens.

What do you think? Comment and let us know!