The shareholder proposal made on behalf of DAS Defenders calling on Disney to conduct an independent and public review of its controversial Disability Access Service policy changes has been rejected. Here’s the latest on the public audit proposal, what this rejection means and doesn’t, and why it happened.
This has been quite the saga. To bring you up to speed, Disney overhauled DAS at Walt Disney World and Disneyland back in May 2024. According to the company, the changes were due in large part to abuse, misuse, and proliferation of the program’s use–with issuances of DAS tripling from 2019 to last year. For more about the specifics of the overhauled DAS, see Disability Access Service (DAS) Changes at Walt Disney World FAQ.
Even over 18 months later, the DAS overhaul remains controversial. It’s also a sensitive subject that is personal since it’s make or break for some guests trying to experience Walt Disney World and Disneyland. There have been reports of guests who previously had DAS being denied and advised to use alternative accommodations instead. here have also been a number of small tweaks to DAS over the last year, some of which could be attributed to a pending class action lawsuit.
In addition to that pending class action lawsuit, there was also a shareholder proposal seeking an independent review of the DAS overhaul. The Walt Disney Company first intended to exclude the aforementioned shareholder proposal from the proxy materials for its 2026 annual meeting of shareholders.
This meant that shareholders would not vote on whether to approve the resolution for the independent review. This shareholder proposal first came to light late last year because Disney sought assurance of no enforcement action from the Securities and Exchange Commission (SEC) following the exclusion.
Fast-forward to early 2026, and Disney sent a follow-up letter to the SEC withdrawing its previous no-action request. The company no longer sought such an assurance because they’ve instead opted to include the aforementioned shareholder proposal in their proxy materials for the 2026 annual meeting.
The “why” of that is wonkish, but boils down to the SEC issuing this statement last November, indicating it wouldn’t respond to no-action requests for, and express no views on, companies’ intended reliance on any basis for exclusion of shareholder proposals.
That statement was made 10 days after Disney submitted its no-action letter, so Disney wouldn’t have known of that position when making the request. Without that certainty, many other companies have withdrawn their no-action requests, presumably due to the legal risk.
Only a couple of days after withdrawing its no-action request, Disney filed its proxy statement with the SEC ahead of the Annual Meeting of Shareholders on March 18, 2026. In this, the company elaborates on its stance to the Disability Access Service shareholder proposal seeking independent review of the controversial changes.
Unsurprisingly, Disney’s Board recommended that shareholders vote against outside DAS risk analysis, which is exactly as expected. The Board concluded that the proposal’s request is not in the best interests of the Company and its shareholders as it would not provide meaningful additional information to shareholders to merit the resources it would require. (See below for additional details.)
During the Annual Meeting of Shareholders, there were four shareholder proposals that were presented and voted on. The shareholder proposal at issue here was #7: “Independent Review and Report on Accessibility and Disability Inclusion Practices.”
DAS Review Rejected by Shareholder Vote
During the annual meeting of shareholders of the Walt Disney Company on March 18, 2026, Erik Paul presented his proposal, stating that Walt Disney’s promise of inclusivity should continue to be the guiding light for the company.
He pointed out that disabled guests are a growing demographic, and that accessibility is not charity or politics, but rather responsible and sound risk management. According to Paul, 85% of disabled guests surveyed are unlikely to return to the Disney Parks. Paul argued that an independent review would be good business.
The Walt Disney Company board reiterated its position in response, recommending a vote against the proposal. In support thereof, they referred to their statement in the proxy materials.
Proposal #7, concerning an independent review of DAS, failed with only 5% of shareholders supporting.
It’s not the least bit surprising that the DAS proposal failed, or spectacularly so.
One of the reader misconceptions in response to our previous coverage was that this proposal was being driven by investors concerned about the impact of the DAS changes on the company’s financials.
As we explained previously, this DAS review proposal was better viewed as a small subset of shareholders framing an issue that’s personally important to them in such a way to make it appropriate for proxy vote. It was an inventive angle for contesting the DAS changes, as opposed to a legitimate concern among large investors.
Anyone who has listened to the annual meetings knows that there are a lot of politically-charged and niche causes presented. All of them are summarily shot down without much in the way of further discussion.
As a Disney shareholder, I could write a proposal about how the company’s refusal to reimagine Journey into Imagination has resulted in financial strain, underperformance, unrealized earnings, social media backlash, and brand damage. I could cite things like popcorn bucket, merchandise sales, and DTB blog posts in support of my position.
Doing this as opposed to someone asking (yet again) during the Q&A would be a more ‘legitimate’ way of raising the issue, but it would be an equally futile effort. Even though I’m right and a Figment announcement would send $DIS rocketing to new heights, those stodgy institutional investors lack my vision and would vote it down.
Now reverse the roles and consider what would’ve happened had a shareholder asked about DAS during the Q&A as opposed to going through the formal process for this proposal. Josh D’Amaro might’ve given a diplomatic answer that offered false hope, but that’s about it. The outcome would’ve been the same as this, and all those Figment questions over the years. (Hey, a least we got the ‘How NOT to Draw’ short with NPH out of it!)
While we strongly believe Disney should do a better job at finding a middle ground and have a more delicate touch in handling DAS, it’s easy to see why this is not something with which shareholders will concern themselves.
When ‘reacting’ to this news, one important thing to keep in mind here is that individual shareholders are not outcome-determine on things like this. Anyone disappointed by this outcome shouldn’t be upset at fellow fans. Those who are aware of the DAS controversy and sympathetic to the plight of disabled guests did cast the deciding votes.
It’s the large institutional ones who were make or break. And although Disney’s stock has underperformed for the last several years, that’s definitely not attributable to the theme parks. If anything, the parks are what is carrying the company and preventing that share price from dipping well below $100.
As we’ve covered in earnings call reports and crowds coverage, attendance was down year-over-year (by about 1%), but that was largely attributable to hurricanes ($120 million disclosed losses). Meanwhile, the parks continue to set revenue records and hotel occupancy continues to rise. Right or wrong, that’s what matters to large shareholder.
Simply put, institutional investors like BlackRock, Vanguard, and Fidelity did not concern themselves with this. Their team has not been sifting through the comments on DTB trying to assess whether DAS is good or bad for business.
They almost assuredly deemed it too trivial, and deferred to Disney’s assessment that park operations are ordinary business and not subject to shareholder micromanagement; that they’ve already done their due diligence on the DAS changes,
Honestly, all BlackRock, Vanguard, etc. probably needed to see is this: “The proposal’s request would not enhance shareholder value.” That was the whole ballgame, and what likely led to their casting of the deciding (millions of) votes.
In case you want to know even more, here’s the full background on the shareholder proposal, including the original resolution, Disney’s response, and more…
Shareholder Statement & Resolution
Disney’s brand and financial stability are under strain from underperforming films, rising park costs, consumer boycotts, and waning trust. According to the resolution, a significant contributor to this strain is the company’s recent overhaul of disability accommodations at its parks due to negative media coverage, social media, guests canceling trips and Annual Passes, as well as legal exposure to a class action lawsuit.
As a result of the controversial DAS changes, Disney exposed itself to legal claims, regulatory scrutiny, and brand damage. Other companies have faced multimillion-dollar settlements under accessibility-related actions. Future liabilities could include costly settlements, operational disruption, and weakened market positioning.
Resolved: 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’s Proxy Statement Response
The Walt Disney Company prefaced the shareholder proposal with the following:
Given recent regulatory changes, we are including this proposal in the proxy statement, notwithstanding that we believe that it does not meet the requirements of Rule 14a-8, including on grounds that the proposal, read together with its supporting statement, is materially false and misleading in multiple respects (including statements regarding the Company and statements regarding purported research the proponent cites), relates to the Company’s ordinary business operations and has already been substantially implemented by the Company. These bases for exclusion are detailed in the Company’s no-action request submitted to the SEC on November 4, 2025.
Disney’s argument for exclusion in that November 4th no-action request was that any attendance decrease in the last fiscal year was attributable to hurricanes. Moreover, park operations are ordinary business and not subject to shareholder micromanagement; that they’ve already done their due diligence on the DAS changes, and there’s no duty to disclose any nonpublic information.
There’s still more to it than that, but Disney indicated in the proxy statement that the company has limited its response to the most important points and have not attempted to address all the statements with which they disagree. You can read Disney’s full argument here.
The Walt Disney Company Board Recommendation
The Walt Disney Company Board recommended that shareholders vote against this proposal for the following key reasons, as discussed in more detail below:
- The Company is committed to the design and implementation of innovative and effective services that accommodate persons with disabilities and already reviews its practices on an ongoing basis. The Company has been the industry leader in accessibility for over 30 years.
- The Company provides detailed public information, tips and recommendations regarding its accessibility and disability inclusion practices, both online and in person in its theme parks.
- The Company provides strong governance and oversight of its inclusion practices, as well as risk management.
- The proposal’s request would not enhance shareholder value.
Across the Company, we endeavor to provide opportunities to enjoy our products and services. To that end, the Company has made thoughtful investments to incorporate accessibility for people with disabilities throughout our operations as we strive to design, promote and serve as a model for accessibility.
The Company has given the same attention to detail in its development of the Disability Access Service program for its domestic parks, which provides an extraordinary benefit – never having to wait in the regular standby lines for most rides for those who require that option.
The Company also offers a broad range of different accommodations to assist in accessing the rides and other attractions in the parks, accessing our content and programming and experiencing our other products and services. For example, the Company offers a range of tools and accessibility features across our streaming platforms and networks, including tools such as audio descriptions, closed captioning, keyboard navigation and interoperability with popular screen readers.
The Company provides detailed information regarding accessibility and disability inclusion practices on its websites, including the publication of an Accessibility Topic Brief. Each of our theme parks also publicly provides thorough information about its accommodations and assists guests both before and during their visits. For our domestic theme parks, Disneyland Resort and Walt Disney World Resort, this includes pages on the Disability Access Service program with guidance on registration and the process for using the program once in one of the parks.
The Company has strong governance and oversight of both its accessibility efforts and risk management. Our Senior Executive Vice President and Chief People Officer leads Disney’s global people and culture strategy; talent acquisition and development; compensation and benefits; opportunity and inclusion; organizational effectiveness; and employee services and systems. Reporting to our Chief People Officer, our Senior Vice President and Chief Opportunity & Inclusion Officer leads the Company’s Opportunity & Inclusion strategy and partners closely with leaders and teams across all segments to foster a culture rooted in belonging. The Chief Safety Officer leads the Company’s guest safety efforts for Disney Experiences, including those related to guest accessibility, in collaboration with businesses and leaders across the Company. The Board and its committees oversee the Company’s major financial, legal and reputational risks, supporting strong brand stewardship and mitigation of such risks. See section entitled “The Board’s Role in Risk Oversight” in this proxy statement for more details.
The Company already details the support and accommodations it offers to guests and consumers with accessibility needs, as well as risk oversight practices and governance. The Board therefore believes that the proposal’s request is not in the best interests of the Company and its shareholders as it would not provide meaningful additional information to shareholders to merit the resources it would require.
For the reasons set forth above, our Board unanimously recommends voting AGAINST this proposal.
Anyway, just wanted to bring this to your attention since this Disability Access Service shareholder proposal has been an ongoing story, and this brings it to a resolution. To end on a potentially positive note for this who support further DAS review, just getting this on the ballot and in front of investors should be deemed a small victory.
This keeps the conversation about the controversial DAS changes going, and that help might put pressure on Disney for further reform, an informal rule relaxation, or just making the process less dehumanizing.
We’ll conclude by once again reiterating our position that Disney should work towards improving DAS. Just because we believe this shareholder proposal is almost certain to fail doesn’t mean we don’t think Disney should take a second-look at its DAS policies.
The company has an exemplary reputation for guest service. The need for DAS reform was absolutely understandable, as there was rampant abuse exacerbated by social media, entitlement, and Disney creating an incentive for DAS scammers by monetizing line-skipping via Lightning Lanes.
There have been heartbreaking stories of DAS denials, and these have made clear that a more flexible and humane approach offering greater discretion to Cast Members is optimal. It seems that Disney went too far with the DAS overhaul; the pendulum swung from one extreme to another. Here’s hoping a middle ground solution can still be found. We’ll keep you posted.
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YOUR THOUGHTS
Surprised that only 5% of shareholders voted to approve the proposal for an independent review of DAS changes at Walt Disney World and Disneyland? Or did you expect this to be overwhelmingly rejected? Agree or disagree with our assessment of the changes or policy as a whole? Please try to stay on topic–we’ve noticed some of these DAS comments sections get heated and personal. Discuss the policy itself, not others’ use (or lack thereof) of it.