The ability to file a shareholder proposal, which are resolutions submitted by investors for a vote at a company’s annual general meeting, is a fundamental shareholder right, ensuring investors have a say in the companies they own. In November 2025, the Securities and Exchange Commission announced it would pause the review of no-action requests, which are submitted by companies seeking to exclude a shareholder proposal from a vote at the AGM.

While there may be valid legal reasons why a company can exclude a shareholder proposal from a vote, the SEC has historically played an important role as a neutral referee in making judgements on no-action requests. The SEC decides whether a shareholder proposal can be excluded, and both companies and proponents of those proposals have respected the SEC’s determinations. Often, before the SEC gets involved, companies and proponents can reach a resolution. Examples of such resolutions include the company agreeing to put a proposal on the ballot, or the proponent withdrawing the proposal after the company takes action to address the issues raised.

The SEC’s announcement represents a concerning shift in the no-action request process. The change paves the way for companies to exclude shareholder proposals more easily and leaves proponents with little recourse. In early 2026, several proponents already have sued major companies, including AT&T, PepsiCo, Chubb and UnitedHealth Group, over attempts to exclude proposals from their respective ballots. Litigation, which is normally reserved as a last resort, is becoming the only option for investors. While large institutional investors may have the resources to file lawsuits, many smaller investors and individuals do not.

CalSTRS is closely monitoring how the shift in SEC policy will play out this proxy season. CalSTRS is watching for potential abuse of the new policy, assessing each shareholder proposal exclusion, engaging with companies and potentially adjusting proxy voting decisions. Shareholder rights are fundamental to well-functioning financial markets, and CalSTRS will continue to engage with companies and policymakers to ensure they are protected.

Southern Company and the status of nuclear power

Bloomberg New Energy Finance forecasts U.S. data center power demand to reach more than 100 gigawatts by 2035, highlighting the challenges and opportunities of producing sufficient electricity to fuel this rapid growth. One of the solutions being explored by the utility and technology sectors is the expansion of nuclear energy.

CalSTRS staff recently attended a meeting with Southern Company—one of the largest energy companies in the United States—to continue a dialogue that has been taking place over the past six years. CalSTRS leads engagement with Southern Company through Climate Action 100+, a global investor initiative to address climate-related financial risk at the world's largest greenhouse gas emitters. The meeting focused on the implications of expanded development of nuclear power, including both large conventional nuclear power plants and small modular reactors. SMRs are smaller nuclear reactors that can be deployed more quickly and at a lower cost than traditional plants.

Southern Nuclear, a subsidiary of Southern Company, operates three major nuclear power plants in the Southeast, comprising six active reactors in Georgia and Alabama. These include Plant Vogtle and Plant Hatch in Georgia and Plant Farley in Alabama.

Plant Vogtle Units 3 and 4 are the first newly constructed nuclear units to enter commercial operation in the U.S. in more than 30 years. With the completion of these units in 2023 and 2024, Vogtle is the largest nuclear power plant and generator of clean energy in the country.

Small modular reactors are advanced nuclear reactors with 300 megawatts of electrical output—approximately one-third the amount of a conventional nuclear reactor. They are categorized by their cooling technology and fuel type, such as light-water reactors, molten-salt reactors, high-temperature gas-cooled reactors and liquid-metal fast reactors. These designs are assembled in a factory, shipped to the site and incorporate improved safety features.

While SMR technology is being used internationally, commercial SMR technology in the United States is still in the development stage. One project, the Natrium reactor, developed by TerraPower in partnership with GE Hitachi Nuclear Energy, received a construction permit from the U.S. Nuclear Regulatory Commission in March 2026. The first natrium plant in Kemmerer, Wyoming, represents a major shift in nuclear design by combining a sodium-cooled fast reactor with a molten-salt energy storage system. This is the first commercial construction permit for a reactor using a design other than the conventional light-water technology in the U.S. in more than 40 years.

One of the barriers to providing clean, reliable and affordable nuclear power to businesses and communities across country is establishing a reliable supply chain that can produce consistent, positive financial results. To be successful, this effort will require significant regulatory support and capital investment over the next decade. Engaging a large utility like Southern Company is key to identifying risks and opportunities for CalSTRS future investments in this sector.