A letter sent to Disney shareholders and an SEC filing reveal that Disney Parks has agreed to a shareholder’s proposal to review the Disability Access System (DAS) changes after a previous denial.

In December 2025, a disabled shareholder asked Disney to hire an independent expert to review the risks associated with the DAS changes:

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.

DAS Shareholder Resolution

However, Disney asked the SEC (Securities and Exchange Commission) to allow them to exclude the resolution because it is “materially false and misleading”, “relates to the Company’s ordinary business operations,” and “the Company has substantially implemented the Proposal.”

Disney’s letter to the SEC was filed on November 4. On November 17, the SEC’s Division of Corporation Finance announced it would no longer review company attempts to exclude shareholder proposals except in some state-law circumstances. The change took effect immediately, meaning Disney no longer needed the SEC’s approval to exclude the resolution.

Disney to Include Disability Access Proposal in 2026 Proxy

The following letter was sent to Disney shareholders on January 19, 2026, sharing that Disney Parks have withdrawn the no-action request and are agreeing to the original shareholder proposal:

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 [email protected] or (202) 663-6743.

Best regards,

Lillian Brown

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

SEC Filing Withdrawing Disney’s Exclusion Request

According to the SEC filing submitted today by Disney’s counsel, Wilmer Cutler Pickering Hale and Dorr LLP, The Walt Disney Company has withdrawn its request to exclude the shareholder proposal on disability accommodations from its 2026 proxy statement.

The Proposal

The proposal, submitted by shareholder Erik G. Paul, calls for an independent review of Disney’s controversial 2024-2025 changes to its Disability Access Service (DAS) and oversight of risks to shareholder value, believing it a “growing crisis for shareholders.”

“Disney’s narrowing of DAS eligibility has created escalating operational, legal, and reputational challenges:

Pending litigation: A class-action lawsuit alleges discriminatory exclusion under the Americans with Disabilities Act.

Sustained negative coverage: National outlets, including USA Today, Associated Press, Los Angeles Times, Forbes, NBC News, and Business Insider, have reported on guest complaints.

Safety concerns:  Recent incidents, including a violent altercation at Disneyland that resulted in a guest requiring stitches, have highlighted tensions linked to alternative queueing arrangements in which disabled guests denied DAS accommodations are instructed to have companions hold a spot in line, a practice that can be misinterpreted as line-cutting.

Market exposure: Disabled travelers and families represent a significant portion of the 70+ million disabled adults in the U.S., a demographic controlling substantial discretionary travel spending”.

What the Proposal Requests

The shareholder proposal does not mandate specific operational changes or reinstatement of prior policies. Instead, it asks Disney to retain an independent expert to review the impacts of DAS changes, ensure board-level oversight of disability access risks, and provide transparency to shareholders on findings.

Why This Matters to Investors

Advocates supporting the proposal argue that Disney’s current approach to disability accommodations creates preventable risks that may devalue shares through legal exposure, reputation damage, and alienation of a substantial consumer demographic.

The withdrawal of Disney’s SEC exclusion request means shareholders will now have the opportunity to vote on whether the company should address these concerns systematically.

The proposal will appear in Disney’s 2026 proxy materials for shareholder consideration at the annual meeting.

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