A letter sent to Disney shareholders, and an SEC filing a few days ago, revealed that Disney Parks had agreed to a shareholder’s proposal to review the Disability Access System (DAS) changes after a previous denial. This would now allow a vote by the shareholders on the proposal. However, in a proxy letter released today, Disney is now recommending that shareholders vote against the proposal to review DAS.
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.
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 Withdraws Its Exclusion Request
According to the SEC filing submitted several days ago by Disney’s counsel, Wilmer Cutler Pickering Hale and Dorr LLP, The Walt Disney Company withdrew its request to exclude the shareholder proposal on disability accommodations from its 2026 proxy statement.
This would allow the proposal to be put to a vote by shareholders.
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”.
Today’s Letter to Shareholders
The proxy recommendation is as follows:
Board Recommendation
The Board recommends that you 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.
“The Board recommends that you vote “AGAINST” this proposal, and if the proposal is presented, your proxy will be voted against this proposal unless you specify otherwise.”
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