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ARTICLE · 29 OCTOBER 2026

SEC Staff Grants Broad Relief For Board-Aligned Retail Shareholder Voting Programs

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The SEC's Division of Corporation Finance has issued a no-action letter allowing Tesla and other companies to implement voluntary retail voting programs that enable individual shareholders to establish revocable standing instructions aligned with board recommendations.

United StatesCorporate/Commercial Law
Gunderson Dettmer LLP
Gunderson Dettmer LLP

“By giving retail investors access to a no-fee, client-directed process similar to those currently available to institutional investors, [issuer voluntary retail voting programs] will remove time and other burdens borne by retail investors in the voting process, enabling greater participation in shareholder democracy by ultimate asset owners.”

—Tesla Framework Letter, September 29, 2026


On September 29, 2026, the Office of Mergers and Acquisitions in the SEC’s Division of Corporation Finance (Division), in response to a request from Tesla, issued a no-action letter stating that it would not recommend enforcement action to the Commission if Tesla implements a voluntary retail voting program enabling individual shareholders to authorize revocable standing instructions to vote their shares in line with the recommendations of the company’s board of directors, as described in Tesla’s request. In Tesla’s words, such a standing instruction “does not ‘lock in’ the proxy or

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