On October 9, 2025, SEC Chairman Atkins delivered a speech in which he inveighed against "shareholder proposals focused on environmental and social issues." According to Chairman Atkins, "these proposals consume a significant amount of management's time and impose costs on the company" even though "they almost always receive even lower support than shareholder proposals do generally." Chairman Atkins therefore expressed the view that it would be beneficial to limit these ESG proposals, and he identified a legal mechanism for doing so--i.e., that "a company [is not] actually required to include these [ESG] shareholder proposals in its proxy materials," because "there is no fundamental right under Delaware law for a company's shareholders to vote on [ESG] proposals," and those ESG proposals can thus be excluded.