Disney has reversed course on a previously denied shareholder proposal seeking a review of the Disability Access System (DAS) changes. The DAS disability pass eligibility changes, first introduced in 2024, have drawn criticism and have continued to generate national attention.
As a result, advocacy groups have emerged to push back on the restrictions, most notably DAS Defenders, which supported efforts such as the recent shareholder proposal. Below, we break down Disney’s latest decision and what this review could mean for the future of DAS at Disneyland and Walt Disney World. Mickey Visit brings you the latest Disney news, including a look at recent policy changes and construction impacts at Disneyland.
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Shareholder Proposal Urges Disney to Reconsider DAS Changes
DAS was significantly restructured in 2024 in an effort to curb overuse, misuse, and other issues that were beginning to weaken the program’s effectiveness. Since that overhaul, Disney has continued to make adjustments, including changes to the online registration process.
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One of the most closely scrutinized changes in early 2025 was the removal of the word “only” from language stating that DAS is available to guests with “developmental disabilities or similar.” As we noted in our initial coverage, this wording change did not expand eligibility for the program, despite early speculation from some guests that it might.
A shareholder proposal recently introduced by advocates urged The Walt Disney Company to “assess the legal, financial, and reputational risks associated with its controversial Disability Access Service (DAS) overhaul.” Part of the language in this shareholder proposal attributed the recent dip in Disney Parks attendance, previously noted by executives on a February 2025 quarterly shareholder call, to the more restrictive DAS eligibility criteria.
A shareholder proposal is a formal request submitted by an investor of a publicly traded company urging the company to take a specific action. These proposals are generally included in the company’s proxy materials and presented for consideration at a shareholder meeting. Disney’s original response “intended to exclude this proposal from its proxy materials for the 2026 annual meeting of shareholders.” But now, a recent SEC (Securities and Exchange Commission) filing submitted by Disney’s legal counsel reveals that the company has withdrawn its request to exclude the proposal.
Disney is about to vote on this newest proposal at the next shareholder meeting.
Disney Reverses Course on Denying Shareholder Proposal
The shareholder proposal does not require specific operational changes but instead asks Disney to commission an independent review of the DAS changes, provide board-level oversight, and share the findings with shareholders.
In its original response, the legal counsel for The Walt Disney Company submitted a letter, initially published on the SEC’s website, requesting permission to exclude the resolution because it was “materially false and misleading,” related to the company’s ordinary business operations, and had already been substantially implemented. After that filing, however, an administrative change within the SEC’s Division of Corporation Finance eliminated the requirement for companies in similar situations to obtain SEC approval before excluding shareholder proposals.
So it is quite a surprise to learn that The Walt Disney Company has withdrawn its request to exclude the shareholder proposal from its 2026 proxy statement. In a letter to shareholders, copied below, The Walt Disney Company confirmed that it has withdrawn its request to the SEC to exclude the shareholder proposal and that the proposal will appear in the company’s 2026 proxy statement for consideration at the annual shareholder meeting.
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 lillian.brown@wilmerhale.com or (202) 663-6743.
Best regards,
Lillian Brown
cc:
Jolene Negre, Deputy General Counsel – Securities Regulation, Governance & Secretary
The Walt Disney Company
Does This Mean Disney Will Change DAS?
While this does not guarantee any changes are coming to the eligibility for DAS, this is good news for DAS advocates. The withdrawal of Disney’s request to exclude the proposal means shareholders will be able to vote on whether the company should formally evaluate and address these concerns. The company now has to publicly disclose the proposal and let shareholders weigh in, moving the issue out of internal discussions and into the public spotlight.
This is also a sign that the advocacy efforts are having an impact. The fact that Disney withdrew its attempt to exclude the proposal could indicate that these efforts are influencing corporate decision-making. It also creates a record that advocates can cite in future negotiations and media coverage. Shareholder proposals become part of the permanent proxy record, so even if it does not pass, it can be helpful to reference and keep disability access firmly on Disney’s agenda. DAS Defenders has become a prominent voice in the advocacy movement, consistently engaging with reporters to keep the disability access changes in the national spotlight.
On the other hand, Disney might feel confident that a formal review of DAS might come out in their favor, and allowing the possibility for a review to move forward could help bring the issue to a close. Regardless, shareholders would still need to vote in favor of the proposal for the review to move forward.
The proposal is expected to be included in Disney’s 2026 proxy materials and considered at the company’s annual shareholder meeting. The date for the next shareholder meeting has not been announced yet, but based on the company’s typical schedule, it should take place in the first quarter of 2026. The first quarter of 2026 runs from January 1 through March 31, 2026.
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We will continue to keep our readers informed of any updates to DAS as this process moves forward.
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I hope they decide to let people with disabilities have a chance for a pass. My son is in a wheelchair and last June we spent over 3000.00 dollars at Disney land and for my son it was a failure. 😞 it saddens me that he was not able to enjoy his family vacation. We won’t be renewing our magic pass this year. Thanks for letting me share our story.
Same experience here. My son is non verbal profound autism, mobility issues, etc.
We had a terrible interaction with a Disney cast member to get the DAS pass. The cast member was rude to us and mad sis felt bad for applying.
We will just go to universal instead where we were treated with respect and compassion
I totally understand the over use and abuse, w3e actually witnessed it. BUT people with mobility issues should be recognized. We were told just because we ride scooters as we couldn’t walk the park and stand the long lines due to mobility issues we were not allowed to get a disability pass. they said there is places to sit in every line. no there isn’t and scooters are not allowed in the lines, which I understand but parking them and then getting in a 40+ min lines is not going to work. Just simply can’t stand that long or walk that far. So we just figured Disney no longer values us as guests, and have stopped going. We will go where we are welcomed. It’s getting ridiculously over priced. It takes us a long time to save and then they excluded all of us with mobility issues. Thanks for letting me vent.
I agree with you I told them I issues standing in long lines and they said you can rent a wheelchair or scooter and to do that is is not feasible when you are spending a lot of money on food and they want you to spend around $100 dollars to rent a scooter because you have mobility issues they should rent something because of that it is your choice if you want to try and walk unfair
First off the disability access should be allowed for anyone with something that’s protected by disability access and instead they’ve made it entirely about mental or learning disabilities. Which by far are super important but what about people who have devastating diseases like ms, md, type 1 diabetes with seizures there’s so many things. It’s not that people are trying to skip the lines it’s that people like us literally can’t stand in them but we want to be able to enjoy life as best we can and Disney has really screwed the pooch on this recent change
On a side note for people with Mobility issues. I have mobility issues but that definitely is not a disability. That’s a Mobility issue. There are electric scooters that can be rented cheaper than the ones you’re talking about in disney. But when I’m Type 1 diabetic and I’m out in the heat even though I live in Florida and my body is used to the heat my veins open up, I become more sensitive to my insulin and even if I cut my insulin a couple of units which is about the maximum you’re allowed on a very busy day, I still end up having super low blood sugar seizures. Why not carry snacks you ask? I’m glad you asked. I do I carry an entire backpack but sometimes I get so low or I have to drink so much juice I end up having to get out of line or I have a seizure and repeatedly the on-site Walt Disney World specifically Magic Kingdom management has said I need to get on das. I had it for years then they took it away and said well diabetes is in a disability. Have they read the disability act? You technically aren’t classified as a full-time disabled person sitting at home go to work but it is protected. It’s absolutely ludicrous. And just take my diabetes and toss that to the side what about MD or MS or cystic fibrosis