Executive Order 14366: Protecting American Investors From Foreign-Owned and Politically-Motivated Proxy Advisors

What does Executive Order 14366 do?

The SEC chair was asked to consider revising proxy adviser and shareholder proposal rules; the FTC was to investigate possible unfair or anticompetitive practices, and Labor to review retirement-plan fiduciary guidance under applicable law.

Later official evidence reviewed September 26, 2026: In April 2026, the Department of Labor issued technical guidance saying proxy advisers may qualify as ERISA investment-advice or functional fiduciaries under existing tests, expressly following this order. The guidance is not a final finding of misconduct against a particular firm or an SEC rule change.

Reading the operative provisions of Executive Order 14366

EO 14366 directs the Securities and Exchange Commission, Federal Trade Commission and Labor Department to review proxy-adviser practices, shareholder voting rules and potential foreign influence. Proxy advisers provide research and recommendations that investors may consider when voting corporate shares. The Federal Register text assigns agency reviews; it does not itself determine that a proxy adviser violated securities law or require investors to follow a particular vote.

The SEC regulates proxy solicitation and disclosure under federal securities law, while the FTC may examine competition and consumer-protection issues within its jurisdiction. Labor oversees rules that apply to certain employee benefit plans and fiduciary duties. These roles are distinct. Any change to proxy-voting requirements must be grounded in the agency’s statutory authority and follow the rulemaking process where required.

Proxy advisers can influence voting, but corporate shareholders retain their own decision-making responsibilities. Investors should consider the adviser’s methodology, conflicts, data and the company-specific proposal. Foreign ownership may raise disclosure or security questions, but it does not by itself prove that advice is politically motivated or inaccurate. Implementation should be judged through final SEC rules, enforcement actions and Labor guidance, not from the order’s stated concerns alone.