CGI Glass Lewis has recently updated its proxy voting guidelines, introducing a quantitative benchmark for CEO minimum shareholding requirements (see HERE).

Under the revised approach, a holding of at least three times fixed remuneration is viewed as appropriate, while a minimum of two times fixed remuneration is considered acceptable.

In this article, Guerdon Associates researched the Minimum Shareholding Requirement (MSR) policies of ASX 300 Chief Executive Officers (CEOs). The disclosure cut-off date was 15 August 2025, with data sourced from the most recent company annual reports available as of that date. After excluding delisted companies, the final sample consists of 296 ASX-listed companies.

Table 1: Presence of CEO minimum shareholding requirements and guidelines in the ASX300

 

Data shows that 45% of companies in the ASX300 have a disclosed a minimum shareholding policy for CEOs, of which 39% are structured as requirements and 6% as guidelines. Just over half of ASX300 companies have not disclosed a minimum shareholding policy.

The data is further split into two groups: policies based on base salary and those based on fixed remuneration.

Table 2: CEO minimum shareholding policies in the ASX300

 

Table 2 shows the median CEO minimum shareholding policy across two separate samples — 200% of base salary and 100% of fixed remuneration.

Twenty-two companies with an MSR policy did not disclose the number of years given to achieve. Two companies disclosed that there is no time limit to achieve the minimum shareholding requirement.

By GICS Sector

Tables 3 and 4 below show the minimum shareholding policies and guidelines within the ASX300 by GICS sector.

Table 3: Presence of CEO minimum shareholding policies and guidelines by GICS Sector

 

The Information Technology sector was the least likely to disclose a minimum shareholding policy, with 73% of companies providing no disclosure. This was closely followed by the Communication Services and Consumer Discretionary sectors, where 67% of companies did not disclose such a policy.

Table 4: Average CEO minimum shareholding policies by GICS Sector

 

Based on base salary, the highest average minimum shareholding policy for CEOs was in the Materials sector at 457%, while the lowest was in the Energy sector at 50%.

When measured against fixed remuneration, the highest average policy was in the Energy sector at 179%, with the lowest again in the Information Technology sector at 100%.

Across sectors, the time allowed to meet the minimum shareholding requirement ranged from 4.25 to 5.13 years.

By Market Capitalisation

The below table summarises the differing MSR policies by 30-day average market capitalisation quartiles, as of the 15^th of August 2025.

Table 5: Average CEO minimum shareholding policies by market capitalisation

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