The 5-Year Lookback. Hard Enforcement.
ISS and Glass Lewis 2026 doubled the pay-for-performance window from three years to five. Your 2021 retention awards are now mathematical inputs to your 2026 Say-on-Pay vote. The Long-Term Alignment narrative is the only proxy disclosure that survives the new framework.
The signal that triggered this briefing
The Delta: High Concern thresholds for S&P 500 firms have been tightened. Legacy pay decisions from 2021 are now actively dragging down 2026 Say-on-Pay scores. ISS RDA window: 3 years to 5 years. Glass Lewis quantitative window: 3 years to 5 years. Effective for 2026 annual meetings.
Action for the CEO and the Comp Committee: If your firm had a volatility event in 2021 or 2022, it is now a mathematical anchor on your current voting recommendations. You must include a Long-Term Alignment narrative in your proxy to explain the 5-year delta, rather than relying on recent 12-month successes.
The three things that changed
Every other change in the 2026 cycle flows from these three. Read the policy text and you find the same three architectural shifts running through both ISS and Glass Lewis.
1. The window doubled
ISS RDA: 3 years to 5 years. Glass Lewis quantitative tests: 3 years to 5 years (3-year fallback). ISS Multiple of Median: now 1-year and 3-year average. Time integration extended; legacy decisions stay in the screen longer.
2. Glass Lewis abandoned the letter grade
The familiar A-F scale is gone. In its place: a 0-100 scorecard composed of up to six tests, with a qualitative test that can only reduce the score. Weightings are not publicly disclosed.
3. ISS opened the door for time-based equity
For the first time in the Say-on-Pay era, ISS will view long-vesting time-based equity favorably without performance vesting conditions. Plus expanded flexibility for documenting Company Responsiveness when shareholders decline direct feedback.
The 5-Year Window Stack diagnostic
The mathematical anchor problem is fixable, but only at the proxy disclosure stage. Issuers who try to retrofit after a sub-70-percent 2026 result will face a 5-year window that mathematically prevents recovery through 2027 and 2028.
Six questions in 6 minutes
Answer the six questions below. If your answer is “yes” or “I don’t know” to four or more, the Long-Term Alignment narrative is required for your 2026 proxy.
The full diagnostic, with scoring and recommended Long-Term Alignment narrative emphasis, is in Section 12 of the Executive Playbook.
The product suite
Executive Briefing
Download the briefing PDF · Read the companion article
The crisis-cycle briefing for board directors and comp committee chairs. 25 pages. Establishes the governance frame, the 5-component Long-Term Alignment narrative architecture, the 3-document Documentation Stack, and the 70 percent trap. Companion to the May 2026 Playbook.
Executive Playbook
110 pages, 23 sections, 10 appendices. Full diagnostic, full templates, worked examples, ISS-Glass-Lewis Dual-Read Matrix, board-record-grade Documentation Stack specifications. Ships May 2026.
Executive Lab
Two half-day sessions. Comp committee builds its Documentation Stack in real time on its own peer group. Final deliverables: signed Multi-Year Alignment Philosophy Memo, populated Legacy-Award Disposition Log, drafted Engagement-and-Disclosure Protocol, reorganized CD&A skeleton.
Long-Term Alignment Diagnostic Engagement
Custom 1:1 advisory engagement. Touch Stone runs the diagnostic on your specific peer group, your specific 2021-2026 decisions, and (optional) your specific 2026 proxy disclosure draft. Four-week engagement.
Free download: the 24-page briefing
The plain-English version. Suitable for forwarding to your General Counsel, your comp consultant, your proxy solicitor, and your investor-relations team. Establishes the governance frame in under 20 minutes of reading time.