Disney just pulled off a corporate power move that’s got the disability community furious. A disabled shareholder named Erik Paul wanted an independent expert to review Disney’s controversial 2024 Disability Access Service changes, and Disney’s doing everything possible to make sure that review never happens.\
Paul filed a shareholder resolution asking Disney to commission a qualified third party to assess the legal, financial, and reputational risks of the DAS overhaul. Pretty reasonable request, right? Just have an independent expert look at what happened and report back. But Disney filed a letter with the SEC on November 4 asking to exclude the resolution from shareholder voting.
Then two weeks later, the SEC announced it would no longer review company exclusion requests. The timing is almost suspicious. Disney can now block Paul’s resolution without needing SEC approval.
What Paul Actually Wanted
Paul’s resolution wasn’t demanding Disney reverse the DAS changes or restore the old system. He just wanted an independent assessment. The specific language requested that Disney “commission an independent review, conducted by a qualified third party, of the company’s accessibility and disability inclusion practices. This review should assess legal, financial, and reputational risks; evaluate Disney’s policies against international accessibility standards and competitors; and identify opportunities for leadership improvement.”
He also asked Disney’s Board to provide both a public summary and internal briefing on findings to ensure accountability and transparency.
That’s it. No threats. No lawsuits. Just asking Disney to let an independent expert examine the DAS changes and report what they find. The fact that Disney’s fighting this so hard makes you wonder what they’re afraid an independent review might reveal.
Disney’s Arguments for Blocking It
Disney gave the SEC three reasons why Paul’s resolution should be excluded.
First, it’s “materially false and misleading,” meaning Disney thinks the resolution contains incorrect statements that would confuse shareholders.
Second, it “relates to ordinary business operations.” This is the argument companies use to block shareholder proposals about day-to-day decisions rather than major policy issues. Disney’s claiming DAS policies are just operational matters management should control.
Third, Disney says it already “substantially implemented” what the proposal requests, meaning the company claims it’s already doing independent reviews so the resolution is pointless.
Paul submitted a rebuttal challenging all three arguments. But here’s the problem: the SEC rule change means nobody at the SEC will actually evaluate whether Disney’s reasons are legitimate. Disney can just exclude the resolution based on its own say-so.
The SEC Rule Change That Changed Everything
On November 17, the SEC’s Division of Corporation Finance announced it would no longer review company attempts to exclude shareholder proposals except in limited state-law circumstances. The change took effect immediately.
Before this rule change, companies had to request SEC approval to exclude shareholder proposals. SEC staff would review both the company’s arguments and shareholder rebuttals before deciding whether exclusion was justified. It provided real protection for shareholders trying to raise concerns.
Now companies can exclude proposals based on their own interpretation with no SEC oversight checking whether their reasoning is sound. The power just shifted massively toward corporations and away from shareholders.
For Paul’s resolution specifically, the timing couldn’t be worse. Disney filed its exclusion request November 4. The SEC rule changed November 17. If the change had happened even a month later, the SEC would have reviewed Disney’s arguments. Instead, Disney gets to block it without any external check.
The DAS Changes That Started This Mess
Disney overhauled DAS at Walt Disney World and Disneyland in early 2024, significantly limiting who qualifies. Lots of guests who previously got DAS found themselves denied under the new rules.
Disney suggested alternatives like practicing waiting in line at home or asking for return times at attractions. The problem? Many cast members haven’t been trained to offer return times, creating confusion and wildly inconsistent experiences for disabled guests.
A class-action lawsuit filed in February 2025 against Disneyland alleges disability discrimination based on the DAS changes. The case is ongoing, which means Disney’s facing real legal risk from these policy changes.
Disney keeps tweaking DAS elements, including adding information about the required video call and extending how long the service is valid. These ongoing adjustments suggest Disney knows there are problems even as they fight to avoid independent review.
The changes affect real people with disabilities who planned Disney vacations expecting accommodations they’d received before. Guests share stories about being denied DAS despite qualifying under old criteria, getting conflicting information from different cast members, or being told to use alternatives that don’t work for their specific disabilities.
Paul’s Statement Calls Disney the Villain
Paul didn’t hold back in his response to Disney’s blocking tactics. Here’s his full statement:
“Disney has long told stories where the powerless rise, villains fall, and wrongs are made right. Its brand is built on magic, inclusion, and the belief that every voice deserves to be heard. Yet now, in a twist worthy of its darkest tales, the company risks becoming the villain of its own story, using newfound power to silence the very shareholders it should be listening to. Disney now faces a clear choice: live up to the values it sells to the world, or step into the role of villain silencing the disabled community.”
That’s brutal and accurate. Disney markets itself on inclusion and giving voice to the powerless. Now the company’s using corporate mechanisms to silence a disabled shareholder asking for basic accountability.
What This Actually Means
The shareholder resolution probably won’t reach a vote. Disney can exclude it based on the company’s own determination that exclusion grounds apply, with no SEC oversight.
The ongoing lawsuit will take years. Meanwhile, the 2024 DAS changes stay in effect with Disney making small adjustments without the independent review Paul wanted.
For disabled guests planning Disney trips, this situation shows how little recourse they have. If a shareholder can’t even get an independent review request onto a proxy ballot, regular guests have basically zero power to challenge Disney’s policies.
Disney’s fighting to avoid even a modest independent assessment undermines all the brand messaging about inclusion and hearing every voice. When the company uses every available corporate and regulatory tool to block accountability on disability policies, it proves Paul’s point about becoming the villain of its own story.
