The Walt Disney Company has agreed to address a shareholder proposal to review the impact of its Disability Access System (DAS). This system has gone through multiple changes over the years. The most recent significant change saw it focus on “Guests who, due to a developmental disability like autism or similar, are unable to wait in a conventional queue for an extended period of time.”

At the end of 2025, a Disney shareholder requested that Disney hire an independent expert to analyze the impacts of the changes to the current DAS policy:

Shareholders request 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. Shareholders further request that the Board provide a public summary and internal briefing on the findings to ensure accountability and transparency.

Shareholder Proprosal

Initially, Disney submitted a no-action request to the Securities and Exchange Commission. However, this changed, and Disney withdrew the no-action request and agreed with the shareholder proposal.

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

Erik G. Paul

The next step for this proposal will be a vote by shareholders this spring at Disney’s annual shareholder meeting. The proposal will appear in Disney’s 2026 proxy materials for shareholder consideration at the annual meeting. Daps Magic will continue to monitor this story and provide updates as they become available.