As 2020 annual shareholder meeting dates draw closer, many companies are considering the feasibility of implementing virtual shareholder meetings due to the public health concerns associated with the COVID-19 pandemic (“Coronavirus”). Several high-profile companies have recently filed proxy statements stating that they will conduct their annual meetings virtually, or that they preserve their option to switch from a physical meeting to a virtual meeting at a later date. As companies evaluate these approaches, it is important to consider the legal requirements under federal regulations (particularly the latest SEC guidance), state law and a company’s own governing documents. In the past, institutional investors and proxy advisors have published policies objecting to virtual-only meetings on the ground that such meetings may deprive shareholders of meaningful participation rights. In light of the uncertainty caused by Coronavirus, companies should monitor regulatory and other developments, and work closely with their advisors to determine the appropriate approach to their annual meetings given the company’s particular circumstances and investor base.