Disclosure on Corporate Climate Policy Engagement

InfluenceMap's Metrics Highlight Global Underperformance on Disclosure

An InfluenceMap Investor Briefing, July 2025

Introduction

Corporate climate policy engagement disclosure is rapidly emerging as a key focus for both investors and regulators. Nearly three-quarters of the world’s largest companies now report some information on their direct climate policy engagement. However, only a small minority (15%) provide disclosures that are both complete and accurate. Disclosures on indirect engagement, such as through industry associations, are even more limited, with nearly 90% of companies offering little or no meaningful information.

When evaluating climate policy engagement disclosures, the focus should be on the quality, accuracy, and completeness of the information—not simply its presence or volume. Rigorous fact-checking using external verification and comparison against accepted benchmarks is required for all corporate disclosure statements.

InfluenceMap’s LobbyMap platform is currently the only system capable of delivering this level of analysis at a global, diversified portfolio scale. Covering over 1,000 companies and 350 industry associations worldwide, it offers independent, externally fact-checked assessments of corporate climate policy engagement. This coverage encompasses the majority of most investment portfolios—both in terms of assets under management (AUM) and the policy advocacy impact of investee companies.

The LobbyMap platform's disclosure metrics and analysis enable investors and other stakeholders to distinguish between companies that are genuinely transition-ready and those that may be engaging in greenwashing. As regulatory standards continue to evolve and investor scrutiny intensifies, robust, independent verification of corporate climate disclosures will be essential. This will drive meaningful progress and equip investors with clear, decision-useful insights into how companies are navigating the global energy transition.

About InfluenceMap

InfluenceMap is a non-profit think tank providing objective and evidence-based analysis of how companies and financial institutions are impacting the climate and biodiversity crises. Our company profiles and other content are used extensively by a range of actors including investors, the media, NGOs, policymakers, and the corporate sector. InfluenceMap does not advocate or take positions on government policy. All our assessments are made against accepted benchmarks, such as the Intergovernmental Panel on Climate Change. Our content is open source and free to view and use (https://influencemap.org/terms).

Why Corporate Disclosures on Climate Policy Engagement Matter

As highlighted in a June 2025 briefing, co-written with BNP Paribas Asset Managment, Railpen, AkademikerPension, and Storebrand, transparent and comprehensive reporting on how companies engage with climate policy—both directly and through industry associations—is required by investors to:

  • Assess Company Risks and Transition Readiness: Investors need clear information to evaluate whether a company’s climate lobbying aligns with its public commitments and transition plans, helping to identify legal, reputational, and financial risks.

  • Manage Systemic Climate Risks: Transparent engagement supports the development of robust climate policies, reducing uncertainty and enabling investors to confidently allocate capital toward a net-zero economy.

  • Meet Evolving Regulatory and Stewardship Expectations: Growing investor initiatives and regulatory frameworks, such as the EU’s Corporate Sustainability Reporting Directive (CSRD) and the Global Standard on Responsible Corporate Climate Lobbying, are driving demand for consistent, decision-useful disclosure.

Investor Explainer on Climate Policy Engagement Disclosure

June 2025

This briefing makes the case for requiring reporting on corporate climate policy engagement in emerging mandatory disclosure regulations globally.

Information on a company’s policy positions, its direct and indirect (through trade associations) political engagement, and how this activity is governed, provides investors with an important insight into the coherence of its approach to tackling climate change and transitioning its business model, and the overall quality of its climate governance. Legal and reputational risks are also increasingly relevant, especially in cases where there may be a discrepancy between the company’s public statements and commitments and its policy engagement.

BNP Paribas Asset Management, Railpen, AkademikerPension, Storebrand, and InfuenceMap

Assessing Corporate Climate Policy Engagement Disclosures

Traditional approaches to "ESG" metrics often fall short in evaluating corporate climate policy engagement. They rely heavily on overly simplistic (yes/no) survey formats and company self-reporting, inevitably missing the real picture of how companies—and their industry associations—are actually influencing climate policy. This approach can obscure misalignments between public commitments and real-world lobbying, leaving investors exposed to hidden transition and reputational risks.

To address these issues, the LobbyMap platform:

Benchmarks Against the Global Investor Standard

InfluenceMap’s assessments of company disclosures are benchmarked against the Global Standard on Responsible Climate Lobbying—the leading best practice framework developed by investors on the topic to ensure alignment with the Paris Agreement.

Independently Verifies Disclosures

InfluenceMap systematically cross-references company disclosures with a wide range of independent, real-world data sources—including regulatory filings, government consultation responses, media reporting, statements from senior management, and investor communications. This external verification is essential for assessing the completeness and accuracy of company disclosures, as it reveals where companies may omit or misrepresent their actual policy engagement activities.

Grounds Assessments in Science to Surface Greenwashing

InfluenceMap’s assessments are based on the latest climate science and authoritative policy benchmarks, such as those from the Intergovernmental Panel on Climate Change (IPCC). This scientific foundation ensures the analysis is effective at detecting greenwashing and misinformation—giving investors a clearer, more reliable view of whether companies’ policy engagement truly supports the Paris Agreement’s climate goals.

How InfluenceMap Works with Investors on Corporate Disclosures

InfluenceMap has been working closely with investors to fact-check company disclosure on climate policy engagement since 2017. Since 2022, this has included directly feeding into the Climate Action 100+ (CA100+) Net Zero Company Benchmark, providing analysis that includes assessments of 150+ focus companies’ corporate climate policy engagement disclosures and governance mechanisms. These assessments are now being progressively made available for all 1,000+ companies on the LobbyMap platform via their individual company profiles. Initial examples can be viewed here for Unilever, Maersk, Enel, Stellantis, and Nippon Steel.

InfluenceMap is a vital tool for investors addressing corporate climate lobbying. It has shone a light for us into dark places and gives investors the tools to ask better questions, hold companies and their industry associations accountable and call for better practice. Having comparable disclosures is essential to drive transparency, demonstrate best practice, and so investors can effectively engage to push for progress on this important issue.

Laura Hillis, Director, Responsible Investment, Church of England Pensions Board

A Snapshot of Current Practice on Corporate Climate Policy Disclosure

While nearly three-quarters of the world’s largest companies now report some information on their direct climate policy engagement, only a small minority (15%) provide disclosures that are both complete and accurate when compared to real-world lobbying activities tracked by InfluenceMap’s LobbyMap platform. 1 Disclosures on indirect engagement—such as through industry associations—are even weaker, with almost 90% of companies offering little or no meaningful information.

Breakdown of Corporate Climate Policy Disclosure Assessments

Investor engagement, particularly through initiatives like CA100+ and frameworks like the Global Standard on Responsible Corporate Climate Lobbying, has been instrumental in driving improvements among companies with the strongest disclosures. In particular, there has been a steady increase in companies publishing “climate policy engagement reviews” that follow this standard, offering detailed insights into their own and their industry associations’ policy activities, highlighting any misalignments with their climate commitments, and outlining actions taken to address these gaps.

InfluenceMap, using its LobbyMap database, has fact-checked nearly 250 enhanced “climate policy engagement reviews”—reflecting the Global Standard—from over 100 companies, many on the CA100+ target list, and found a steady rise in quality. Leading firms such as Unilever, Enel, IKEA, and EDF now meet most investor expectations in detail. Transparency levels are notably higher in Europe, with over a third of companies providing strong disclosures on direct climate policy engagement. This is likely driven by active investor engagement and the inclusion of climate policy engagement in regulated reporting frameworks like the EU’s Corporate Sustainability Reporting Directive.

Breakdown of Corporate Climate Policy Disclosure Across Key Regions

However, the overall inconsistency in disclosure leaves investors with an uneven and potentially misleading picture of corporate climate strategies, undermining their ability to assess both company-specific and systemic transition risks and opportunities.

  1. The analysis in this briefing examines the reporting of 450 companies in the wider LobbyMap database of over 1000 companies. These companies, which include those on the Climate Action 100+ target list, represent a broad spectrum of sectors. They were chosen for their exhibition of at least a minimum level of active engagement with climate policy, as assessed by the LobbyMap platform. All assessments were made between the start of 2024 and Q1 2025.

Regulating Corporate Climate Policy Disclosures

InfluenceMap will continue to work with the growing number of investors engaging companies on their climate policy engagement activities to provide independent, evidence-based verification of corporate disclosure on the topic. To support this, InfluenceMap is broadening the coverage of its climate policy engagement disclosure and review assessments beyond the Climate Action 100+ focus list and has begun publishing the additional assessments across its LobbyMap database of over 1,000 company profiles.

However, voluntary action alone is insufficient. Aligned, regulated disclosure standards will be required to close the gap between corporate best practices and the many companies that provide limited or inadequate information on their climate policy engagement. Several regulatory opportunities have emerged to address this gap, including the integration of International Financial Reporting Standards (IFRS) into national frameworks and the development of policies on corporate transition plans. While governments face pressure to avoid overly burdensome disclosure frameworks, there is an opportunity to prioritize near-term, decision-useful information—such as transparent reporting on corporate climate policy engagement.

The summary graphic below assesses the extent of a selection of key initiatives' coverage of climate policy engagement, measured by benchmarking each standard against the provisions set out by the Global Standard on Responsible Climate Lobbying. The analysis of these standards is split into four categories.

  • International standards: Internationally recognized sustainability reporting frameworks
  • Regional/national standards: Introduced by regulators in different jurisdictions (IFRS-aligned standards are not included here for brevity)
  • Voluntary net-zero standards: Voluntary initiatives for companies to meet certain net-zero criteria
  • Transition plan frameworks: Initiatives and regulations on the disclosure and implementation of corporate transition plans

Coverage of Climate Policy Engagement in Emerging Standard Frameworks