Cummins Disclosure Scorecard

Detailed assessment of Cummins's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of Cummins's disclosures on climate policy engagement. This does not include an assessment of the company's real-world climate policy engagement, which can be found on InfluenceMap's online profile of Cummins, accessible via the buttons on the right hand side of the page.

The disclosure assessments are directly integrated into the CA100+ Net Zero Company Benchmark as part of InfluenceMap's Climate Policy Engagement Alignment’ assessment, under two distinct indicators:

  • Accuracy of Climate Policy Engagement Disclosures: An assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.
  • Robustness of Corporate Climate Policy Engagement Review & Misalignment Management Processes: An assessment of the quality and robustness of a company's process to identify, report on, and address specific cases of misalignment between its climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.

In 2023, InfluenceMap’s methodology to assess corporate disclosures on climate policy engagement was formally updated in line with the Global Standard on Responsible Climate Lobbying and stakeholder input. The detailed methodology - as well as additional resources including best practice guidance and Cummins's company profile - is accessible via the buttons on the right hand side of the page.

Accuracy of Climate Policy Engagement Disclosure: Summary

A summary of Cummins's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.

IndicatorScore
Accuracy of Climate Policy Engagement DisclosurePartial, meets some criteria
Sub-IndicatorScore
Accuracy of Direct Climate Policy Engagement DisclosurePartial, meets some criteria
Accuracy of Indirect Climate Policy Engagement DisclosureNo, does not meet criteria

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Summary

A summary of Cummins's performance under this assessment is shown below, using the traffic-light assessment framework shown in the key. A more detailed breakdown is available below.

The Review Score (0-100) assesses corporate performance against seven indicators, using the same traffic-light framework. A ‘Green’ scores 2 points, a ‘Yellow’ scores 1 point, and a ‘Red’ scores 0 points. This total is converted into a percentage from 0 to 100, calculated using the total number of points available (14). As such, only certain scores within the 0 to 100 range are possible under this methodology. A Review Score of 100 would indicate that a company has met all of the assessment criteria related to the review process.

Date of ReviewScore
N/ANo Review Published

Accuracy of Climate Policy Engagement Disclosure: Scorecard

This is an assessment of the accuracy of a company's reporting on its direct and indirect (via industry associations) climate policy engagement activities.

InfluenceMap utilizes its proprietary database to assess how corporate disclosures on climate policy positions and engagement activities compare to InfluenceMap's independent assessment of the companies' and industry associations' real-world climate policy engagement. In short, it assesses the extent to which the company has disclosed on all climate policy engagement identified by InfluenceMap's database.

The tables below provide: (1) a breakdown of Cummins's performance under each sub-indicator, using the traffic-light assessment framework shown in the key; and (2) examples of leading practice by companies.

Has the company published an accurate account of its corporate climate policy positions and engagement activities (as compared to InfluenceMap’s database)?

Cummins

Cummins has published a partial account of its positions and engagement activities on specific climate-related policies, but excludes over 3 cases of material evidence of direct climate policy engagement identified by InfluenceMap's database. Its corporate website links to its most recent sustainability report as well as US federal and state lobbyist registries, which include recent lobbying registrations on key legislation. For example, Cummins disclosed its engagement with the Department of Energy and US Treasury on hydrogen tax credits, although it did not clearly state that it advocated for their weaker implementation, and that it suggested the US Treasury was acting beyond its legal boundary.

In its 2024–25 Sustainability Report, Cummins disclosed strongly supporting the adoption of the EURO 7 Regulation in the EU, as well as testifying before the Texas House Committee on Environmental Regulation, advocating for hydrogen infrastructure incentives, and continue to push for vehicle and refueling infrastructure support through the Texas Hydrogen Alliance, although without stating the need to fully decarbonize.

However, Cummins does not appear to have disclosed a complete and accurate account of its climate policy engagement. For example, in the US, Cummins advocated for maintaining the Inflation Reduction Act’s clean hydrogen tax credit in a February 2025 joint letter, while emphasizing continued eligibility for fossil gas-based hydrogen in a June 2025 Industry Letter, and supported hydrogen infrastructure rules in a July 2025 joint letter. In a February 2025 meeting with DG CLIMA, European Commission, it promoted a technology-neutral approach to light-duty vehicle decarbonization, continued biofuels use, and hydrogen deployment over full electrification. Cummins also did not disclose its February 2024 comments to the EPA on GHG emissions standards for HDVs.

Best Practice

Enel has published a complete and accurate account of its positions and engagement activities on specific climate-related policies, and this is aligned with InfluenceMap's assessment of the company using its LobbyMap database. Enel included its climate advocacy activities, positions, and links to the company’s government consultation responses to specific climate-related policies from 2022-2024 in its 2023 Climate Policy Advocacy report, published April 2024. It also covered a range of regions in its disclosure, including Global, Europe, North & South America, Africa, and the Asia Pacific.

BP partially met the assessment criteria under this indicator, as it excluded material evidence of climate policy engagement. However, BP’s ‘Advocacy Activities’ webpage provides a clear and detailed disclosure of the company’s climate policy engagement, with filters for jurisdiction; date; and topic, including links to relevant consultation responses. It also contains sorting options for most recent, and most relevant.

Has the company published an accurate account of the climate policy positions and engagement activities of the industry associations of which it is a member (as compared to InfluenceMap’s database)?

Cummins

Cummins has disclosed a list of its industry association memberships, but excludes 6 industry associations which are actively engaged on climate policy, including the Confederation of Indian Industry (CII), European Association of Automotive Suppliers (CLEPA), the Fuel Cell and Hydrogen Energy Association (FCHEA), the National Mining Association (NMA), the Tennessee Chamber of Commerce & Industry, and The Transport Project.

The company's disclosure on its industry associations does not include any positions or references to climate policies. Cummins has therefore excluded key instances of engagement with specific climate-related policies by its industry associations. For example, in a July 2025 meeting with the EU Commission, CLEPA advocated for incentives over mandatory targets under the EU's Greening Corporate Fleets initiative

See Appendix A below for details of the company's industry association memberships.

Best Practice

Unilever has published a complete and accurate account of its industry associations' positions and engagement activities on specific climate-related policies. In its March 2024 industry association review, the company attached LobbyMap profile links to each association’s assessment. Iberdrola published a largely complete and accurate of its industry associations' positions and engagement activities on specific climate-related policies.

Iberdrola and its North American subsidiary Avangrid both disclosed the climate policy engagement activities of their industry associations in their respective industry association climate lobbying reviews.

Key

Yes, meets criteria

Partial, meets some criteria

No, does not meet criteria

Appendix A: Cummins's Industry Association Memberships

The table below provides a ranking of Cummins's industry associations currently covered by InfluenceMap’s database by Performance Band, i.e. a full measure of a company’s climate policy engagement, accounting for both its own engagement and that of its industry associations. Detailed profiles for all industry associations can be explored via the links in the table.

Industry associations are categorized by InfluenceMap as having climate policy engagement that is aligned, partially misaligned or misaligned with delivering the 1.5°C goal of the Paris Agreement by Performance Band:

  • Aligned = Performance Band A+ to B
  • Partially Misaligned = Performance Band B- to D+
  • Misaligned = Performance Band D to F
  • Low Engagement = Performance Band N/A

The ranking table below is updated automatically on a continual basis as: (1) new evidence is collected for the industry associations; (2) new industry associations are added to the company profile; (3) industry associations are removed from the company profile, e.g. if the company leaves the association.

As such, the industry associations and/or scores in the ranking table below may differ from the findings in Identify & Assess (Indirect) above, which was written on the date of assessment. See the top of this page for the date of assessment.