E.ON Disclosure Scorecard

Detailed assessment of E.ON's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of E.ON'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 E.ON, 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 E.ON'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 E.ON'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 DisclosureYes, meets 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 E.ON'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
March 20222/14 (14%)
May 20244/14 (29%)

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 E.ON'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)?

E.ON

E.ON has published a broadly complete account of its positions and engagement activities on specific climate-related policies, but excludes 1 material evidence of direct climate policy engagement identified by InfluenceMap's database.

E.ON includes a link to the EU Transparency register which contains the company's government consultation responses to specific climate-related policies from 2023-2025, including the European Union's 2040 Climate Target, Certification of Carbon Removals and Electricity Market Design.

The company however does not appear to have disclosed its engagement on the EU Low Carbon Hydrogen Delegated Act in October 2024, as the Register does not include its consultation response on the Delegated Act, nor has E.ON disclosed its position on the policy on its website.

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)?

E.ON

E.ON has disclosed a list of its industry association memberships, but it excludes its membership to the Natural & bio Gas Vehicle Association. E.ON does not appear to have disclosed an account of its industry associations' positions and engagement activities. E.ON has therefore excluded key instances of engagement with specific climate-related policies by its industry associations.

For example, in a February 2024 testimony to the US Senate, Eurogas called on the Biden administration to reconsider its decision to pause liquified natural gas (LNG) export permits, citing energy security concerns. E.ON last updated its disclosure on its industry association memberships in May 2024, therefore its score has been reduced by 1.

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.

Corporate Climate Policy Engagement Review and Misalignment Management (Review Score): Scorecard - 4/14 (29%)

This is an assessment of the quality and robustness of a company's processes to identify, report on, and address specific cases of misalignment between its climate policy engagement activities (direct and indirect) and delivering the 1.5°C goal of the Paris Agreement.

The Review Score is split into seven indicators, which fall within one of three categories:

  • Review Process: Does the company have clear and robust governance processes to regularly assess alignment against the 1.5°C goal of the Paris Agreement, and address potential cases of misalignment?

  • Review Assessment (Direct - Company): Has the company identified and addressed specific cases of misalignment between its direct - i.e. corporate - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?

  • Review Assessment (Indirect – Industry Associations): Has the company identified and addressed specific cases of misalignment between its indirect – i.e. via industry associations - climate policy engagement and delivering the 1.5°C goal of the Paris Agreement?

The table below provides an overview of E.ON's performance under each sub-indicator, using the traffic-light assessment framework shown in the key.

Review ProcessReview Assessment (Direct)Review Assessment (Indirect)
Monitor & ReviewIdentify & AssessIdentify & Assess
Alignment Assessment MethodActAct
Framework for Misalignment

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

Review Process

Has the company established an annual monitoring and review process to ensure that all of its direct and/or indirect climate policy engagement activities across all geographies are consistent with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels?

E.ON

E.ON has committed to regularly publishing an updated version of its industry association review, and to continuously reviewing its alignment with its stakeholders. However, the company does not commit to an annual review of its climate lobbying activities. The company has published two reviews to date in March 2022 and May 2024.

Best Practice

Rio Tinto has published detailed assessments of its climate policy engagement on an annual basis from 2018 to 2024, with detailed updates on misaligned industry associations each year. The company has committed to continue reviewing its memberships on an annual basis. Alternatively, Shell publishes a detailed review of its climate policy engagement every two years, with a detailed update in the interim year.

Has the company disclosed a clear and detailed framework for assessing alignment, including: (1) the criteria it uses to assess whether its climate policy engagement activities (direct or indirect) align with the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels; and (2) a clear and detailed explanation behind each evaluation?

E.ON

E.ON has assessed the alignment of its industry associations against the company’s positions on four principles, which include: endorsement of the Paris Agreement; support for EU climate ambitions including the Fit-for-55 package; support for sustainable finance; and support for carbon pricing. As a result, E.ON has assessed the alignment of its industry associations against the company’s own climate policy positions. However, E.ON’s disclosure of its climate policy positions are limited to top-line statements in the document, without details on its specific positions on individual climate policies. As a result, the company does not appear to have assessed its associations’ detailed climate policy engagement positions and activities against science-based benchmarks for delivering the 1.5°C goal of the Paris Agreement.

E.ON has provided a table to disclose what constitutes a finding of alignment or misalignment in relation to the criteria provided. 'Aligned’ entities are aligned with E.ON’s climate position on the issues relevant to E.ON. ‘Partially aligned’ entities are partially aligned with E.ON’s position or commitment on the appropriate issue, and ‘Misaligned’ entities are considered to oppose E.ON’s position or commitment on the appropriate issue.

However the company does not appear to provide an overall evaluation for each industry association and the table provides no further details of the assessment.

Best Practice

Unilever assessed its industry associations’ climate policy engagement against both its own climate policy positions, and against science-based policy, determined by “what the Intergovernmental Panel on Climate Change (IPCC) has said is needed to keep global warming below 1.5°C”. Unilever states that this assessment does not mean associations should be expected to support every proposed climate law, but that when an association opposes a specific climate policy, it is incumbent on the association to engage constructively with policymakers to help find alternative, viable policy options that would be (at least) equally effective at reducing emissions.

The company also clearly disclosed the criteria for findings of alignment and misalignment with both its own policy positions and science-based policy, and measured the engagement intensity of each association. It also provided clear and detailed explanations behind each evaluation including their detailed policy positions and links to each industry association’s LobbyMap profile.

Has the company established a clear framework to address misalignments between its climate policy engagement activities (direct or indirect) and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, including the escalation strategies it will use and when it will use these escalation strategies?

E.ON

E.ON discloses a framework for addressing misalignments with its industry associations, including escalation strategies. E.ON states that, for those industry associations that it finds to be misaligned with its climate policy principles, the company will enter into a dialogue with the association and address their reasons for misalignment.

The company also states it will attempt to scrutinize the possibility to rework the industry association’s positions, and present the company’s reasons for its positions on climate-related issues and try to influence the association to reconsider. Should the association continue to take a misaligned position, E.ON disclosed that it will consider discontinuing their membership with the association.

However, the company does not provide clear deadlines for industry associations that do not amend misaligned practices.

Best Practice

Iberdrola has disclosed a clear and detailed framework to address potential misalignments, including escalation strategies and deadlines for industry associations that do not amend misaligned practices. Iberdrola's escalation strategy includes engagement with the industry association, sending a "notification of dissatisfaction", and formal notification that a termination of membership is being assessed. If the association does not provide a clear and credible action plan to address the misalignment within 12 months, Iberdrola will implement one or more of the following actions: make a clear public statement regarding the misalignment, request the industry association refrains from engaging on misaligned issues, and/or suspension or discontinuation of membership.

Review Assessment (Direct - Company)

Has the company identified and reported on the existence of all misalignments between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database (including all of its subsidiaries, business areas, and operational jurisdictions)?

E.ON

In its review, E.ON states that it's “lobbying positions and activities regarding climate protection are fully aligned with the Paris Agreement” and it is committed to lobbying “in line with the Paris Agreement in order to achieve the common goal of limiting global warming to a maximum of 1.5 degrees above the pre-industrial level.” However, the company provides no further details on any assessment of alignment.

As a result, E.ON has not identified any cases of potential misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. For example, in comments submitted on the EU 2040 Climate Target in June 2023, E.ON appeared to advocate for relying on industrial carbon removals over real greenhouse gas emissions reductions under the Target. Additionally, in its March 2023 Integrated Report, E.ON CEO Leonhard Birnbaum appeared to support the role of liquified natural gas (LNG) in the energy mix in the short term, to help address the energy crisis in Europe.

At time of this assessment, E.ON's InfluenceMap organization score was 72%, just below the cutoff for alignment between the Paris Agreement and the company’s detailed climate policy engagement (75%). Please see E.ON’s profile in the LobbyMap databased for additional details on the company's real-world climate policy engagement activities.

Best Practice

Danone assessed 12 of its own climate policy positions and engagement activities across Europe, the US, and globally. It found all 12 to be aligned. According to InfluenceMap’s database, Danone does not appear to have any material evidence of negative climate policy engagement during the reporting period. As a result, Danone has assessed its climate policy engagement activities in line with InfluenceMap’s findings. It is the only company to have ‘broadly met’ the criteria for this indicator.

Sasol published a detailed review of its direct climate policy engagement in August 2023. Sasol assessed the alignment of five of its own climate policy positions, including four in South Africa (Climate Change Bill; Carbon Tax; PCC Just Transition Framework; Upstream Oil and Gas Tax Regime Discussion Document) and one in the EU (European Union Delegated Acts). However, Sasol did not identify any cases of misalignment with its own climate policy engagement. As such, the company has not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database. The company has not updated its review in 2024.

As a result, no company has shown evidence of identifying cases of misalignment of its direct climate policy engagement and delivering on the 1.5°C goal of the Paris Agreement.

Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between its direct climate policy engagement activities and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?

E.ON

E.ON has not disclosed any details of a review of the alignment of its own climate policy engagement activities. As such, the company has shown no evidence of action to address cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement.

Best Practice

Danone and Unilever are the only companies to have ‘broadly met’ the criteria for this indicator by default. Both companies do not appear to have any material evidence of negative climate policy engagement according to InfluenceMap’s database, and therefore have no cases of misalignment to act upon.

As a result, no company has actively shown evidence of acting to address cases of misalignment between its own direct climate policy engagement activities and delivering the 1.5°C goal of the Paris Agreement.

Review Assessment (Indirect - Industry Associations)

Has the company identified and reported on the existence of all misalignments between the climate policy engagement activities of its actively engaged industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?

E.ON

E.ON assessed 70 initiatives, organizations and industry associations in its 2024 review. The company did exclude associations actively engaged on climate policy according to InfluenceMap’s database, including the Natural & bio Gas Vehicle Association (NGVA Europe).

The company identified total of five cases of misalignment within three industry associations: the Association of Hungarian District Heating Enterprises (MaTáSzSz), PTPiREE, and the Hungarian Power Cogeneration Association (COGEN Hungary). InfluenceMap does not currently cover these industry associations in its database. E.ON does not provide an overall evaluation for each industry association. As such, it is unclear how many associations E.ON found to be ‘Aligned’, ‘Partially aligned’, or ‘No position’ in total.

InfluenceMap analysis indicates that the company has at least 2 memberships to industry associations with active climate policy engagement misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database), including the Federation of German Industries (BDI) and NGVA Europe. InfluenceMap analysis also indicates that the company has 5 memberships to industry associations with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+), including Eurelectric, Eurogas, Hydrogen Europe, Confederation of British Industry (CBI) and European Round Table for Industry (ERT).

The company did not identify misalignments with these associations. As a result, the company has not identified key cases of misalignment and partial misalignment between its industry associations and delivering the 1.5°C goal of the Paris Agreement in line with InfluenceMap’s database. See Appendix A below for further details on the company’s industry association memberships.

Best Practice

Unilever assessed 27 industry associations in its review and identified all cases of misalignment and partial misalignment with its industry associations and the 1.5⁰C goal of the Paris Agreement in line with InfluenceMap's database. Unilever has membership to 1 misaligned industry association (Tennessee Chamber of Commerce & Industry), and 10 partially aligned associations.

Has the company reported on what action is being (or has been) taken to address misalignments, if and where they exist, between the climate policy engagement activities of its industry associations, and the goal of restricting global temperature rise to 1.5⁰C above pre-industrial levels, in line with InfluenceMap's database?

E.ON

E.ON has shown some evidence of action to address specific misalignments with its industry associations.

In its 2024 review, the company stated that in 2022 it went into dialogue with the associations it found to be misaligned and addressed the reasons for non-conformance and scrutinized the possibility on their side to rework their positions. These include the Association of Hungarian District Heating Enterprises (MaTáSzSz), PTPiREE, and the Hungarian Power Cogeneration Association (COGEN Hungary). The company also stated that in cases where positions did no change or permanently contradicted E.ON’s positions, the company challenged the continuation of its memberships.

However, E.ON does not appear to have shown evidence of action to address specific cases of misalignment and partial misalignment with delivering the 1.5°C goal of the Paris Agreement identified by InfluenceMap’s database.

Best Practice

Unilever is the only company to have met investor expectations in this area, showing evidence of action to address all cases of misalignment between its industry associations and delivering the 1.5⁰C goal of the Paris Agreement, as identified by InfluenceMap’s database. In its review, the company included a section for each association titled “Actions (to be) taken” in which it outlined the actions taken or to be taken with the industry association as per its assessment. For example, Unilever stated that it would write to the Tennessee Chamber of Commerce & Industry stating that their positions do not reflect those of Unilever. It also disclosed it would encourage the European Roundtable for Industry to continue to engage constructively on the EU Green Deal and explore how it can revise its position on the EU Emissions Trading System.

Additionally, Unilever stated that for the 12 associations that were deemed “passively aligned” (minimal to non-existent policy engagement), the company will aim to push the associations to become more actively engaged in promoting outcomes and policies that aid in decarbonization.

Key

Yes, meets criteria

Partial, meets some criteria

No, does not meet criteria

Appendix A: E.ON's Industry Association Memberships

The table below provides a ranking of E.ON'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.

Industry AssociationInfluenceMap Performance BandInfluenceMap Assessment
SolarPower EuropeB+Aligned
EurelectricB-Partially Aligned
European Round Table for Industry (ERT)C+Partially Aligned
Hydrogen EuropeCPartially Aligned
EurogasD+Partially Aligned
Carbon Capture and Storage Association (CCSA)D+Partially Aligned
Federation of German Industries (BDI)D+Partially Aligned
Natural & bio Gas Vehicle Association (NGVA Europe)D-Misaligned