ExxonMobil Disclosure Scorecard

Detailed assessment of ExxonMobil's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of ExxonMobil'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 ExxonMobil, 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 ExxonMobil'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 ExxonMobil'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 DisclosurePartial, meets some criteria

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

A summary of ExxonMobil'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
April 20224/14 (29%)
January 20244/14 (29%)
January 20254/14 (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 ExxonMobil'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)?

ExxonMobil

ExxonMobil has published a partial account of its positions and engagement activities on specific climate-related policies, but excludes and provides a misleading account on more than 3 items of material evidence of direct climate policy engagement identified by InfluenceMap's database. ExxonMobil has disclosed its position on, and engagement with, specific climate-related policies, including the US Inflation Reduction Act and the Environmental Protection Agency (EPA)'s methane regulations.

However, the company's 2025 Advocacy Report only discloses its top-level positioning on climate policies, focusing mainly on its 2022-23 advocacy. As a result, ExxonMobil does not appear to have disclosed a complete and accurate account of its climate policy engagement.

For example, the 2023 Lobbying Report released in January 2025 stated that the company “lobbied in support of durable methane regulations,” including the EPA methane rule in the US. In contrast, InfluenceMap's assessment shows that the company was unsupportive of the proposal. For instance, comments submitted by ExxonMobil to the EPA in January 2022 showed a mixed position on the proposed regulation, supporting some elements of the policy while appearing to suggest that more ambitious state-level programs would be of "questionable legality." Other comments submitted by the company in the same month appeared unsupportive of methane leak detection provisions.

In addition, the company has not disclosed its recent engagements with other climate proposals. In comments to the EU in October 2024, ExxonMobil advocated to weaken the EU Hydrogen and Gas Decarbonization Package Delegated Act. In June 2024, the company opposed Colorado's SB24-159 Bill that proposed the phasing out of oil and gas permits by 2030. In Australia, ExxonMobil advocated for fossil gas in an April 2024 consultation.

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)?

ExxonMobil

ExxonMobil has published a partial account of its industry associations' positions and engagement activities on specific climate-related policies. However, ExxonMobil excludes more than 3 cases of material evidence of indirect climate policy engagement identified by InfluenceMap's database.

In addition, the company did not disclose its memberships to 2 groups that are actively engage on climate policy, including Asia Natural Gas and Energy Association (ANGEA) and Federation of Indian Petroleum Industry (FIPI). InfluenceMap has found that the American Petroleum Institute opposed the US Environmental Protection Agency's (EPA) GHG emissions standards for heavy-duty vehicles (HDV) in October 2024 comments and opposed the methane fee in March 2024 comments.

Texas Oil and Gas Association also opposed EPA's GHG standards for HDVs in an October 2024 joint industry brief. Furtherrmore, The International Association of Oil and Gas Producers opposed EU Methane Regulation for the energy sector in a November 2024 feedback to policymakers.

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 ExxonMobil'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 ExxonMobil'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 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?

ExxonMobil

ExxonMobil has published 3 reviews of its climate policy advocacy to date. The company released its first review in April 2022 and the second in January 2024, in which it assessed its 2021 and 2022 climate advocacy activities, respectively. The latest report, published in January 2025, covers the 2023 reporting cycle. In this report, the company has committed to annually review and publicly report its alignments and misalignments with industry associations.

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?

ExxonMobil

ExxonMobil has assessed the alignment of its industry associations against top-line positions on climate policy, and the company’s own climate policy positions. The company’s primary criteria for assessment considers whether an organization acknowledges the “importance of energy security.”

The company assesses its climate policy alignment against four key areas: the Paris Agreement, limiting average global warming to "well below 2 degrees Celsius", policies to incentivize emissions reductions, and advocacy on specific climate policy proposals. However, ExxonMobil does not provide a clear explanation of what constitutes a finding of alignment, partial alignment, or misalignment in relation to the criteria disclosed.

AS such, it is unclear whether the company has assessed alignment against policy pathways for delivering the1.5°C goal of the Paris Agreement. ExxonMobil states that it assesses whether an industry association's advocacy is in line with helping society achieve a "net-zero future", and limiting global warming to "below 2°C.” However, there is insufficient information provided in this methodology or the assessments to explain how this has been applied in practice, and therefore it is unclear to what extent the company has assessed alignment with the 1.5°C goal of the Paris Agreement.

While ExxonMobil has provided explanations behind the evaluations of its 3 partially aligned industry associations and 1 misaligned industry association, the company has not provided explanations for the remaining industry associations that it found to be aligned.

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?

ExxonMobil

ExxonMobil disclosed a framework for addressing misalignments with its industry associations in its review, which includes clear escalation strategies. Where a misalignment exists, the company will work towards alignment with the organization. Where the company fails to find alignment across critical issues, or where an organization is not committed to engaging constructively, ExxonMobil may choose to cease membership to this industry association.

However, ExxonMobil has not disclosed 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)?

ExxonMobil

ExxonMobil states in its lobbying report that its “direct lobbying activities are aligned with limiting average global warming to below 2 degrees Celsius.” However, InfluenceMap analysis suggests that 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.

In the report, ExxonMobil stated that it “lobbied in support of durable methane regulations”, including the Environmental Protection Agency’s (EPA) methane regulations for the oil and gas sector in the US. However, InfluenceMap’s assessment shows that the company was unsupportive of the proposal. For instance, comments submitted by ExxonMobil to the EPA in January 2022 showed a mixed position on the proposed regulation, supporting some elements of the policy while appearing to suggest that more ambitious state-level programs would be of "questionable legality." Other comments submitted by the company in the same month appeared unsupportive of methane leak detection provisions.

At the time of this assessment, ExxonMobil’s LobbyMap Organization Score was 44%, indicating that the company’s direct climate policy engagement is misaligned with science-aligned pathways for delivering the 1.5°C goal. The company also has an engagement intensity of 38%, indicating strategic, oppositional engagement with climate policy. Please see ExxonMobil’s profile in the LobbyMap database 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?

ExxonMobil

ExxonMobil has shown no evidence of action to address cases of misalignment between its direct climate policy engagement and science-aligned policy pathways for 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?

ExxonMobil

ExxonMobil has not identified key cases of misalignment between its actively engaged industry associations and delivering the 1.5ºC goal of the Paris Agreement. The company assessed 65 associations in its 2025 review, and excluded multiple actively engaged industry associations, including (but not limited to) the Consumer Energy Alliance, Asia Natural Gas and energy Association (ANGEA) and Japan Chemical Industry Association (JCIA).

ExxonMobil found 61 out of the 65 organization assessed as aligned, 3 partially aligned (American Fuel and Petrochemical Manufacturers (AFPM), Louisiana Mid-Continent Oil and Gas Association (LMOGA), Texas Oil & Gas Association (TXOGA)), and 1 misaligned (American Exploration & Production Council (AXPC)).

However, InfluenceMap analysis indicates that the company has memberships to at least 20 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 AFPM. InfluenceMap’s analysis also indicates the company has 16 memberships to industry associations that InfluenceMap assesses to be partially aligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).

As ExxonMobil only identified 3 partially aligned associations, and 1 misaligned association, it has not identified the above cases of partial misalignment and 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?

ExxonMobil

ExxonMobil has shown evidence of taking some action to address misalignments. In its 2025 review, ExxonMobil has stated that it will end its membership to the American Exploration & Production Council (AXPC) in 2025, reporting that it worked to “bring AXPC closer in alignment with ExxonMobil climate principles” prior to this decision. Previously, in its 2022 Climate Lobbying Report, published in January 2024, ExxonMobil stated that it withdrew its membership to the Independent Petroleum Association of America (IPAA) in 2022, after deeming it to be misaligned on climate grounds.

Regarding the 3 partially aligned organizations, the company states that it will continue to work with them to develop policy positions and enhance alignment. However, there are limited details on the specific outcomes sought in these engagements, and the company does not address the specific misalignments with the associations.

Furthermore, ExxonMobil does not show evidence of action to address other 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: ExxonMobil's Industry Association Memberships

The table below provides a ranking of ExxonMobil'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
Confederation of British Industry (CBI)B-Partially Aligned
American Cleaning Institute (ACI)C+Partially Aligned
Offshore Energies UK (OEUK) (Formerly OGUK)C+Partially Aligned
International Emissions Trading Association (IETA)CPartially Aligned
Federation of Indian Petroleum Industry (FIPI)CPartially Aligned
International Petroleum Industry Environmental Conservation Association (Ipieca)CPartially Aligned
Indonesian Petroleum AssociationCPartially Aligned
Fuels Industry UK (formerly UKPIA)CPartially Aligned
AmCham EUCPartially Aligned
Dutch Employers' Federation (VNO-NCW)C-Partially Aligned
China Petroleum and Chemical Industry FederationC-Partially Aligned
European Chemical Industry Council (Cefic)C-Partially Aligned
International Gas UnionC-Partially Aligned
Japan Chemical Industry Association (JCIA)C-Partially Aligned
PlasticsEuropeD+Partially Aligned
Carbon Capture and Storage Association (CCSA)D+Partially Aligned
German Association of the Automotive Industry (VDA)D+Partially Aligned
Australian Pipelines and Gas AssociationD+Partially Aligned
Asociación Mexicana de Empresas de Hidrocarburos (AMEXHI)D+Partially Aligned
Federation of German Industries (BDI)D+Partially Aligned
International Swaps and Derivatives Association (ISDA)D+Partially Aligned
International Association of Oil and Gas Producers (IOGP)DMisaligned
Clean Hydrogen Future Coalition (CHFC)DMisaligned
Business RoundtableDMisaligned
American Chemistry Council (ACC)DMisaligned
KazEnergyDMisaligned
FuelsEuropeDMisaligned
Malaysian Gas AssociationDMisaligned
Australian Institute of PetroleumDMisaligned
Pathways AllianceDMisaligned
German Chemical Industry Association (VCI)DMisaligned
Asociación Colombiana de Petróleo y Gas (ACP)DMisaligned
International Air Transport Association (IATA)DMisaligned
Brazilian Institute of Oil and Gas (IBP)DMisaligned
BusinessEuropeD-Misaligned
Canadian Association of Petroleum Producers (CAPP)E+Misaligned
Korea Gas UnionE+Misaligned
Asia Natural Gas and Energy Association (ANGEA)E+Misaligned
Australian Energy Producers (Formerly APPEA)E+Misaligned
Western States Petroleum Association (WSPA)EMisaligned
Natural Gas Supply Association (NGSA)EMisaligned
National Association of Manufacturers (NAM)EMisaligned
US Chamber of CommerceEMisaligned
Consumer Energy AllianceE-Misaligned
American Petroleum Institute (API)E-Misaligned
American Fuel & Petrochemical Manufacturers (AFPM)E-Misaligned
Texas Oil & Gas Association (TXOGA)FMisaligned