FirstEnergy Corp Disclosure Scorecard

Detailed assessment of FirstEnergy Corp's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of FirstEnergy Corp'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 FirstEnergy Corp, 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 FirstEnergy Corp'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 FirstEnergy Corp'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 DisclosureNo, does not meet criteria
Sub-IndicatorScore
Accuracy of Direct Climate Policy Engagement DisclosureNo, does not meet 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 FirstEnergy Corp'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
Q1 20233/14 (21%)
Q1 20242/14 (14%)
Q4 20242/14 (14%)
Q1 20252/14 (14%)

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 FirstEnergy Corp'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)?

FirstEnergy Corp

FirstEnergy's disclosure of its positions is limited to top-line climate statements without reference to specific climate-related policies. As a result, in its latest Corporate Responsibility Report published June 2024, the company appears to have excluded key engagements with specific climate proposals.

For example, FirstEnergy signed March 2025 comments with the Utility Water Act Group that supported the removal of implementation regulations around the National Environmental Policy Act, and subsidiary Jersey Central Power & Light submitted March 2025 testimony before the New Jersey Senate Legislative Oversight Committee that advocated for fossil gas infrastructure.

The score has been further reduced by 1 as the company has not updated its disclosure in over a year.

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)?

FirstEnergy Corp

FirstEnergy has disclosed a complete list of its industry association memberships. FirstEnergy has disclosed a complete list of its industry association memberships. However, the company's disclosure on its industry associations is limited to top-line climate statements without reference to specific climate policies. FirstEnergy has therefore excluded key instances of engagement with specific climate-related policies by its industry associations.

For example, Edison Electric Institute filed a May 2024 legal challenge of the finalized carbon standards for new gas and existing coal power plants, and submitted March 2025 comments that supported the Trump administration's repeal of implementing regulations for the National Environmental Policy Act (NEPA) review process. Meanwhile, the US Chamber of Commerce submitted a May 2025 letter to the US Senate in support of repealing the Environmental Protection Agency's waivers for California's vehicle emissions regulations, as well as an April 2025 letter to the US House of Representatives that advocated for annual fees on electric vehicles.

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 - 2/14 (14%)

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 FirstEnergy Corp'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 FirstEnergy Corp'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?

FirstEnergy Corp

In its first review published in August 2021, FirstEnergy stated that it would actively monitor its memberships, participation and alignment with trade associations, and publish this assessment quarterly on its corporate website.

FirstEnergy has published at least 7 updates to date since Q4 2021. According to the company, its latest Q1 2025 update covers “direct and indirect contributions to 501(c)(4) organizations, as well as payments to 501(c)(6) trade organization that exceeded $25,000” between January 1, 2025 and March 31, 2025.”

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?

FirstEnergy Corp

FirstEnergy has not disclosed a methodology for assessing alignment, criteria for findings of alignment, or explanations behind each evaluation of its industry associations.

FirstEnergy does not disclose a clear explanation of its alignment assessment method, stating that it is measured against its climate position and strategy but with no reference to what this involves, or what would constitute a finding of alignment or misalignment in relation to these criteria. As such, it is unclear if FirstEnergy has assessed its associations’ detailed climate policy engagement activities against science-aligned policy pathways for delivering the 1.5°C goal of the Paris Agreement.

In addition, the company has disclosed no explanation behind how the framework has been applied to each industry association, just disclosing their “Position on climate” and stating that each is “Aligned”, “Partially Aligned”, or “Not applicable.”

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?

FirstEnergy Corp

In its first review published in August 2021, FirstEnergy outlined the steps it will take to address different degrees of misalignment, with some escalation strategies. The company states that it will either dissent or resign membership for significantly misaligned groups, and it will engage and advocate for further alignment for partially aligned groups. It is however unclear if this framework still applies in 2025. There are also no timelines attached to this framework for industry associations which 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)?

FirstEnergy Corp

FirstEnergy has not published a review of the alignment of its own climate policy engagement activities. The company has therefore not identified any cases of misalignment between its direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement.

For example, via subsidiary Monongahela Power Company, FirstEnergy joined the ad hoc utilities coalition “Electric Generators for a Sensible Transition” and submitted an August 2024 emergency application for immediate stay of the Biden administration’s finalized carbon standards for existing coal- and new gas-fired power plants.

At the time of this assessment, FirstEnergy’s LobbyMap Organization Score was 44%, indicating that the company’s direct climate policy engagement is misaligned with science-aligned policy pathways for achieving the goal of the Paris Agreement to limit warming to 1.5°C. Its Engagement Intensity metric is 22%, indicating active, obstructive climate advocacy activities. Please see FirstEnergy’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?

FirstEnergy Corp

FirstEnergy has not published a review of the alignment of its own climate policy engagement activities. The company has therefore 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?

FirstEnergy Corp

FirstEnergy assessed 14 organizations in its Q1 2025 review update. FirstEnergy appears to exclude 1 industry association actively engaged on climate policy (the US Chamber of Commerce), however this may be because its Q1 2025 update only covers contributions between January 1, 2025 and March 31, 2025. InfluenceMap notes that the company did include the US Chamber in its prior update (Q4 2024) and found it to be aligned.

In its Q1 2025 review, FirstEnergy found 1 association to be aligned (Edison Electric Institute), 6 groups to be partially aligned, and 7 groups to be “not applicable.” FirstEnergy did not find any associations to be misaligned.

InfluenceMap analysis indicates that the company has at least 1 membership (US Chamber of Commerce) to industry associations with active climate policy engagement misaligned with science-aligned policy pathways for delivering the 1.5°C goal of the Paris Agreement (ranked D or below on InfluenceMap’s database) and at least 1 industry association (Edison Electric Institute) with active climate policy engagement partially misaligned with policy pathways for delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).

FirstEnergy therefore has not identified key cases of misalignment and partial misalignment between its actively engaged industry associations and policy pathways for delivering the 1.5°C goal of the Paris Agreement.

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?

FirstEnergy Corp

The company does not appear to have shown evidence of action to address specific cases of misalignment and partial misalignment with science-aligned policy pathways 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: FirstEnergy Corp's Industry Association Memberships

The table below provides a ranking of FirstEnergy Corp'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
Edison Electric InstituteD+Partially Aligned
US Chamber of CommerceEMisaligned