National Grid Disclosure Scorecard

Detailed assessment of National Grid's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of National Grid'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 National Grid, 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 National Grid'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 National Grid'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 National Grid'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 20243/14 (21%)

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 National Grid'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)?

National Grid

National Grid exhibits very high levels of engagement with climate policy. National Grid has published a partial account of its positions and engagement activities on specific climate-related policies in its Annual Report published in May 2025 and industry association review published in May 2024, but excludes more than 6 material evidence of direct climate policy engagement identified by InfluenceMap's database.

Across these disclosures, National Grid has disclosed a partial account of its engagement with specific climate-related policies in the UK (Energy Act of 2023, 2030 renewable energy target) and the US (Inflation Reduction Act, state-level energy policies in Massachusetts and New York). However, the company does not appear to have disclosed a complete and accurate account of its climate policy engagement.

For example, National Grid signed an April 2025 joint letter advocating for the UK and EU Emissions Trading Scheme to be linked and submitted April 2024 written evidence to the UK's Net Zero and Trade Inquiry. In the US, the company advocated repeatedly to weaken the implementation of the Inflation Reduction Act's clean hydrogen tax credit, including in February 2024 individual comments, a February 2024 industry letter, and a July 2023 joint letter.

National Grid also signed September 2023 joint comments in support of the US Department of Energy's energy conservation standards for water heaters. At the state level, according to its Massachusetts reports for lobbying activities between January and June 2025, National Grid engaged on the state's renewable energy portfolio standard.

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)?

National Grid

National Grid has published a partial account of its industry associations' positions and engagement activities on specific climate-related policies in its industry associations review, which was published over a year ago in May 2024. However, the company appears to exclude material evidence of indirect climate policy engagement identified by InfluenceMap's database for more than 3 industry associations.

For example, National Grid disclosed Edison Electric Institute (EEI)'s support for including clean energy investments in the Inflation Reduction Act. However, the company did not include the group's negative engagement on federal regulatory proposals, including March 2025 comments on the Trump administration's repeal of the National Environmental Policy Act implementation regulations and May 2024 comments on the regulation of carbon emissions from existing gas plants. The score has been further reduced by 1 as the company has not updated its disclosure in over a year.

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 - 3/14 (21%)

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 National Grid'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 National Grid'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?

National Grid

National Grid has committed to periodically publishing an update to its review of its industry associations, but not explicitly on an annual basis. This is the company’s first published corporate climate policy engagement review.

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?

National Grid

National Grid has disclosed a clear methodology for assessing alignment. The company assessed its industry associations against three criteria: 1) commitment to the 1.5ºC ambition of the Paris Agreement and net zero; 2) support for the energy transition; and 3) other relevant positions, including carbon pricing, energy efficiency and heat decarbonization, and transport decarbonization.

National Grid does not appear to clearly explain what constitutes a finding of alignment or misalignment within each of these criteria. However, in the four cases where the company has found there to be "partial misalignment" with an industry association, National Grid explains that the specific area of misalignment is each group’s position on the “future role envisioned for natural gas within the clean energy transition.” In these cases, National Grid describes the industry group’s high-level position on the role of gas in the energy transition and compares it to the company’s operational commitment to fully replace the fossil fuels within its existing gas network with renewable natural gas and green hydrogen by 2050.

In addition, National Grid did provide explanations for each assessment, disclosing how each association that it found to be fully aligned performed under the 3 assessment criteria. In these cases, the company appears to have focused on an assessment of its industry association's high-level statements, while occasionally including details of specific policy engagements.

However, the company appears to have assessed its association’s top-line support for the 1.5°C goal of the Paris Agreement (their "commitment' to the goal), rather than an analysis of its associations’ climate policy engagement activities against science-based benchmarks for delivering the 1.5°C goal of the Paris Agreement.

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?

National Grid

National Grid has disclosed a framework for addressing misalignments within its industry associations, but the disclosure does not include escalation strategies, nor does it include clear deadlines for industry associations which do not reform misaligned practices.

National Grid stated that it will continue to engage with the associations it found to be partially aligned to work toward fully adopting the company’s own position, including through its leadership positions and participation in working groups, committees, or other forums.

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)?

National Grid

National Grid 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. National Grid links its Global Corporate Policy on Responsible Lobbying and Political Engagement, which broadly states that the company lobbies and engages in line with the 1.5°C goal of the Paris Agreement on UK, US, and EU policy, however neither the document nor the review identifies any cases of misalignment.

InfluenceMap has detected multiple cases of misalignment between National Grid’s direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement. For example, the company has repeatedly engaged to weaken the proposed implementation of the Inflation Reduction Act’s clean hydrogen tax credit, including in February 2024 individual comments and joint comments to the Internal Revenue Service, a July 2023 letter, and an April 2023 letter.

Please see the National Grid’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?

National Grid

National Grid 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 delivering the 1.5°C goal of the Paris Agreement.

InfluenceMap has detected multiple cases of misalignment between National Grid’s direct climate policy engagement and delivering the 1.5°C goal of the Paris Agreement. For example, the company has repeatedly engaged to weaken the proposed implementation of the Inflation Reduction Act’s clean hydrogen tax credit, including in February 2024 individual comments and joint comments to the Internal Revenue Service, a July 2023 letter, and an April 2023 letter.

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?

National Grid

National Grid has assessed 35 industry associations in its review. It did not include an industry association that is actively engaged on climate policy within the scope of the review, namely the Business Council of New York State.

National Grid finds 31 associations to be aligned, 4 to be partially aligned, and 0 to be misaligned. The cases of partial alignment are the American Gas Association and Gas Infrastructure (in addition to the Interstate Natural Gas Association and the Northeast Gas Association, which are not currently covered by InfluenceMap).

InfluenceMap analysis indicates that National Grid has at least 2 memberships (American Gas Association (AGA), Business Council of New York State) 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), and at least 2 associations (Edison Electric Institute (EEI), Gas Infrastructure Europe) with active climate policy engagement partially misaligned with delivering the 1.5°C goal of the Paris Agreement (ranked B- to D+).

National Grid has therefore missed two cases of misalignment (AGA, Business Council of New York State) and one case of partial misalignment (EEI). The company provides a high-level description of AGA’s position on the role of gas, stating that the group advocates for the fuel’s “continued growth” in the energy transition. This assessment omits AGA’s strategic obstruction of US climate policy at the federal, state, and local levels, in which AGA advocates for fossil fuel infrastructure buildout while campaigning against building electrification measures, which in some cases has involved taking legal action against federal energy efficiency standards. AGA has also advocated for measures to preempt climate action, such as federal legislation to block regulation of gas stoves and state laws that prevent local governments from pursuing bans on gas in new construction.

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?

National Grid

National Grid has shown some evidence of action to address cases of misalignment between its industry associations and delivering the 1.5°C goal of the Paris Agreement. For each association that National Grid found to be partially misaligned, the company states that it has written the association to notify them that they are misaligned on the issue of the “role of natural gas” and that it will continue to engage with the association to “expand their support for low carbon fuels.”

However, National Grid does not appear to have shown evidence of action to address all 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: National Grid's Industry Association Memberships

The table below provides a ranking of National Grid'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.