TotalEnergies Disclosure Scorecard

Detailed assessment of TotalEnergies's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of TotalEnergies'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 TotalEnergies, 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 TotalEnergies'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 TotalEnergies'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 TotalEnergies'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
May 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 TotalEnergies'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)?

TotalEnergies

TotalEnergies has published a largely complete account of its positions and engagement activities on specific climate-related policies, but appears to exclude 1 material evidence of direct climate policy engagement identified by InfluenceMap's database.

TotalEnergies' corporate website includes advocacy updates on specific government policy consultations in France, the EU, and the US, with links to public submissions for most of these, including its October 2024 consultation response to the EU Energy Security Fitness Check and August 2024 comments on the IRA Clean Electricty Tax Credits in the US.

The company excluded only 1 engagement: April 2025 comments on the EU 2030 storage objectives for oil and producers' contributions.

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)?

TotalEnergies

TotalEnergies has disclosed a list of its industry association memberships, but excludes 6 industry associations which are actively engaged on climate policy, such as Équilibre des Énergies, the Natural Gas Supply Association, Wind Europe, European Business Aviation Association, Brazilian Association of Wind Energy and New Technologies (ABEEólica) and Brazilian Business Council for Sustainable Development (CEBDS).

The company also discloses its membership to Instituto Brasileiro de Petróleo e Gás (IBP) and states it does not hold board or executive committee level membership, however IBP lists TotalEnergies as a member of several committees and its board on its website. The company's disclosure on its industry associations does not include any positions or references to climate policies. The disclosure has not been updated since May 2024.

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 TotalEnergies'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 TotalEnergies'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?

TotalEnergies

TotalEnergies has published reviews of its industry associations in 2019, 2021 and now 2024 (covering calendar year 2023). While the company states that its entities record memberships to industry associations every two years, it has not committed to publishing a publicly available review of its memberships on an annual basis.

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?

TotalEnergies

TotalEnergies has disclosed a methodology for assessing its industry association’s top-line policy statements, rather than the alignment of their detailed climate advocacy activities against the 1.5°C goal of the Paris agreement. The company did disclose criteria for findings of alignment, however it did not provide detailed explanations behind each assessment.

TotalEnergies has disclosed a methodology for assessing alignment based on six key principles from its own principles on climate change. These included entities' positions on climate change science; the Paris Agreement; carbon pricing mechanisms; the development of renewable energies; the role of natural gas; and carbon offsetting mechanisms, in particular natural climate solutions. However, TotalEnergies has only assessed top-line support for the Paris Agreement, rather than a detailed analysis of its associations’ climate policy engagement activities against science-based benchmarks for delivering the 1.5°C goal of the Paris Agreement. The company has also not assessed alignment of its own policy positions against the 1.5°C goal of the Paris Agreement, therefore alignment with its positions may not indicate positive advocacy.

The company did provide a framework for what constitutes as ‘Aligned’, ‘Partially aligned’ and ‘Not aligned’ for its industry associations. To be ‘Aligned’, an association's positions will be aligned with TotalEnergies across all assessment criteria; to be ‘Partially aligned’, an association’s positions on one or more criteria will be partially aligned; and to be ‘Not aligned’, positions on at least one principle are misaligned. TotalEnergies also states that for the first two principles, the absence of a public position constitutes as partial alignment, however absence of a public position for the other principles means they are not factored into the assessment.

Despite this, TotalEnergies does not provide a clear and detailed explanation behind each industry association evaluation. The company provides a limited explanation for two associations that it found to be ‘Partially aligned’, but did not include explanations behind the other assessments.

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?

TotalEnergies

TotalEnergies has disclosed a framework for addressing potential cases of misalignment, with some escalation strategies under its 'Introduction' section. The company states it conducts regular assessments of the public positions of the industry associations to which it belongs, enabling the company to reaffirm its stance and simultaneously advocate for changes if positions are misaligned. It also stated that it prioritizes promoting, supporting and defending its own positions within these bodies and if there are divergences, the company will work diligently to shift positions, and in extreme cases, propose withdrawal if the organization's positions continue to contradict its own.

However, there are no deadlines attached to this framework for industry associations that do not reform misaligned climate policy engagement 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)?

TotalEnergies

TotalEnergies does not appear to have undertaken a review of the alignment of its climate policy engagement activities in this document. 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. For example, in a meeting with the EU Director-General for Energy in May 2023, TotalEnergies appeared to advocate against the EU Methane Regulation for the energy sector; by labelling the rules "over-prescriptive" and the company did not appear to support the inclusion of imports. The company also appeared to advocate for an increase in the cap on Annex IX B feedstocks; Annex IX is an approved list of sustainable feedstocks under RED in Feedback on delegated act in December 2022.

At time of this assessment, TotalEnergies' InfluenceMap organization score was 59%, indicating partial misalignment between the Paris Agreement and the company’s detailed climate policy engagement. Please see TotalEnergies’ 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?

TotalEnergies

TotalEnergies has not undertaken 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?

TotalEnergies

TotalEnergies assessed 116 associations in its review, finding 114 associations to be ‘Aligned’ and 2 associations to be ‘Partially aligned’. These were the Texas Oil and Gas Association (TXOGA) and International Air Transport Association (IATA). TotalEnergies found no industry associations to be misaligned, but excluded key associations actively engaged on climate policy. These include the EU Chamber of Commerce in China and Équilibre des Énergies.

InfluenceMap analysis indicates that the company has 8 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). These include TXOGA and IATA, which TotalEnergies found to be partially aligned, as well as BusinessEurope. InfluenceMap analysis also indicates that TotalEnergies has a further 15 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 the International Association of Oil and Gas Producers (IOGP) which TotalEnergies found to be partially aligned. I See Appendix A below for further details on the company’s industry association memberships.

As TotalEnergies has only identified partial misalignment with TXOGA and IATA, the company has not identified the remaining 21 above 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.

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?

TotalEnergies

TotalEnergies showed some evidence of action to address specific misalignments in its May 2024 review, however it only covered actions to address misalignments from its previous review in 2021. It is unclear if the company has taken action to address misalignments over the last 2 years.

However, TotalEnergies 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: TotalEnergies's Industry Association Memberships

The table below provides a ranking of TotalEnergies'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
Solar Energy Industries Association (SEIA)A+Aligned
Advanced Energy United (AEU)AAligned
American Clean Power Association (formerly AWEA)B+Aligned
Brazilian Business Council for Sustainable Development (CEBDS)B+Aligned
SolarPower EuropeB+Aligned
WindEuropeB+Aligned
Business Leadership South AfricaB-Partially Aligned
Brazilian Association of Wind Energy and New Technologies (ABEEólica)B-Partially Aligned
European Round Table for Industry (ERT)C+Partially Aligned
European Union Chamber of Commerce in ChinaC+Partially Aligned
Offshore Energies UK (OEUK) (Formerly OGUK)C+Partially Aligned
Hydrogen CouncilCPartially Aligned
Équilibre des ÉnergiesCPartially Aligned
Bioenergy EuropeCPartially Aligned
International Emissions Trading Association (IETA)CPartially Aligned
Federation of Indian Petroleum Industry (FIPI)CPartially Aligned
Hydrogen EuropeCPartially Aligned
International Petroleum Industry Environmental Conservation Association (Ipieca)CPartially Aligned
Fuels Industry Association of South Africa (formerly SAPIA)CPartially Aligned
Japan Hydrogen Association (JH2A)C-Partially Aligned
European Chemical Industry Council (Cefic)C-Partially Aligned
International Gas UnionC-Partially Aligned
French Association of Large Companies (AFEP)C-Partially Aligned
PlasticsEuropeD+Partially Aligned
EurogasD+Partially Aligned
Carbon Capture and Storage Association (CCSA)D+Partially Aligned
Energy Council of South AfricaD+Partially Aligned
Mouvement des Entreprises de France (MEDEF)D+Partially Aligned
Asociación Mexicana de Empresas de Hidrocarburos (AMEXHI)D+Partially Aligned
International Association of Oil and Gas Producers (IOGP)DMisaligned
American Chemistry Council (ACC)DMisaligned
KazEnergyDMisaligned
FuelsEuropeDMisaligned
European Business Aviation AssociationDMisaligned
International Air Transport Association (IATA)DMisaligned
Brazilian Institute of Oil and Gas (IBP)DMisaligned
Confederation of Italian Industry (Confindustria)D-Misaligned
BusinessEuropeD-Misaligned
Brazilian Association of Thermoelectric Generators (ABRAGET)D-Misaligned
Natural & bio Gas Vehicle Association (NGVA Europe)D-Misaligned
Korea Gas UnionE+Misaligned
Natural Gas Supply Association (NGSA)EMisaligned
Texas Oil & Gas Association (TXOGA)FMisaligned