Vistra Corp Disclosure Scorecard

Detailed assessment of Vistra Corp's climate policy engagement disclosure

Date of Assessment - August 2025

Overview

This scorecard provides a detailed breakdown of InfluenceMap's assessment of Vistra 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 Vistra 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 Vistra 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 Vistra 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 Vistra 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
N/ANo Review Published

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 Vistra 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)?

Vistra Corp

Vistra's disclosure of its positions and engagement activities on climate policies is limited to top-line climate statements in reports published over a year ago, specifically its 2023 Climate Report from October 2023 and its 2023 Sustainability Report from July 2024.

The company referenced several US policies (Inflation Reduction Act, the federal power plant carbon standards) without disclosing any positions or engagement activities. As a result, Vistra appears to have excluded key instances of engagement with specific climate proposals.

For example, the company signed a January 2025 letter to the incoming Trump administration that advocated for the review or repeal of a range of power sector emissions standards, following its participation in an August 2024 legal challenge of the power plant carbon standards via the ad hoc coalition Electric Generators for a Sensible Transition.

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)?

Vistra Corp

Vistra has disclosed a list of its industry association memberships in disclosures published over a year ago, but it excluded its membership to the Solar Energy Industries Association. Vistra does not appear to have disclosed an account of its industry associations' positions and engagement activities. Vistra has therefore excluded key instances of engagement with specific climate-related policies by its industry associations.

For example, Business Roundtable advocated for the passage of the One Big Beautiful Bill in May 2025 and submitted February 2024 comments that advocated for weaker implementation of the Inflation Reduction Act's clean hydrogen tax credit. 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.

Key

Yes, meets criteria

Partial, meets some criteria

No, does not meet criteria

Appendix A: Vistra Corp's Industry Association Memberships

The table below provides a ranking of Vistra 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
Solar Energy Industries Association (SEIA)A+Aligned
Business RoundtableDMisaligned