EDP - Energias de Portugal SA

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive EDP – Energias de Portugal provides highly detailed and specific information about its climate-policy lobbying. It names a wide array of concrete legislative files it has engaged on, including the EU Green Deal and its “Fit for 55” package (revision of the EU ETS, Renewable Energy Directive, Energy Efficiency Directive, Alternative Fuels Infrastructure Regulation, Effort Sharing Regulation, Energy Taxation Directive, CO₂ standards for cars and vans, the Gas Package), the “Electricity Market Design” reform, the “Green Deal Industrial Plan,” the “REPowerEU Plan,” the Renovation Wave Strategy, the EU Smart Sector Integration Strategy and the EU Hydrogen Strategy. The company also sets out the channels it uses and whom it addresses: it “held several meetings with European and national policymakers,” prepared “a response to the public consultation on the revision of the electricity market design,” worked “with Eurelectric and EFET through the participation in working groups and the draft of position papers,” took part in “meetings with MEPs,” and spoke at “conferences and webinars at the European level,” clearly identifying EU institutions, MEPs and national authorities as targets. Finally, EDP spells out the changes it seeks, advocating, for example, for “a stable upward long-term trend” in the EU ETS price, “a renewable target of at least 32 %” in REDII, “a more ambitious rollout of charging points” under AFIR, inclusion of “glass and carbon fibers for wind production” in the Critical Raw Materials Act, principles such as “market cohesion between short- and long-term tools” in electricity-market reform, and enlargement of the ETS to cover buildings within the Renovation Wave. This combination of policy-specific, mechanism-specific and outcome-specific disclosures demonstrates a very high level of transparency around the company’s climate-related lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate EDP integrates its climate objectives into its policy engagement through what it describes as "dedicated structures in each geography that manage the relation with the supervisory bodies of the energy sector", which "ensure the overall alignment of EDP’s climate policy engagement activities with the corporate climate strategy". The company underscores that "this position has been stressed in all the fora and trade associations in which the company participates, as well as with all regulatory bodies EDP interacts with", and reports that "in 2022, EDP held several meetings with European and national policy makers within the scope of energy transition, decarbonization and climate change". These disclosures indicate a clear process for aligning both direct interactions with policymakers and contributions to trade association positions, yet EDP does not specify a named executive or governance body tasked with oversight of these activities, nor describe a formal review or audit mechanism to monitor and enforce alignment with its Paris Agreement–aligned goals. 2