International Consolidated Airlines Group SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	International Consolidated Airlines Group (IAG) provides an extensive and highly specific account of its climate-policy lobbying. It names a wide range of concrete measures it engages on, including the EU “Fit for 55” package (covering the EU ETS revision, the RefuelEU SAF mandate, the Energy Taxation Directive and the Renewable Energy Directive III), the UK “Jet Zero Strategy”, “UK ETS reform”, the “Zero Carbon Humber” carbon-capture project, ICAO’s CORSIA scheme, and SAF-related provisions in the US Inflation Reduction Act, among others. The company also spells out how and where it tries to influence these files. It describes “one-to-one meetings with interested Members of Parliament”, hosting “an informal reception and a private dinner”, submitting “a written response to the Government’s Jet Zero Consultation”, holding “meetings with MEPs, Permanent Representation of Member States to the EU and European Commission officials”, attending UN and ICAO working groups, and working through trade associations such as A4E, IATA and the UK Emissions Trading Group. Targets are named at ministerial, parliamentary and civil-service level in the UK (DfT, BEIS, CCC), Spain, Ireland, EU institutions and ICAO, demonstrating clarity on both mechanisms and audiences. Equally explicit are the outcomes the Group seeks. It supports “a SAF mandate on intra-EU and UK flights”, calls for “a global SAF commitment covering all international flights through ICAO”, proposes “a price-stability mechanism such as contracts-for-difference” to accelerate SAF and hydrogen in the UK, asks that “EU/UK ETS funds [be] recycled back into innovation”, advocates the inclusion of “high-quality carbon offsets” and the strengthening of CORSIA’s baseline and reporting rules, and seeks UK government funding for carbon-capture infrastructure in Humber. It also opposes new flight taxes that it believes would weaken airlines’ capacity to invest in low-carbon technology. By naming the specific policies it lobbies, detailing the channels and decision-makers it targets, and articulating clear, measurable legislative and regulatory outcomes, IAG demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	International Consolidated Airlines Group (IAG) discloses a multi-layer governance structure that explicitly links climate-related lobbying to senior oversight and a defined review process, indicating strong governance. The company states that "internal governance ensures that wider stakeholder engagement on climate change is consistent with addressing IAG’s material issues and environmental goals," and this governance is coordinated through the Sustainability Steering Group, Sustainability Network and the Government Affairs team, demonstrating a process that covers direct engagement. Oversight responsibility is clearly assigned – the "Board Safety, Environment and Corporate Responsibility (SECR) Committee" meets at least quarterly to provide "dedicated oversight of the Group’s sustainability programme and alignment with strategic priorities," while the "IAG Chief Financial and Sustainability Officer…chairs the SSG and provides approval and direction of Group programmes," and the CEO updates the Board on progress, showing named senior accountability. For indirect lobbying, IAG describes an active alignment mechanism: "If the climate-related positions of trade associations are deemed to be substantially weaker or inconsistent with this stance, IAG representatives take roles on task forces and working groups and respond to consultations to communicate our position and constructively move to alignment," and lists concrete actions across ten associations. Direct lobbying is coordinated so that "The IAG Government Affairs team coordinates these efforts for a consistent approach," and the company supports its positions with studies and participation in policy fora such as A4E, ICAO and the EU-US Joint Committee. These disclosures show a defined process, responsible committees/individuals and evidence that the company works to align both its direct and indirect lobbying with its climate strategy. However, we found no evidence of a standalone public lobbying‐alignment audit or third-party review, and the company does not detail measurable criteria or a regular schedule for assessing each trade association’s climate stance, which would further strengthen transparency. Overall, the disclosure indicates strong but not comprehensive climate-lobbying governance.	3