Bayerische Motoren Werke AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	BMW Group offers highly detailed disclosure of its climate-related lobbying. It names multiple identifiable policy files across key markets, including the EU’s “Fit for 55” package (revision of CO2 fleet standards, the Alternative Fuels Infrastructure Regulation, Energy Taxation and Renewable Energy Directives), the German Federal Government’s National Development Plan for Electric Mobility and accompanying “electro mobility law,” CO₂-based vehicle-taxation schemes in “20 out of 28 EU member states… South Africa or Singapore,” the U.S. “California Framework Agreement” and EPA/NHTSA greenhouse-gas standards for model years 2027-2032, and China’s New Energy Vehicle mandate, fuel-consumption targets and “China 6” emission standard. The company also describes the channels it uses to influence those measures. It cites direct meetings with “EU Commissioners regarding the ‘Fit for 55’ package,” a “constructive working-level dialogue” with the EPA, CARB and NHTSA, participation in government advisory bodies such as the German Government’s National Platform Mobility, and ongoing representation through offices in Berlin, Brussels, Beijing, London and Washington DC. Indirectly, it works through industry associations like ACEA, VDA and the Alliance for Automotive Innovation, submits position papers, co-chairs working groups and takes part in EU “TRILOGUE negotiations,” together mapping out a clear picture of both mechanisms and targets. Finally, BMW is explicit about what it wants to achieve. It calls for “binding and measurable targets” for public charging infrastructure, urges governments to place “a price tag on CO₂ use-phase emissions,” supports “purchase and tax incentives for electrified vehicles,” seeks the continuation of the German “Umweltbonus” and U.S. federal tax credits, backs a 3.7 % annual fleet-emission reduction in the United States, and presses for fast-charging and green-hydrogen incentives in China. By specifying concrete legislative aims and the reasoning behind them, BMW Group demonstrates a comprehensive level of transparency about its climate-policy lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Comprehensive	BMW Group demonstrates a comprehensive climate lobbying governance process that integrates transparency, accountability, and alignment with its climate-related goals. The company explicitly states that "all of our direct and indirect activities that influence policy are CONSISTENT with our overall climate change strategy," ensuring alignment across its lobbying efforts. BMW Group has established a centralized coordination mechanism in Munich, where positions on global legislative issues are developed with input from various departments, including those responsible for sustainability and environmental protection. Proposals concerning climate-relevant issues are aligned between the Vice President of Sustainability and the Vice President for Government and External Affairs before being presented to the Strategy & Structure Circle, which prepares decisions for the Board of Management. This governance structure ensures oversight at the highest levels of the organization. Furthermore, BMW actively engages with trade associations and industry bodies, stating that "if we notice our positions diverging, we raise the issue with the association concerned and discuss it to improve alignment." The company also advocates for the targets of the Paris Climate Agreement within associations and organizations it is a member of, demonstrating proactive alignment efforts. BMW Group publishes a "Klima-Engagement Bericht" that provides stakeholders with an overview of its climate-related lobbying positions and activities, further enhancing transparency. Additionally, the company is listed in multiple transparency registers, including the EU Transparency Register and German Bundestag Lobby Register, providing detailed disclosures about its lobbying activities, association memberships, and financial expenditures. This indicates a robust governance framework that encompasses direct and indirect lobbying activities, with clear monitoring mechanisms, accountability structures, and public reporting in place.	4