Endesa SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Endesa provides a highly detailed picture of its climate-policy advocacy. It names a broad suite of specific measures it engages on, including the reform of the EU Emissions Trading System, the Renewable Energy Directive 2018/2001/EU and its later revisions, the Energy Efficiency Directive, the Effort Sharing Regulation, the EU Methane Strategy, the EU Taxonomy Regulation, and elements of the “Clean Energy for all Europeans” and “Fit for 55” packages. The company also explains how it presses its views: it records direct meetings with “Commissioners, Members of their Cabinet and EC Directors-General,” says it “provid[es] input to the European Commission through the official public channels,” publishes its submissions to EU consultations, and pursues indirect influence “through the trade associations in which it participates (among which Eurelectric).” Targets are clearly identified as the European Commission, Parliament and Council, and Endesa lists the associations and think-tanks through which it works and notes its registration in the EU Transparency Register. Equally explicit are the policy outcomes it seeks. For the ETS it “supports the reform … to be strengthened” by increasing the linear-reduction factor, adjusting the market-stability reserve and introducing a Carbon Border Adjustment Mechanism; for the RED it “welcomes the Commission’s initiative to revise” the Directive and argues for higher renewable targets and streamlined permitting; for energy efficiency it backs the binding 9 % additional reduction by 2030; it also advocates a “100 g CO2e/kWh life-cycle intensity limit” under the Taxonomy and calls for methane rules that “tackle energy-related methane emissions from a structural point of view.” By disclosing the concrete policies, the methods and forums of engagement, and the precise changes it wants to see, Endesa demonstrates a very high level of transparency around its climate-related lobbying.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Endesa has established a systematic verification process for aligning its indirect lobbying through industry associations with its climate change strategy, but it does not disclose governance details for its direct advocacy or name who oversees these efforts. In particular, the company “systematically verifies the consistency of the associations’ positions with the climate policies,” and explains that this “verification process is carried out in two stages: (i) before joining the association, through an in-depth analysis of the body’s by-laws; (ii) after joining the association, by actively contributing to its work and/or taking positions of responsibility within it or promoting the Endesa’s position within working groups.” The firm also affirms a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement,” to which it responds “Yes,” and ensures associations “operate in full compliance with the objectives of the Paris Agreement and the decarbonisation roadmap established by the company,” indicating clear indirect lobbying alignment. However, the company does not disclose a specific individual or formal body responsible for overseeing the alignment of its lobbying activities, and we found no evidence of a process governing its direct lobbying efforts.	2