Deutsche Lufthansa AG

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	Deutsche Lufthansa AG offers an extensive, highly specific picture of its climate-policy lobbying. The company names a wide array of concrete measures it works on, including the EU “Fit for 55” package (covering reform of the EU-ETS, the ReFuelEU Aviation SAF blending mandate and the Energy Taxation Directive), the global CORSIA scheme, the “Single European Sky” air-space reform, the ICAO aircraft CO₂ standard, revisions to the EU Taxonomy screening criteria for aviation, the German Government’s PtL Roadmap and quota, and several other named initiatives. Its disclosures also spell out how it tries to influence these files: direct conversations with “national, EU and international policymakers,” formal responses to EU consultations (e.g. the TSC draft), “Policy Briefs” sent several times a year to Members of Parliament and ministries, participation in EU trilogue negotiations, joint press conferences with airports, submission of position papers through trade bodies such as IATA, A4E and BDL, and work inside technical fora like the ICAO Fuel Task Group and SESAR. Target institutions are identified throughout, including the “EU Parliament and Council,” “DG Move and DG Fisma,” German federal ministries BMWK and BMDV, and ICAO working-group representatives, and the company records itself in both the EU Transparency Register and the German Bundestag register. Lufthansa is equally explicit about what it wants to achieve: it calls for a “competition-neutral SAF blending mandate,” proposes a “SAF levy based on travel destination” and the use of German aviation-tax revenues to fund SAF, urges amendments to the EU-ETS and ReFuelEU rules to “avoid carbon leakage,” supports a 2 % PtL quota for kerosene by 2030, seeks inclusion of the Single European Sky in the EU Green Deal to save up to “1 to 1.8 million t CO₂ per year,” and presses for a single global CO₂ certification standard for aircraft. By detailing the specific policies addressed, the concrete channels and decision-makers approached, and the precise regulatory outcomes it pursues, the company demonstrates a comprehensive level of transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	Deutsche Lufthansa AG demonstrates a moderate level of governance in its lobbying activities, with some processes and oversight mechanisms in place. The Corporate International Relations and Government Affairs department, which reports directly to the Chair of the Executive Board, is responsible for representing the political interests of the Lufthansa Group, indicating a clear organizational structure for lobbying oversight. The Group Policy Committee (GPC), chaired by the Chairman of the Executive Board, discusses politically significant issues, including those relevant to sustainability, and prepares decisions, showing some integration of sustainability into political engagement. Furthermore, the company actively participates in industry associations such as IATA and A4E, and engages in drafting position papers and consultations on environmentally relevant issues, which suggests efforts to align indirect lobbying with broader goals. However, while Lufthansa has established committees like the Emissions Management Committee and the Sustainability Circle to address climate-related topics, there is limited evidence of a specific process to ensure that lobbying activities are consistently aligned with climate goals or the Paris Agreement. The company does disclose its lobbying activities in the EU Transparency Register and publishes a Policy Brief accessible to the public, which enhances transparency. Despite these measures, there is no explicit mention of a detailed review or audit process for climate lobbying alignment, nor evidence of actions taken to address misalignment in trade associations. This indicates that while Lufthansa has some governance mechanisms, the processes for monitoring and enforcing alignment with climate-related lobbying remain underdeveloped.	2