Verbund AG

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Verbund AG offers a very detailed picture of its climate-policy lobbying. It names a wide range of concrete measures it has engaged on, including the Revision of the EU ETS Directive, the European Climate Law and wider Fit-for-55 package, the Renewable Energy Directive (RED3), the Austrian Renewable Energy Expansion Act (EAG), the EU Energy Taxation Directive, the EU Energy Efficiency Directive, the National Hydrogen Strategy Austria, the EU Sustainable Finance Regulation and taxonomy delegated acts, and the EU Gas Directive and Regulation, among others. The company also lays out how it lobbies and whom it targets: it participates in public consultations, drafts association position papers, hosts INSPIRE energy talks and other forums, publishes position papers on its website, co-chairs working groups in a stakeholder process run by the Austrian Ministry of Climate and Energy, holds direct meetings with “decision-makers in the European institutions,” and engages Austrian authorities and EU decision makers through alliances for the hydropower sector. Finally, Verbund is explicit about what it wants to achieve. It backs “earlier phase-out of free allocations in combination with a Carbon Border Adjustment Mechanism,” calls for “higher target ambition levels,” seeks “high renewable targets and acceleration of permitting processes,” advocates a “price-floor for the CO2-price in the EU-ETS” and extension of CO2 pricing to mobility and buildings, presses for a “regulatory environment favourable to the generation of renewable hydrogen,” argues that hydropower should be fully recognised in the EU taxonomy while criticising the inclusion of nuclear, and opposes “mandatory full ownership unbundling for hydrogen network operators as of 2030.” The breadth and specificity of these disclosures demonstrate a comprehensive level of transparency across the policies lobbied, the mechanisms employed, and the concrete outcomes sought. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Verbund states that its "strategy, policy and corporate responsibility departments" are "responsible for the strategy implementation as well as the consistency of political interest representation," indicating that these departments serve as the internal body overseeing whether lobbying is aligned with the company’s climate strategy. The company further confirms that it has "a public commitment…to conduct [its] engagement activities in line with the goals of the Paris Agreement," which demonstrates a formal policy intention to keep lobbying consistent with its climate commitments. However, the disclosure stops at this high-level description: it does not explain the specific monitoring steps, review frequency, escalation procedures, or criteria used to assess alignment, and it offers no information on how indirect lobbying via trade associations is managed or whether the board is involved. As a result, while there is evidence of a governance policy and named departmental oversight, the transparency and depth of the process remain limited. 2