Ryanair Holdings PLC

Lobbying Transparency and Governance

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Direct Lobbying Transparency
Overall Assessment Comment Score
Comprehensive Ryanair provides a high level of transparency around its climate-related lobbying. It repeatedly identifies the exact legislative files it is engaging on, including the EU “Fit for 55” package (covering EU ETS reform, RefuelEU Aviation SAF blending mandates and the proposed kerosene tax), the “Single European Sky” air-traffic-management reform, the European Union’s Emissions Trading Scheme extension to long-haul flights, and national measures such as the Dutch Government’s aviation tax and the Danish “eco-tax.” The airline also discloses how it pursues these objectives: direct outreach by its Brussels Public Affairs team to “DG MOVE in the European Commission, Members of the European Parliament … and Member States’ Permanent Representations,” participation in European-Parliament hearings, collaboration with industry association A4E and NGO Transport & Environment, petitions that gathered more than two million signatures which were presented to the European Commission, and public events such as hosting “Europe’s Journey to Sustainable Aviation” inside the Parliament. Finally, Ryanair clearly states the concrete policy changes it is seeking, for example calling for “the exclusion of palm fatty acid distillates (PFAD) from the list of eligible feedstocks under ReFuelEU,” urging that “all flights departing the EU are covered” by ETS to prevent carbon leakage, pressing for legislation to “protect 100% of overflights during national ATC strikes,” supporting a mandatory 5 % SAF blend while opposing a double ETS/kerosene tax, and demanding that the Dutch and Danish passenger taxes be scrapped or redesigned to reward more efficient carriers. By naming the policies, the decision-makers it engages, the methods it uses and the specific outcomes it pursues, the company demonstrates comprehensive disclosure of its climate-policy lobbying activities. 4
Lobbying Governance
Overall Assessment Comment Score
Moderate Ryanair discloses a limited but identifiable process for governing how its policy engagement aligns with its climate strategy. It states that its Brussels-based Public Affairs team "engages with all relevant stakeholders in Brussels regarding the environment and sustainability" and that this team "receives updates of the Group climate change strategy directly from the Sustainability team who receive direction from the Board," indicating a mechanism by which lobbying positions are informed by climate objectives. Oversight is explicitly assigned: "The Board has ultimate oversight of our sustainability goals including climate-related issues" while the "Director of Sustainability reports to the Board quarterly," showing that a named executive and the Board review climate-related activities, including external engagement. The Sustainability Committee, chaired by the Director of Sustainability, "meets to monitor our climate-related impacts and upcoming environmental legislation," suggesting ongoing monitoring of advocacy contexts. The company also states that it has "a public commitment … to conduct [its] engagement activities in line with the goals of the Paris Agreement." However, the disclosure does not describe any formal review of trade-association positions, does not detail criteria for assessing alignment or corrective actions, and provides no dedicated climate-lobbying audit; therefore the governance framework appears moderate rather than comprehensive. 2