AerCap Holdings NV

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	AerCap gives a largely transparent picture of what climate-related policies it tries to influence and how it goes about doing so. It names several identifiable measures, including the EU’s “ReFuelEU” sustainable aviation fuel mandate, the “EU Taxonomy for Aviation” climate-change-mitigation criteria and the U.S. “Inflation Reduction Act” provisions that provide tax credits for SAF, as well as earlier work on pandemic-related aviation policy. The company also sets out its channels of influence in detail: its Government Affairs & Sustainability team in Brussels holds “regular and coordinated dialogue with senior policymakers in the European Union,” it maintains “regular technical engagement” with the U.S. FAA and the EU’s EASA, it conducts “regular direct interactions with DG FISMA and DG MOVE,” and any contact with Irish Designated Public Officials must receive internal sign-off, with the resulting activity logged on the Irish lobbying register. However, while AerCap explains that it wants to “support the scale-up of Sustainable Aviation Fuel” and help airlines “transition to lower-carbon economies,” it stops short of stating what specific legislative amendments, SAF volume targets or other concrete outcomes it is pressing for. As a result, its disclosures are comprehensive on the policies addressed and the mechanisms and targets used, but provide only general indications of the results it seeks to achieve.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	AerCap requires “prior approval is required for any intended communication with a DPO that potentially constitutes lobbying activity” and discloses all such interactions in the central Irish lobbying register, noting that “all lobbying activities were properly disclosed” in its statutory filings. The company has established a “dedicated government affairs function based in Brussels, focused on legislative developments and strategic matters … focusing on aircraft leasing, air transport, aviation sustainability and ESG” and reports that its “Board-level ESG Committee provides oversight of ESG risks and opportunities at the highest level.” However, we found no evidence of a policy or procedure designed to align the company’s lobbying specifically with climate or Paris-aligned objectives—indeed, the company states “No, and we do not plan to have one in the next two years” with respect to a Paris-Agreement position—and it does not identify any formal climate-lobbying review process or a named individual tasked with ensuring climate-related lobbying alignment beyond its general compliance and ESG oversight mechanisms.	1