A2A SpA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	A2A SpA provides an unusually detailed picture of its climate-policy lobbying. It lists multiple identifiable pieces of legislation it has worked on, including the “Amendments for directive (Fit for 55 package),” the “Recast of the Energy Performance of Buildings Directive,” the “Recast of the Energy Efficiency Directive,” Italy’s “Legislative Decree 99/2021,” the ministerial decrees on fast-charging infrastructure and on district-heating support schemes, the EU “Renewable Energy Directive,” and national measures such as “ARERA Resolution 2/2022/A.” For each file, the company explains how it intervened—e.g. being “involved in the consultation procedure,” “presented improvement proposals,” or “focused on amending the text proposed by the Commission”—and names the policymaking body addressed, such as the European Commission, ARERA, or the Italian Minister for Environment and Energy Security. The disclosure also spells out the concrete results it is seeking, supporting “the introduction of a new ETS mechanism for the residential and transport sectors” while asking for “the exclusion from this system of WTE plants powered by urban waste connected to district heating networks,” urging that “buildings directly connected to efficient district-heating systems” be treated as zero-emission, backing “the increase in the energy-efficiency targets to 2030,” proposing to “eliminate some constraints regarding the production of green hydrogen,” and requesting “to associate one or more SDG indicators with each strategic objective” in future regulation. By naming the exact laws, the governmental counterparts, and the specific changes it advocates—while consistently stating alignment with the Paris Agreement—A2A demonstrates comprehensive transparency around its climate-related lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Moderate	A2A SpA affirms a public commitment to conduct its engagement activities “in line with the goals of the Paris Agreement” and describes a clear regulatory risk monitoring and management policy to align external engagement with its climate commitments, including ongoing “dialogue with institutions such as the Regulatory Authority for Energy, Networks and the Environment (ARERA), the Antitrust Authority (AGCM) and technical bodies” and “active participation in trade associations” like Eurelectric and Cedec to stay informed of EU policy developments. It also holds “specific moments of internal discussion ... across the various Departments (Regulatory Breakfast)” and relies on its “Regulatory Affairs and Competition Structure” to drive advocacy on issues from the hydrogen supply chain to waste‐management rules. However, the company does not disclose a specific individual or formal board committee responsible for reviewing or approving its lobbying alignment, nor does it provide a dedicated climate‐lobbying audit or report, suggesting that while both direct and indirect lobbying processes are in place, oversight mechanisms and transparency could be more explicitly defined.	2