AIB Group PLC

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	AIB Group Plc provides a solid level of transparency on the climate-related public-policy issues it engages on. It names several identifiable laws and regulatory initiatives it has addressed, including consultations on proposed EU sustainable-finance regulation and the EU’s Renewed Sustainable Finance Strategy, compliance reporting under Ireland’s National Energy Efficiency Action Plan and the associated 2009 Energy End-Use Efficiency Regulations, and its submission of an action plan responding to the UK Prudential Regulatory Authority’s Policy Statement PS11/19 and Supervisory Statement SS3/19 on climate-related financial risk. The bank also discloses the channels it uses: direct written submissions to EU consultations, indirect advocacy “through the Banking and Payments Federation of Ireland” and by “influencing European Banking Federation responses,” as well as delivering an action plan to the UK PRA and filing reports with the Sustainable Energy Authority of Ireland. It acknowledges its registration on the Irish lobbying register, stating, “Lobbying activity in Ireland is recorded on the lobbying register. AIB is registered as a lobbyist, albeit we do not actively lobby,” while still describing the trade-association and consultation routes it employs. With respect to objectives, the disclosures focus mainly on meeting regulatory requirements—such as achieving a 33 % energy-saving target under NEEAP, reducing CO₂e emissions by 30 %, and embedding climate-risk management in line with PRA expectations—rather than advocating for specific new policy changes, so the desired outcomes remain broadly articulated. Overall, the company is open about the policies it touches and the mechanisms it uses to influence them, but it is less explicit about the precise legislative or regulatory changes it wants regulators to adopt.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	AIB Group PLC provides only limited disclosure of its lobbying governance, referencing an internal policy framework without describing oversight or alignment mechanisms specific to climate lobbying. For example, the company states that “our approach to lobbying is covered in our Conflicts of Interest policy and Financial Crime policy (which are publicly available), and our internal Lobbying policy,” and notes that it is “registered as a lobbyist, albeit we do not actively lobby.” It also confirms a public commitment to align its engagement with climate goals, answering “Yes” to having “a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement.” However, the company does not disclose who is responsible for reviewing or approving its lobbying activities, how it monitors or manages alignment with its climate policy, or any mechanisms for assessing or exiting industry associations whose positions may conflict. We found no evidence of a named individual, committee, or review process overseeing the alignment of its direct or indirect lobbying with its climate objectives.	1