Telefonica SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Strong	Telefónica provides a solid level of transparency on its climate-related lobbying. It identifies two concrete policy files it has engaged on – the work of the EU Radio Spectrum Policy Group concerning spectrum policies and the EU’s Delegated Act on Climate Change within the Taxonomy for Sustainable Finance – and explains why each is relevant to climate mitigation. The company also describes several distinct mechanisms and the targets of those efforts: it contributed directly to consultations within the RSPG, released a formal position paper, and supplied scientific evidence and internal reports to the EU officials drafting the Taxonomy rules, clearly singling out the RSPG and the European Commission policymakers responsible for the Delegated Act. Finally, Telefónica states the outcomes it is pursuing, such as avoiding spectrum policies that would raise energy use or slow digitalisation and securing the classification of telecommunication networks as green investments within the EU Taxonomy so their decarbonisation potential is recognised. This combination of named policies, specified lobbying channels and clearly articulated objectives reflects strong, though not yet comprehensive, disclosure of its climate-policy lobbying activities.	3

Lobbying Governance

Overall Assessment	Comment	Score
Limited	Telefonica SA has made a public commitment to align its engagement activities with climate policy, stating that it has a “public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement”. This indicates an acknowledged intent to integrate climate considerations into its lobbying. However, we found no evidence of any internal review processes, oversight bodies, or named individuals responsible for monitoring or ensuring this alignment, and no mechanisms are described for managing or assessing its direct or indirect lobbying activities, which limits the transparency and accountability of its lobbying governance.	1