Banco Bilbao Vizcaya Argentaria SA

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Direct Lobbying Transparency

Overall Assessment	Comment	Score
Comprehensive	BBVA provides a high level of transparency on its climate-related public-policy engagement. It names a range of identifiable measures it has worked on, including the Corporate Sustainability Reporting Directive proposal, the European Banking Authority’s draft Implementing Technical Standards on Pillar-3 ESG risk disclosures, the Corporate Sustainability Due Diligence Directive, the EU Taxonomy Article 8 delegated act, and consultations run by the IFRS Foundation and the Basel Committee, as well as its work through the Spanish Green Growth Group on the EU 2030 Climate & Energy framework. BBVA also explains how it seeks to influence these files, describing “regular engagement with the TEG & European institutions, such as the European Commission and the European Parliament,” participation in industry associations such as the European Banking Federation and AFME, direct “meetings with European institutions’ representatives and with Central Banks,” written responses to public consultations, position papers and workshops, and its role as a founding member of the Spanish Green Growth Group that collaborates with Spain’s Ministry of Environment. Finally, the bank is explicit about the policy outcomes it pursues: it supports adoption of the CSRD and the “double materiality” principle in global reporting standards, backs the EBA Pillar-3 package while advocating a practicable implementation timetable, wants comparable KPIs such as the Green Asset Ratio, encourages a “well-designed carbon price,” and promotes an efficient roadmap for a low-carbon economy aligned with the EU’s 2030 goals. By clearly identifying the policies, the channels it uses, the public bodies it targets, and the specific changes it advocates, BBVA demonstrates comprehensive disclosure of its climate-policy lobbying activities.	4

Lobbying Governance

Overall Assessment	Comment	Score
Strong	BBVA discloses a structured process that links its climate-related advocacy to the bank’s sustainability strategy and assigns clear decision-making authority. The bank states that it has “a robust internal process to ensure that the information provided to the market associations is consistent with BBVA’s Sustainability General Policy, in line with the bank’s strategy and its priorities,” and adds that “the areas in charge of regulatory and non-regulatory advocacy on sustainability have procedures to ensure that the positions they defend in different fora are in line with our net zero ambition.” Alignment is governed through a dedicated “Working Group (WG) which meets on a monthly basis” and undertakes “technical assessment of new sustainability commitments … and proposals are made to be submitted to the Head of the Global Sustainability Area for decision on adhesion and disengagement of commitments.” This mechanism covers both direct engagement (“BBVA would express its views individually”) and indirect engagement via trade bodies (“In general we make sure that the position of these associations are in line with our own positions”). Accountability is anchored in a named executive: “These responsibilities related to sustainability advocacy are part of the Duties and Authority of the Head of the Global Sustainability Area,” who in turn reports to the CEO and Chair, while board-level committees receive periodic sustainability reports. Together these disclosures indicate strong governance for aligning climate lobbying; however, the company does not disclose any public, stand-alone lobbying alignment audit or describe a formal process for publishing the results of its trade-association reviews, so transparency on outcomes remains limited.	3