Climate Policy Engagement Analysis
Climate Policy Engagement Overview: EDF takes broadly positive positions on climate change policy, with strategic engagement on a range of key climate policy streams, predominantly in the EU. Its engagement on the energy mix however contains a mix of positive and negative positions, with its subsidiary Edison advocating for a decarbonization pathway for heavy-duty vehicles that is not science-aligned.
Top-line Messaging on Climate Policy: EDF supports climate action in its top-line communications. The company supported climate neutrality by 2050 and the Paris Agreement to limit global temperature rise to 1.5°C above pre-industrial levels in its 2023 Universal Registration Document, published in April 2024. In its 2023 EU Affairs Report, published in September 2024, EDF supported the EU’s 2050 climate neutrality objective. In a January 2024 document setting out EDF’s policy proposals in the EU for 2024-29, the company supported the European Green Deal and the Fit for 55 package.
Engagement with Climate-Related Regulations: EDF engages broadly positively on climate regulations in the EU, with some exceptions relating to renewable hydrogen policy. In June 2023 comments to EU policymakers, the company supported measures that would increase the stringency of the EU Emissions Trading System (EU ETS) post-2030, including an "ambitious reduction of the cap" and defining a carbon budget up to 2050. It also stated top-line support for the EU Carbon Border Adjustment Mechanism while emphasizing certain concerns, including the inclusion of indirect emissions from hydrogen, in the same comments to EU policymakers.
In its 2023 EU Affairs Report, published in September 2024, EDF supported the revision of the EU's Energy Performance of Buildings Directive. The company supported the implementation of energy efficiency measures in the EU Fit for 55 package in its ‘EU priorities proposals for 2024-2029’ document shared with EU policymakers, in January 2024. I In March 2024 the company signed a joint letter in which it supported a target level of at least 90% in line with scientific recommendations. However, in a June 2023 comment to EU policymakers, EDF advocated for an EU 2040 GHG emissions reductions target of at least 80%.
The company supported the EU’s Delegated Act on renewable hydrogen under the Renewable Energy Directive revision in its 2023 EU Affairs Report, published in September 2024. However, in a March 2023 joint letter the company advocated for non-renewable, low-carbon hydrogen to be recognized in the revision, a position which is misaligned with the EU Commission’s original ambition. EDF supported measures to boost renewable energy in the EU Electricity Market Design reform but advocated for two-way contracts for difference to be voluntary only in a May 2023 comments to EU policymakers.
Positioning on Energy Transition: EDF takes broadly positive positions on transitioning the energy mix away from fossil fuels, with some exceptions. The company strongly supported the EU Green Deal Industrial Plan to accelerate the EU’s path to climate neutrality and supported phasing out fossil fuel subsidies, in a February 2023 letter to EU policymakers. EDF strongly supported the US Clean Hydrogen Tax Credit, which aids the development of hydrogen produced from renewables, in a July 2023 letter to the US federal government. However, while the company supported the electrification of transport, industry and the buildings sector in a January 2024 position paper shared with EU Policymakers, it did not clearly advocate for hydrogen to be produced from decarbonized sources. In the same report, it advocated for low-carbon hydrogen to be considered alongside renewable e-fuels in the EU’s ReFuelEU Aviation and FuelEU Maritime initiatives.
In its 2023 Annual Report, published in April 2024, EDF advocated against “discriminatory energy taxation” for low-carbon energy in the EU. The company supported zero emission corporate fleet targets for light, medium and heavy-duty vehicles in the EU in a July 2024 joint letter. In a July 2024 consultation response, accessed via FOI, EDF also appeared supportive of mandates and incentives for zero-emission vehicles in corporate fleets. However, EDF subsidiary Edison advocated for a policy pathway misaligned with the IPCC’s recommendations, calling for the EU to adopt a technology-neutral approach to decarbonizing heavy-duty vehicles over a complete transition to zero-emissions vehicles, in a May 2023 consultation response.
Industry Association Governance: In its 2023 Climate Policy Engagement Review', EDF disclosed a list of its industry association memberships, but omitted South African Wind Energy Association (SAWEA) and Clean Energy Council, providing some transparency around its indirect influence but not fully meeting investor expectations. Despite its membership of some associations which have supported EU climate policy, such as WindEurope and SolarPower Europe, EDF is also a member of Eurogas, and Confindustria (via its subsidiary Edison), which appear unsupportive of various strands of climate and energy policy. EDF stated in its review that it is partially aligned with the Edison Electric Institute and Hydrogen Europe on climate policy.
A detailed assessment of the company's corporate review on climate policy engagement can be found on InfluenceMap's CA100+ Investor Hub here.
Additional Note: EDF is a listed company with more than 50% of its shares owned by the government of France. State-owned enterprises likely retain channels of direct and private engagement with government officials that InfluenceMap is unable to assess, and therefore are not represented in EDF's engagement intensity metric.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q4 2024.