Climate Policy Engagement Analysis
Climate Policy Engagement Overview: Shell appears to be strategically engaged on climate change policies, showing top-line support for emission reduction targets, carbon pricing and for the decarbonization of transport. However, it continues to advocate for policies to advance fossil fuel production and consumption, particularly fossil gas. It also retains membership to industry associations that engage negatively on climate change policies.
Top-line Messaging on Climate Policy: Shell appears to support climate action through its top-line messaging on climate policy. In its 2024 Sustainability and Lobbying Report, published in May 2025, the company stated support for GHG emissions reductions in line with the 1.5°C target and the Paris Agreement, while also calling for countries to submit more ambitious nationally determined contributions. It also supported the need for policies to achieve global climate goals.
Engagement with Climate-Related Regulations: Shell appears to have a mixture of both positive and negative engagement with climate-related regulations. In September 2024, Shell released a position paper on the company’s views on the 2024-29 EU cycle, in which the company supported the need for climate regulation, including an expansion of the EU's carbon border adjustment mechanism (CBAM) to cover exports and additional sectors. However, its recent engagement on emissions trading policy appears to be less supportive. For example, Shell submitted several comments across 2023–2024 on the amendments to the California Cap-and-Trade Regulation, in which the company favored the less ambitious cap trajectory scenario and appeared to advocate against significant changes, such as modifications to the price ceiling or allowance banking, that would increase the stringency of the program. Although the company had communicated support for the EU Emissions Trading Scheme (ETS) reforms in an earlier July 2022 position paper.
Shell’s engagement with renewable energy legislation also appears to be mixed. In Shell’s 2024 Sustainability and Lobbying Report, published in May 2025, Shell stated that it supported renewable hydrogen rules under the EU's Renewable Energy Directive. However, in October 2024 comments on the EU Hydrogen and Gas Decarbonization Package Delegated Act on the definition of low-carbon hydrogen, it appeared to not fully support the proposed rules, specifically not supporting the proposal for hourly matching or additionality. Furthermore, Shell discloses in its 2024 Climate and Energy Lobbying report that it is supportive of policy that increases electrification such as the EU Electricity Market Design reform, although the company appeared to support the policy with exceptions in its February 2023 comments on the policy.
Shell is frequently supportive of sustainable aviation fuel mandates in its own communications, however its engagement with specific regulation on the subject is less supportive. In its 2024 Climate and Energy Lobbying report, it stated support for sustainable aviation fuel (SAF) mandates. However, in June 2023 comments to UK policymakers, it appeared to support a UK SAF mandate, but with major exceptions, such as not supporting feedstock restrictions for hydrogen-based fuels. In the same comments, the company also opposed stringent sustainability criteria for SAF's by opposing a cap on Hydro treated Esters and Fatty Acids (HEFA) fuels and advocating for first generation ethanol fuels to be eligible.
On the need for GHG emissions regulation, Shell’s position appears to be mixed. In April 2025 comments, Shell appeared to not support the proposed oil and gas producers’ contributions to the EU’s 2030 carbon storage objective, stating that the proposed timelines are ‘highly challenging’ and did not support the proposed reporting requirements. In February 2024 comments to policymakers in Canada, Shell also appeared to not support the proposed methane regulation for the oil and gas sector. However, Shell states support for methane emissions regulation is its own communications, such as in its September 2024 position paper and in February 2023 comments, it appeared to support the US EPA's Methane Regulation Supplementary Proposal, although its submission does not include comments on key policy elements.
Positioning on Energy Transition: Shell appears to support a long-term role for fossil fuels in its global advocacy, particularly around the need for new supplies of liquified natural gas (LNG). In the company’s 2024 Climate and Energy Transition Lobbying Report, published May 2025, it disclosed its advocacy in support of policies that support the continued investments in fossil gas infrastructure and promoted the role of LNG in the EU, Australia, Malaysia, Brazil, India, Egypt, Canada and Nigeria. In July 2024 comments to policymakers in Brazil, Shell advocated for new oil and gas licenses for areas that have not yet been developed for fossil fuel extraction.
Shell also appears to be unsupportive of policy that excludes hydrogen produced from fossil fuels. In its 2024 Climate Policy Positions, it stated that it supports policy to promote decarbonized hydrogen development and uptake. However, it opposed the proposed US Clean Hydrogen Tax credit in February 2024 comments. Similarly, in Canada, Shell advocated for the removal of the requirement for lifecycle hydrogen emissions to be considered in Canada's Clean Electricity Regulations in November 2023 comments.
In Shell’s 2024 Sustainability and Lobbying Report, it stated support for policy measures to decarbonize road transport in several countries, while continuing to advocate for the use of fossil fuels for heavy-duty vehicles and shipping. Nonetheless, in Canada, in March 2023 comments, it supported specific purchase incentives for zero-emission vehicles and EV charging infrastructure. Also, in the UK, Shell appeared to support an electric vehicle sales mandate in a March 2023 consultation response.
Industry Association Governance: Shell disclosed a partial account of the company's indirect climate policy engagement. In 2025, Shell published its fourth detailed industry association review, in which it found 12 industry associations to be partially misaligned, including the American Petroleum Institute, Australian Energy Producers the Chamber of Minerals and Energy West Australia, the National Association of Manufacturers and the US Chamber of Commerce. Shell found all of these associations to be partially misaligned in its last full industry association review, published in 2023.
A detailed assessment of the company's corporate review on climate policy engagement can be found on InfluenceMap's CA100+ Investor Hub here.
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 Q2 2025.