The EU's Sustainable Finance agenda is leading the world in defunding the climate crisis and shifting trillions to build the net zero economy we need by 2050. Leading sustainable asset managers have globally voted to mitigate the climate crisis and supported the EU agenda. Others have sided with executives of polluting corporations who exercise power over certain asset managers via corporate pension fund mandates and investment banking fees available for some asset manager's parent company. History will be kind on the former whose support will be needed for decades to reach the EU's Net Zero 2050 goal. Public pension funds served by the latter might want to engage in the debate ...

Prof. Andreas G. F. Hoepner, Ph.D, Chair in Operational Risk, Banking & Finance, College of Business, University College Dublin (UCD) and Member of. the Technical Expert Group on Sustainable Finance, DG FISMA, European Union

The vast majority of the financial sector is allowing sustainable finance policies to be watered down by incumbent interests in the fossil fuel value chain due to their skepticism of robust regulation. These policies are critical for aligning the financial sector with the goals of the Paris Agreement, which they all nominally support. For the ambition of the Action Plan to be realized, the financial sector needs to deploy its lobbyists according to its top-line positions.

Rebecca Vaughan, InfluenceMap Analyst

This research has mapped out intensive lobbying on European sustainable finance policy, led by industry groups representing the finance and corporate (real economy) sectors. Whilst a small number of financial institutions have pushed for ambitious policy, the majority have remained silent or stated only high-level support. Meanwhile, all but one of the 20 powerful industry associations analyzed have lobbied to dilute and delay key regulations designed to align Europe's financial system with the Paris Agreement.

The lobbying comes at a critical moment with the European Commission currently deciding a Renewed Sustainable Finance Strategy, considering both the European Green Deal and the need to recover from the impact of COVID-19. Having consulted on possible next steps over the summer, a proposal is expected from the Department for Financial Stability and Capital Markets (DG FISMA) in the fourth quarter of 2020. This will build on the current EU's Action Plan on Sustainable Finance, originally launched in 2018, to deliver on a High-Level Expert Group on Sustainable Finance (HLEG) recommendation for “no less than a transformation of the entire financial system”.

Overview of results

The quadrant chart plots the results of InfluenceMap's analysis for the financial institutions and industry associations included in the analysis. Engagement Intensity refers to how actively the entity is engaging, while Organization Score measures the degree of support/opposition to policy.

Most financial institutions (bottom-right quadrant, in blue) have shown caution and, despite having made some high-level supportive comments, have tended not to engage in a detailed or intensive manner. A small number of financial institutions (top-right quadrant, blue) have been actively engaged in promoting sustainable finance policy. A few financial institutions (center-left of the diagram, blue) appear to be more cautious about sustainable finance policy.

See section on Key Finding 1 for more detail.

Finance industry associations (center-left of the diagram, yellow) appear to have positions that are misaligned from most of their members and have tended to state high-level support for policies whilst lobbying on detailed regulation to weaken their stringency.

See section on Key Finding 2 for more detail.

The research highlights the importance for active progressive lobbying by finance, with a battle emerging with corporate industry associations (bottom-left quadrant, green) that have been highly engaged on certain strands of sustainable finance regulation and appear to be a significant barrier to progressive sustainable finance policy.

See section on Key Finding 3 for more detail .

EU Sustainable Finance Policy Engagement Summary

Financial institutions with an Engagement Intensity below 8 are excluded as a clear position on sustainable finance policy cannot be determined from the limited evidence available


Launched in March 2018, the EU's Action Plan on Sustainable Finance is seen as critically important in achieving the EU's climate goals, through reorienting capital flows towards a more sustainable economy and mainstreaming sustainability issues into financial decision-making. The Action Plan followed the recommendations of the High-Level Expert Group on Sustainable Finance (HLEG) which highlighted the need for “no less than a transformation of the entire financial system” to deal with the challenges raised by climate change.

In 2020, in light of both the agreement on the European Green Deal and the need to recover from the impact of COVID-19, the Commission announced a Renewed Sustainable Finance Strategy which will build on the current workstream and is expected to be launched in the fourth quarter of 2020.

The EU's Action Plan on Sustainable Finance


Key Finding 1:

Most financial institutions are not strategically engaged

Most financial institutions do not appear to be strategically engaged on sustainable finance policy, keeping largely to high-level statements in their own policy engagement and communications. More than 50% of the financial institutions researched have had such limited engagement that a clear position on sustainable finance policy could not be ascertained.

BNP Paribas, Aviva and Groupe BPCE stand out as being very positively engaged on sustainable finance policy, as seen in the quadrant diagram. A larger group have taken similarly supportive positions but do not appear to be as strategically engaged. This includes Legal & General, Nordea, Rabobank, Unipol and Aegon. A few financial institutions appear to be more resistant towards sustainable finance regulation and have pushed back against more stringent requirements. This includes BlackRock, Invesco, UBS and BNY Mellon.

How Financial Institutions are Engaging

Key Finding 2:

Finance industry associations are misaligned from their members

Most finance industry associations have stated broad support for sustainable finance policy whilst lobbying to weaken the details of key regulatory strands. As a result, their organization scores are significantly lower than the financial institutions they represent. This analysis highlights at least two potential causes of this misalignment:

  • 'Lowest common denominator': Industry associations may be adopting the most cautious positions amongst their members when there are conflicting positions within the association

  • Public vs private positions of financial institutions: Financial institutions may be issuing positive high-level statements on sustainable finance policy whilst channelling their concerns around the details of regulations through finance industry associations, potentially to avoid public scrutiny of less positive positions

61 of the 63 (97%) financial institutions analyzed in this research have links to industry associations that have lobbied to weaken regulation. The following graphic represents the misalignment between finance industry associations and most of their members, with the industry association's organization score indicated by a yellow circle and its members by blue circles . The exception to the trend is IIGCC which, whilst having a very similar set of members to other trade associations, appears to promote the most positive positions of its membership.

Finance Industry Associations and Member Misalignment

Financial Institution Disclosure on Industry Association Membership

Investors are increasingly demanding that the companies they invest in disclose and address misalignments between their lobbying practices and those of the industry associations through initiatives such as CERES and CA100+. Despite this, most financial institutions analyzed have either no or limited transparency on their indirect policy engagement through industry associations.

Key Finding 3

Corporate industry associations are an obstacle to progressive sustainable finance policy

Industry associations representing the corporate sector have been highly engaged on certain sustainable finance policy streams that directly impact their activities and their engagement has been more overtly oppositional to progressive policy than that from financial institutions and finance industry associations. Over 80% of all engagement from corporate trade associations has focused on the taxonomy, reflecting the potential ramifications of this policy for powerful vested interests who have sought to either restrict the taxonomy's coverage of their activities or to ensure their inclusion in what is defined as 'green’. With the upcoming revision of the EU's Non-Financial Reporting Directive (NFRD), corporate industry associations are becoming increasingly engaged on this policy stream and have strongly contrasting demands to the financial sector.

Some of the financial institutions analyzed are represented by EuropeanIssuers in their corporate functions. This includes Aegon, BNP Paribas, Generali, Santander and Intesa Sanpaolo. The positions taken by EuropeanIssuers are clearly highly misaligned from the individual positions of these financial institutions and even from their finance sector industry associations.

Industry Engagement on Sustainable Finance Policies

Score Table

Organization Score: A measure of an organization’s engagement with policy. Above 75 indicates support, below 50 indicates increasing opposition towards 0.

Relationship Score: A measure of a financial institution’s industry association's sustainable finance policy engagement. Above 75 indicates support, below 50 indicates increasing opposition towards 0 (financial institutions only).

Performance Band: A full measure of a financial institution's sustainable finance policy engagement accounting for both its and its own industry associations' activity on an A through to F scale. For industry associations, the performance band is based on the organization score only.

Engagement Intensity: Describes the level of engagement on sustainable finance policy, whether positive or negative. Above 12 indicates active engagement, above 25 indicates highly active or strategic engagement. In this research, financial institutions with an engagement below 8 were excluded from most of the analysis as a clear position could not be determined.

Modifications to InfluenceMap ScoringBack To Home
InfluenceMap Performance BandOrganization
Legal & GeneralFinancialsEurope
Groupe BPCEFinancialsEurope
BNP ParibasFinancialsEurope
Swiss ReFinancialsEurope
Danske BankFinancialsEurope
Deutsche BankFinancialsEurope
NatWest GroupFinancialsEurope
ABN AMROFinancialsEurope
Societe GeneraleFinancialsEurope
Zurich InsuranceFinancialsEurope
abrdn, formerly Standard Life AberdeenFinancialsEurope
Standard CharteredFinancialsEurope
Credit AgricoleFinancialsEurope
State StreetFinancialsNorth America
BlackRockFinancialsNorth America
BNY MellonFinancialsNorth America
InvescoFinancialsNorth America
Institutional Investors Group on Climate Change (IIGCC)FinancialsEurope
Institute of International Finance (IIF)FinancialsGlobal
Association for Financial Markets in Europe (AFME)FinancialsEurope
Insurance EuropeFinancialsEurope
European Banking Federation (EBF)FinancialsEurope
Managed Funds AssociationFinancialsGlobal
European Association of Co-operative Banks (EACB)FinancialsEurope
Invest EuropeFinancialsEurope
Alternative Investment Management Association (AIMA)FinancialsGlobal
European Chemical Industry Council (Cefic)ChemicalsEurope
European Steel Association (Eurofer)Metals & MiningEurope
EuropeanIssuersAll SectorsEurope
BusinessEuropeAll SectorsEurope
International Association of Oil and Gas Producers (IOGP)EnergyEurope


To define policy engagement, InfluenceMap relies on the 2013 Guide for Responsible Corporate Engagement in Climate Policy issued by the secretariat of the UNFCCC and the UNEP under the UN's Caring for Climate collaboration of the UN Global Compact. This document defines a list of corporate activities that constitute corporate climate engagement, covering direct and indirect tactics. These range from social media; public relations; sponsoring research; direct contact with regulators and elected officials; funding of campaigns and political parties; and participation in policy advisory committees.

Since this assessment focuses on EU policy, it is instructive to note that the EU’s institutions operate with varying levels of transparency. Therefore, coverage of interactions between organizations and the European Commission is higher than coverage of interactions with the European Parliament and Council of the European Union.

This analysis and scoring is focused on an organization's comments, interactions and influence on policy and legislation. It does not consider internal strategy, activities and performance of a company on sustainable finance or climate change related issues.

InfluenceMap's scoring process is policy neutral. It does not assess the quality of governmental policy but rather the positions of companies and industry groups relative to this policy. This is achieved by using the statements and ambitions of government-mandated bodies tasked to propose or implement sustainable finance policy as the benchmarks against which corporate and industry association policy positions are scored.

For this analysis, the recommendations of the European Commission’s High-Level Expert Group and its Action Plan on Sustainable Finance were relied on heavily as benchmarks. This was supplemented in places with the statements and recommendations of UN-backed scientific enquiry, such as the findings of the Intergovernmental Panel on Climate Change (IPCC).

Scored evidence is coded by InfluenceMap as: ‘strongly supporting’, ‘supporting’, ‘no position/mixed position’, ‘not supporting/supporting with exceptions’, or ‘opposing’ with reference to the benchmarks explained above. These categories correspond to a numerical five-point scale between +2 and -2, where +2 indicates strong support and -2 indicates opposition.

This research covers the period from 2017 to July 2020, following the High-Level Expert Group on Sustainable Finance and the first stage of the EU's Action Plan on Sustainable Finance. The weighting system prioritizes the most recent evidence pieces, so older evidence pieces have a smaller impact on the overall score. InfluenceMap's platform provides a snapshot of policy engagement so far and will be continually updated to cover future engagement, including on the EU's Renewed Strategy on Sustainable Finance.

This assessment has focused on the largest European financial groups’ engagement on sustainable finance policy, primarily EU-level policy with some engagement on policies in other European regions.

The universe of financial groups was selected by taking the top 25 European banks by assets, the top 25 European insurance groups by assets, and top 25 asset managers with a significant presence in Europe by AUM. These companies were scaled up to the financial group level, creating a final list of 63 financial groups after overlaps were excluded. 20 trade associations found to be active in this policy area were also selected.

The queries were selected to broadly cover the recommendations of the EU’s High Level Expert Group on Sustainable Finance and have been refined through consultation with experts in the field.

This is an emerging area of sustainable finance related policy which InfluenceMap plans to cover in the near future.

This is covered by InfluenceMap’s flagship platform on corporate influence and lobbying on climate policy.