How Big Oil kills sustainability and climate legislation

In May 2024, after an intense four-year political process, full of twists and turns, EU governments finally approved(opens in new window) the Corporate Sustainability Due Diligence Directive (CSDDD), the landmark law aimed at holding corporations accountable for human rights violations, environmental harms, and climate impacts in global supply chains. Just seven months later, President of the European Commission Ursula von der Leyen announced that the Commission would develop an Omnibus proposal overhauling several EU sustainability laws, including the CSDDD. Following the publication of the EU Omnibus I package in February 2025, the EU seems to be on a path to rid the CSDDD of most of what makes it meaningful, including its provisions on climate and civil liability.

Who has been driving the EU’s gutting of the CSDDD? With the launch of the Antwerp Declaration(opens in new window) in February 2024, business associations such as Cefic and BusinessEurope started advocating for an Omnibus regulation aimed at “correcting” EU sustainability laws, including the CSDDD. While most companies let business associations front the lobbying efforts, one company has been openly and vocally demanding sweeping changes to EU legislation: the American oil and gas giant ExxonMobil.

While ExxonMobil publicly opposed(opens in new window) the CSDDD in several interviews(opens in new window) in the summer of 2025, calling(opens in new window) it “probably some of the worst legislation […] passed anywhere in the world”, this SOMO investigation reveals how the company embarked on an intense lobbying campaign against the CSDDD already in the second half of 2023(opens in new window) . 1 Its goal? “Withdrawal or substantial modifications” 2 – in other words, killing the CSDDD.

Our analysis unravels the intensity and scale of ExxonMobil’s lobbying operation. We also expose how European Commissioners, members of the European Parliament, and EU governments now hold positions that are remarkably aligned with those of the fossil fuel giant. ExxonMobil also appears to have played a key role in building up the US resistance against the CSDDD, including by lobbying the Trump administration.

ExxonMobil is the world’s largest privately-owned oil and gas producer(opens in new window) and emitter of CO₂(opens in new window) , being responsible for 1.3 per cent(opens in new window) of all global emissions. In spite of its rhetoric about the future of EU competitiveness and defending jobs in Europe, the company does not lobby in the interest of society, the EU economy, or even the general interest of the business community. ExxonMobil’s position represents its own private business interests; its shareholders would not accept anything else. As to the CSDDD, ExxonMobil makes no secret of seeing it as a threat(opens in new window) to its profitability and business model – and that is why it wants to see it gone. Exxon’s position contrasts sharply with the support(opens in new window) from hundreds of multinational enterprises(opens in new window) and investors for maintaining(opens in new window) the EU sustainability framework and the CSDDD, including its climate obligations(opens in new window) .

Exxon’s problem: the CSDDD is bad for profits

The CSDDD obliges large companies to address human rights violations and environmental harms in their own operations and global supply chains by conducting due diligence. It also makes it possible for victims of harm to hold companies liable if they violate the law. In addition, the CSDDD obligates companies to implement a ‘climate transition plan’ to ensure the company is operating in line with the EU climate targets and the Paris Agreement.

ExxonMobil sees the introduction of laws containing due diligence requirements and obligations on “government-mandated energy transition plans” as a risk(opens in new window) that could “adversely affect” its profits. ExxonMobil’s CEO, Darren Woods, has called(opens in new window) the CSDDD “an irrational piece of policy” which contains(opens in new window) “bone-crushing penalties” and will “accelerate our exit(opens in new window) from Europe”. By fighting the CSDDD, Woods claims(opens in new window) , ExxonMobil is “trying to help the Europeans save themselves”.

Since March 2024(opens in new window) , ExxonMobil has repeatedly threatened(opens in new window) to spend “practically nothing” of its $20 billion planned investments in low-carbon technologies in the EU, unless European lawmakers cut “red tape” 3 like the CSDDD. The fossil fuel giant complained(opens in new window) that regulatory burdens in the EU are too high and specifically called(opens in new window) for the CSDDD to be addressed, claiming it “would be a very strong message [for the EU] to say, we heard you.” In September 2025, ExxonMobil announced(opens in new window) it would pause €100 million of investments in Europe due to draft EU rules on plastic recycling, and also repeated its concerns about other EU regulations, specifically the CSDDD. In 2024, Exxon raked in net profits of over $33.7 billion and paid out over $36.0 billion to its shareholders. The annual implementation costs of the CSDDD for very large companies, calculated by the European Commission, are estimated to be just 0.002 per cent of Exxon’s net profits in 2024 and less than 20 per cent of its annual lobbying expenditure(opens in new window) in the EU. According to Oil Change International(opens in new window) , ExxonMobil’s current climate transition plans are completely incompatible with reaching the Paris Agreement’s 1.5 degrees Celsius climate target.

Turning on the lobbying machine

ExxonMobil has the thirteenth largest lobbying budget(opens in new window) of all companies lobbying EU institutions, spending €3.5-4 million and employing 15 lobbyists (6.1 full-time equivalent) in 2024. 4 Since early 2024, the company’s lobbying machine has been in full swing to get the CSDDD watered down or cancelled completely. Documents shared with SOMO by a confidential source show that ExxonMobil was lobbying at least one major EU government already in September 2024, calling 5 for the CSDDD to be “paused” so that the “necessary remedies” could be identified, including “withdrawal” – well before Ursula von der Leyen’s November 2024 announcement(opens in new window) that the Commission would develop an Omnibus proposal overhauling several EU sustainability laws.

If scrapping the CSDDD was not an option, another ExxonMobil document 6 lists the “substantial modifications” the company wanted to see instead:

1. Entirely removing the obligations on climate transition plans (Article 22).
2. Entirely removing the provisions on civil liability of companies (Article 29). 
3. Limiting the due diligence obligations to large direct suppliers only (Tier 1).
4. Limiting the scope of due diligence for non-EU companies to their business within the EU only.

ExxonMobil’s lobbying efforts, alongside those of the business associations(opens in new window) it supports, have started to pay off – and in no small measure. The Commission’s Omnibus I proposal(opens in new window) , presented in February 2025, strongly aligned with ExxonMobil’s demands by removing the obligation to implement climate transition plans and the provisions on civil liability, as well as by restricting the due diligence obligation to direct (Tier 1) suppliers only. EU Member States integrated the same three ExxonMobil points in the Council position(opens in new window) they adopted in June 2025. Although negotiations on the European Parliament’s position on the Omnibus proposal are currently still ongoing, the May 2025 draft report(opens in new window) of Jörgen Warborn, the leading Member of the European Parliament on this issue, aligns with ExxonMobil’s positions even more strongly, including by proposing to scrap the entire climate article in the CSDDD. In the EU-US trade agreement from August 2025, the EU committed(opens in new window) to proposing changes to the CSDDD in at least three of ExxonMobil’s four priority areas: civil liability, climate transition plans, and the law’s application to non-EU companies (extraterritoriality).

How did ExxonMobil manage to be so seemingly effective? By setting up an intensive, multi-pronged lobbying campaign both in Europe and the US, comprising the following tactics:

• Directly lobbying policymakers.
• Accessing policymakers via business associations.
• Sponsoring media events and strategic media outreach.
• Funding think tanks.

The cumulative impact of ExxonMobil’s lobbying approach has been enormous. It has enabled the company to have extensive access to EU and US policy spaces at crucial moments throughout the Omnibus political process in 2024 and 2025.

Directly lobbying policymakers

While the EU Transparency Register(opens in new window) shows no evidence of ExxonMobil engaging with policymakers on the CSDDD at all during the initial political process between 2020 and 2023 7 , it set its lobbying machine in full swing in early 2024. Between April 2024 and July 2025, ExxonMobil had at least seven meetings with the European Commission in which it discussed 8 the EU’s simplification agenda and legislation targeted by the Omnibus proposals, such as the CSDDD. Just weeks before Commissioner Dombrovskis published the Omnibus I proposal in February 2025, he had a meeting(opens in new window) with ExxonMobil in which the company’s demands for the CSDDD were discussed.

In the same period, ExxonMobil had at least eighteen meetings(opens in new window) with Members of the European Parliament, which covered the Omnibus proposal and/or competitiveness. This includes two meetings with rapporteur Warborn in February and March 2025, in the run-up to the publication of his draft report(opens in new window) in May 2025. Based on the European Transparency Register, this makes ExxonMobil the most active entity lobbying the European Parliament on Omnibus, competitiveness, and/or the CSDDD.

According to AmCham EU, ExxonMobil participated in two meetings held in April 2025 between AmCham EU members and President of the European Commission Ursula von der Leyen(opens in new window) and President of the European Parliament Roberta Metsola(opens in new window) , respectively, in which competitiveness, concerns about regulatory burdens and the Omnibus simplification package were discussed. 9 ExxonMobil(opens in new window) also participated in meetings which covered competitiveness and “regulatory reform” with the President of the European Council in July 2024(opens in new window) (Charles Michel) and April 2025(opens in new window) (Antonio Costa).

On the side of the Council, there is evidence of ExxonMobil lobbying several EU Member States on withdrawing, delaying, or severely weakening the CSDDD, including one major EU government in September 2024, 10 the Dutch government(opens in new window) in December 2024, and the office of the Chancellor of the German government(opens in new window) in January 2025. ExxonMobil has stated it also raised the CSDDD with the prime minister of Greece(opens in new window) , Kyriakos Mitsotakis, in November 2024. In October 2024, ExxonMobil criticised the CSDDD at the Business Meets Government Summit(opens in new window) in Hungary, which was attended by several Hungarian government officials. 11 The conference was co-organised by AmCham Hungary and a Hungarian government agency and co-sponsored(opens in new window) by ExxonMobil.

ExxonMobil was also present at key moments in the European Commission’s political process leading up to the Omnibus I package. ExxonMobil participated in the European Commission’s controversial(opens in new window) ‘reality check’ consultations on the Omnibus I proposal in February 2025. It was also one of only 83 companies interviewed for the Draghi report(opens in new window) on EU competitiveness, which laid the groundwork(opens in new window) for the Commission’s deregulation drive.

In response to a letter from SOMO, Ursula von der Leyen stated that “the Commission listened to a broad range of stakeholders and views, in line with its very high transparency standards in law-making” in preparation for the Omnibus I package.

Lobbying the US government and Congress

In the US, ExxonMobil appears to have successfully mobilised(opens in new window) the Trump administration and members of Congress in its fight against the CSDDD. ExxonMobil started lobbying(opens in new window) the US Senate and House of Representatives on the CSDDD from the second half of 2023 and has confirmed it lobbied Congress “about putting in blocking legislation”(opens in new window) . In March 2025, Senator Bill Hagerty introduced the “Protect the USA Act(opens in new window) ”, which would ban some American businesses from complying with the CSDDD, including companies “exploring or producing fossil fuels”.

Before introducing the bill, Hagerty co-authored an anti-CSDDD letter(opens in new window) to the Biden administration in September 2024 and an op-ed in the Wall Street Journal(opens in new window) in October 2024, which claimed the CSDDD undermines US sovereignty. Making arguments similar to ExxonMobil’s, Hagerty urged the Biden administration to push EU legislators to pause the implementation of the CSDDD, in order to repeal or “substantially modify” it. 

Of the 66 Members of Congress who signed the letter, 64 received campaign donations(opens in new window) totalling almost $700,000 from ExxonMobil’s Political Action Committee (PAC) between 2017 and 2024. One of the signatories, Representative Dan Meuser, specifically related the CSDDD to US fossil fuel companies, asserting(opens in new window) that under the CSDDD, “US businesses could be sued by the EU for simply doing business with so-called high-impact companies such as natural gas.” 

Hagerty and four other members of Congress sent another letter(opens in new window) in February 2025, which calls upon the Trump administration to lobby the EU to indefinitely pause the implementation of the CSDDD. Each of the letter’s authors received campaign donations(opens in new window) from Exxon between 2017 and 2024.

ExxonMobil has confirmed(opens in new window) that it lobbied the Trump administration “many times”(opens in new window) about bringing the CSDDD “into the tariff discussions as a non-tariff barrier that’s impacting US companies across all industries to compete”. According to the Wall Street Journal(opens in new window) , ExxonMobil CEO Woods raised the CSDDD with President Trump at a meeting at his residence in Mar-a-Lago in January 2025, and again at a meeting at the White House in March.

ExxonMobil’s efforts had the desired effect: after US Secretary of Commerce Howard Lutnick stated(opens in new window) in January 2025 that the US would consider using “trade tools” to combat the CSDDD, Trump government officials(opens in new window) reportedly did so in the spring of 2025 during the US-EU trade negotiations. In September 2025, US Energy Secretary Chris Wright said(opens in new window) that EU climate regulations, including the CSDDD, need to undergo “massive modifications” and “significantly threaten the ability to implement the [US-EU] trade deal”. 

Gaining additional access to policymakers via business associations

Lobbying through business associations provides(opens in new window) ExxonMobil with an additional route to access policymakers and increase the cumulative impact of its lobbying campaign. ExxonMobil supports, and in many cases holds board positions in, thirteen business associations in the EU and the US, which have had a strong influence(opens in new window) on the European Commission’s deregulation agenda and Omnibus I proposal. In line with ExxonMobil’s position, most of these lobby groups have argued for strong restrictions or complete removal of the climate and civil liability provisions, and for restricting the value chain scope to Tier 1 suppliers only. 

Between July 2024 and July 2025, the EU and US business associations ExxonMobil supports held 12 at least 31 meetings with the European Commission and 66 meetings with members of the European Parliament related to competitiveness and simplification of EU rules, such as the CSDDD. Research has shown that the European Commission incorporated(opens in new window) most of the demands of BusinessEurope and AmCham EU into the Omnibus I proposal.

In February 2024, Cefic, in which ExxonMobil holds key leadership positions(opens in new window) , led the launch of the ‘Antwerp Declaration for a European Industrial Deal(opens in new window) ’, which called upon the European Commission to “develop an Omnibus proposal to take corrective measures on all relevant existing EU regulations”. The Antwerp Declaration kick-started(opens in new window) the Commission’s deregulation agenda. Cefic, BusinessEurope, and IOGP participated in the European Commission’s Omnibus consultation in February 2025 and were interviewed for the Draghi report(opens in new window) . AmCham EU also participated in the Omnibus consultation.

ExxonMobil also supports(opens in new window) the four business associations which lobbied(opens in new window) the US Congress and government on “protect[ing] US companies” from the CSDDD in December 2024 (the US Chamber of Commerce, the American Petroleum Institute (API), the National Association of Manufacturers, and the Business Roundtable). ExxonMobil is on the board(opens in new window) of the API and contributed(opens in new window) between $7.5 million and $10 million to its budget in 2023. Following the 2025 US-EU trade deal, the API thanked(opens in new window) the Trump administration for “standing up” against the CSDDD(opens in new window) .

Sponsoring media events and strategic media outreach

Sponsoring events hosted by established media organisations is a commonly used lobbying tactic, allowing companies to convey(opens in new window) their messages under the banner of well-known media brands. ExxonMobil was the sole sponsor of the FT Live event in March 2025 titled “Tackling Europe’s Red Tape Challenge(opens in new window) ”, which focused entirely on discussing deregulation and the CSDDD. ExxonMobil was also one of the corporate sponsors of Politico’s “Competitive Europe Week(opens in new window) ”, held in October 2024. The event featured an interview(opens in new window) with ExxonMobil Europe President Philippe Ducom, who called for the CSDDD to be “stopped” and “adjusted”. Both events were filled(opens in new window) with EU policymakers, including Enrico Letta, the EU rapporteur on the future of the single market; members of the European Parliament; and officials from the European Commission and EU governments.

ExxonMobil used the media to express its lobbying demands at politically strategic moments. While the Commission was preparing the Omnibus I proposal in late 2024, Ducom raised the CSDDD in three separate interviews. 13 In the summer of 2025, when the trade negotiations between the US and the EU were in their final stages, ExxonMobil CEO Woods brought up(opens in new window) the CSDDD three times(opens in new window) on US television channels(opens in new window) . Speaking to CNBC, Woods stated(opens in new window) that the CSDDD imposes a minimum penalty of 5 per cent of a company’s global revenues. This is not correct; the CSDDD does not set minimum penalties for companies. 14 ExxonMobil Europe and Ducom also published at least 28 LinkedIn posts 15 between December 2023 and June 2025, calling for simplification and reducing regulatory burdens for companies, including by addressing the CSDDD.

Funding think tanks

ExxonMobil has supported at least three think tanks which promoted a position on the CSDDD that is the same as its own: the European Roundtable on Climate and Sustainable Transition (ERCST), the German Marshall Fund of the United States (GMF), and the American Center for Capital Foundation (ACCF).

Since late 2023, the ERCST has produced(opens in new window) three highly critical publications(opens in new window) on the CSDDD(opens in new window) , which all align with ExxonMobil’s positions. The Brussels-based think tank has received funding(opens in new window) from ExxonMobil both through general membership fees and project support. It also employs a former ExxonMobil lobbyist(opens in new window) . ExxonMobil and ERCST participate in each other’s events(opens in new window) , including the ExxonMobil-sponsored FT Live event(opens in new window) in March 2025.

In a report launched while the European Commission was preparing the Omnibus I proposal, the ERCST strongly criticised(opens in new window) the climate provisions in the law and warned against the extraterritorial application, supposed litigation risks, and the regulatory burden. Similar to ExxonMobil, the report calls for re-assessing and modifying the CSDDD, as well as postponing enforcement of “contentious provisions” of the law.

Since November 2024(opens in new window) , the ERCST(opens in new window) has organised four events(opens in new window) related to the CSDDD(opens in new window) , most of which were attended by members of the European Parliament and European Commission officials. In November 2025, the ERCST will hold an event(opens in new window) focused on the Omnibus I trilogue negotiations between EU Member States and the European Parliament, for which it invited(opens in new window) European Parliament rapporteur Warborn.

The GMF, which is based(opens in new window) both in the US and the EU, has been receiving unspecified annual contributions of up to $100,000(opens in new window) from ExxonMobil since at least 2018. 16 In April 2024, the GMF called upon the EU to “cut red tape(opens in new window) ” to improve its competitiveness. ExxonMobil Europe Director Ducom and CEO Woods criticised the CSDDD at a GMF event in November 2024(opens in new window) and the GMF’s Brussels Forum in June 2025(opens in new window) , respectively. The Brussels Forum(opens in new window) was attended by three European Commissioners, five members of the European Parliament and numerous other officials from EU institutions and governments.

The ACCF, a conservative American think tank, published a letter criticising(opens in new window) the CSDDD in the Financial Times in October 2024. Its author, Mark Roman, worked(opens in new window) for ExxonMobil for over 42 years, including twenty years as a lobbyist, prior to joining the ACCF. Exxon has supported(opens in new window) the ACCF since 1998, with total contributions exceeding $1.5 million.

Hitting the mark: the EU aligns with ExxonMobil’s priorities

With its intense, multipronged attack on the CSDDD, enabled by its sizable financial resources, ExxonMobil has been a driving force behind the EU’s gutting of the CSDDD. ExxonMobil has gained levels of influence and access that far exceed those of public interest advocates, such as the civil society organisations, trade unions, and activists lobbying on the CSDDD. This influence does not only stem from the company’s direct lobbying activities, but is the result of the cumulative impact of the different tactics the company used. These tactics are similar to those applied by Big Tobacco companies, including the use of lobby groups(opens in new window) and think tanks(opens in new window) . ExxonMobil will not stop here – it still hopes to get the CSDDD scrapped altogether, and is eyeing(opens in new window) the deregulation of other EU climate laws as well.

While the EU institutions finally completed the regular EU policy-making process for the CSDDD in the spring of 2024, they have now decided to amend the law even before its implementation, in ways that are notably aligned with ExxonMobil’s demands. By ignoring(opens in new window) its own rules for sound policymaking, capitulating to corporate threats about cutting investments or jobs, and giving in to the Trump administration’s tariff war demands on EU laws, the EU institutions are setting a dangerous precedent for democracy in Europe, at a time when it is already under severe pressure. It is crucial that EU governments and the European Parliament – especially the European People’s Party (EPP) and Renew – defend democratic decision-making in Europe, instead of allowing it to be captured by the interests of a small but powerful group of multinational enterprises and the Trump administration.

The obstruction of climate policy-making by fossil fuel companies is a key obstacle(opens in new window) to addressing the climate crisis(opens in new window) . The EU, therefore, desperately needs to apply(opens in new window) what has become the norm for tobacco manufacturers in global health policies: those causing the harm cannot be part of writing the solutions and should be excluded(opens in new window) from climate policymaking.

About the authors

Lily Versteeg, co-author of this investigation, was a research intern at SOMO from April to August 2025.