Commitment Issues: Shell's LNG lobbying risks undermining its Paris pledge

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Executive Summary

This report provides a range of examples of Shell’s lobbying in key emerging markets for higher, long-term gas and liquefied natural gas (LNG) use. This lobbying seeks to support Shell’s strategy to grow LNG in these markets, but these activities do not appear aligned with Paris pathways and are inconsistent with the company’s commitment to lobby in support of the Paris goals.

The Global Standard for Responsible Climate Lobbying encourages companies to review and disclose direct and indirect climate change lobbying positions and activities, and also to assess how aligned these positions are with the goals of the Paris Agreement.^[1] While extensive investor engagement has driven Shell to incrementally improve its lobbying transparency in recent years,^[2] it is evident that investors still do not have adequate insight into the extent, impact or Paris alignment of the company’s lobbying.

Investor focus on Shell’s lobbying in emerging markets is due, in part, to the company’s ambitious LNG growth strategy targeted at these markets. This strategy is underpinned by bullish demand forecasts that predict LNG demand through to 2040 to be 21% higher than the International Energy Agency’s (IEA) Stated Policies Scenario (STEPS), a scenario which implies 2.4°C of warming and is therefore not Paris-aligned.^[3]

Shell is exposed to major financial risk if demand falls short of its expectations. The company has an unprecedented long position on LNG compared to peers and expects to hold around 1.4 billion tonnes of uncontracted LNG through to 2050.^[4] As such, Shell may have a strategic incentive to lobby for increased gas and LNG use at the expense of its commitment to lobby in line with the Paris Agreement’s goals.

It may be the case that companies will not materially change their Paris-misaligned lobbying while their corporate strategy remains Paris-misaligned. Investors may gain little from requests for more lobbying disclosure in this context. However, tackling the source of the inconsistency via ongoing scrutiny of Shell’s LNG growth strategy remains an important pathway for investors. Investors engaging on this can harness the momentum from the greater-than-20% vote at the 2025 AGM for a shareholder proposal asking for more disclosure around how LNG growth targets are consistent with Shell’s climate commitments. A supplementary approach for investors who view climate change as a systemic portfolio risk could include moving towards systems stewardship, with a focus on direct policy engagement.

Key Points

• Despite recent improvement in disclosures following investor engagement and escalation, investors still do not have adequate insight into the impact or Paris alignment of Shell’s lobbying, or the extent to which lobbying is used to support and shape strategy.

• We examined Shell’s long-standing lobbying in four markets which are material for Shell’s gas and LNG business, and where Shell has recently added climate-related lobbying disclosures. We found that while Shell’s disclosures acknowledge its lobbying engagements at a high level, they do not provide investors with sufficient detail to assess the impact of its lobbying and do not show whether this advocacy is aligned with the Paris goals:

  • China: Shell used its scenario modelling to engage with and influence Chinese energy policymakers for decades. For example, in 2015, its scenario modelling likely influenced China to pursue a more expansionary gas policy during its 13th Five Year Plan (2016-2020). Shell’s most recent scenario study, in 2024, promotes the idea that China can meet its Paris commitments with gas consumption higher than the IEA’s STEPS, at a level similar to Shell’s pre-Paris projections for Chinese gas use in the medium-term. However, given policy and technology headwinds, it is unlikely this will influence policymakers to the same degree as previous scenario studies.
  • India: Shell is bullish on India driving medium-to-long-term growth in gas and LNG demand, projecting consumption levels significantly above the IEA’s STEPS. It is engaged in long-term and extensive lobbying to boost gas and LNG use in India. The company used scenario modelling to increase its access to policymakers and funded a study which appears to have influenced policy for developing an LNG trucking market – despite LNG trucking having no clear greenhouse gas emissions benefits in India.
  • Malaysia: Shell advocated for long-term gas use in Malaysia’s energy transition in direct engagements with the government and through the influential Malaysian Gas Association (MGA). MGA helped shape Malaysia’s National Energy Transition Roadmap and endorses its plan to significantly increase gas use while targeting net zero by 2050. This appears misaligned with modelling of Malaysia’s decarbonisation that Shell created with a government agency.
  • Nigeria: Shell is the largest international oil and gas company in Nigeria. It is involved in shaping the country’s Decade of Gas policy initiative, which aims to make Nigeria “gas-powered” by 2030, targeting large increases in gas production and consumption. There is a risk this pushes Nigeria’s rapidly growing economy onto a heavy-emitting development pathway.

• Shell’s LNG growth strategy, which does not appear to be Paris-aligned, conflicts with its commitment to lobby in line with the Paris Agreement. To date, improvements to Shell’s disclosure regime do not adequately address this contradiction. It raises the question of whether investor engagement aimed at tackling Paris-misaligned lobbying via company-level disclosures is sufficient, if corporate strategy remains Paris-misaligned.

• Investors who see climate change as a systemic portfolio risk may consider moving towards systems stewardship, with a focus on direct policy engagement, to constrain Paris-misaligned lobbying.

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