Climate Action 100+

Climate Action 100+ is an investor-led initiative through which institutional investors engage the world's largest corporate greenhouse gas emitters on climate change. Launched in December 2017 at the One Planet Summit in Paris, it was designed as a five-year programme and in 2022 was extended to 2030. Its website lists more than 600 investor signatories as of 2026. The companies it targets, about 170 "focus companies" in oil and gas, utilities, mining, steel, cement, cars, airlines and other heavy-emitting sectors, account for a large share of global industrial emissions.

The initiative is coordinated by five investor networks: the Asia Investor Group on Climate Change (AIGCC), Ceres, the Investor Group on Climate Change (IGCC), the Institutional Investors Group on Climate Change (IIGCC) and the Principles for Responsible Investment (PRI). It does not invest money or vote shares itself; individual signatories decide how to engage and vote. Its goals draw on the Paris Agreement temperature targets.

Imagine the tenants of a large block of flats who are worried about a faulty boiler. One tenant complaining is easy to ignore, but if hundreds of tenants sign the same letter and ask for the same three fixes, the landlord is far more likely to listen. Each tenant still decides whether to stay, pay rent or withhold it.

Climate Action 100+ works in a similar way for shareholders. Investors who together own large stakes in big emitters agree on a short list of requests, take turns leading conversations with each company, and use a public scorecard to track progress. The collective voice is what gives the effort weight; each investor remains free to act on its own.

Signatories ask focus companies to deliver on three goals:

• Governance. Put in place a strong board-level framework that sets out accountability and oversight of climate risk.
• Action. Take action to reduce greenhouse gas emissions across the value chain, consistent with the Paris Agreement goal of net-zero emissions by 2050 or sooner.
• Disclosure. Provide enhanced corporate disclosure in line with the TCFD recommendations, now carried forward by the ISSB's IFRS S2, so investors can assess company plans.

For each focus company, one or more lead investors coordinate a group of signatories that meets management and the board. Tools include private dialogue, public letters, proxy voting against directors, and co-filing shareholder resolutions at annual meetings. This is a form of collaborative corporate engagement and sits within investors' wider investment stewardship programmes.

Progress is tracked through the Net Zero Company Benchmark, first published in March 2021, which assesses each focus company against indicators such as a net-zero ambition, short- and medium-term targets, a decarbonisation strategy, capital allocation alignment, climate policy lobbying, governance and disclosure.

In June 2023 the initiative announced a second phase, starting in 2024, which shifted the emphasis from asking companies for better disclosure towards asking them to implement their transition plans and cut emissions, and which asked signatories to report more on their own engagement activity.

In February 2024 several large asset managers changed their participation. JPMorgan Asset Management and State Street Global Advisors withdrew, with State Street saying the phase 2 requirements were inconsistent with its independent approach to proxy voting and engagement, and JPMorgan citing its own in-house climate engagement capability. BlackRock transferred its participation from its US business to BlackRock International, citing legal considerations, especially in the United States. PIMCO also withdrew. These departures came amid scrutiny from Republican-led committees of the US House of Representatives and state attorneys general, who argued that coordinated climate engagement by competing asset managers could raise antitrust and fiduciary-duty concerns. The initiative and many asset owners, including several large pension funds, said they would continue.

Climate Action 100+ is one of the main vehicles for engagement-based sustainable investing, as opposed to divestment or exclusionary screening. Its benchmark data is used by investors in ESG integration and by asset owners such as members of the Net-Zero Asset Owner Alliance (NZAOA), whose engagement targets often include focus companies. Investors see the initiative as a way to manage climate-related market risk across diversified portfolios, where it is difficult to avoid large emitters entirely, especially in index funds that track benchmarks such as the S&P 500.

Supporters point to companies that set net-zero targets, added climate expertise to boards or improved disclosure after engagement. Critics on the climate side argue that few focus companies have plans fully consistent with 1.5°C, that capital spending on fossil fuels has continued, and that engagement without escalation to divestment gives companies too much time. Critics on the other side argue that collective investor pressure on climate oversteps the role of shareholders, puts political goals ahead of returns and may conflict with competition law. Measuring the initiative's own impact is also difficult, because companies change strategy for many reasons, including regulation, energy prices and customer demand, as well as shareholder pressure. Some focus companies have answered with financial materiality arguments of their own, contending that an overly rapid transition would destroy shareholder value.

• Climate Action 100+