Thematic engagement amidst the current U.S. policy landscape
Investors in North America began a thematic engagement on science-based greenhouse gas (GHG) targets in 2023, focused on supporting companies to strengthen emissions reduction targets and contributing to the development of target-setting frameworks. Some investors are also actively tracking and responding to target regressions, as well as instances where companies claim alignment with climate science, but independent assessments indicate otherwise.
Engagement is taking place against a rapidly evolving U.S. policy and market backdrop. Companies are navigating shifting federal energy incentives, regulatory uncertainty, changing state-level policies, and unprecedented energy demand driven by electrification and data center growth.
In this context, a handful of U.S. companies have revised or removed GHG targets. In many cases, companies quietly omit targets from their latest disclosures without clear explanation or public acknowledgement, making these developments hard for investors and other stakeholders to track. Several of these regressions have surfaced in the 2025 Climate Action 100+ Benchmark results, and the upcoming 2026 dataset will be useful for identifying further shifts and trends.
Why this matters for investors
These targets have historically served as an important signal to investors of how companies assess transition risks and opportunities. Where companies remove targets without providing clear strategic rationale or alternative forward-looking metrics, investors may face reduced visibility into how climate-related risks and opportunities are being managed.
The removal of a GHG target does not change the underlying economic drivers of the energy transition. Companies that dramatically shift climate strategies expose themselves to increased scrutiny and activity from institutional investors who are seeking to mitigate long-term risk and pursue decarbonization opportunities across their portfolios.
Investors are taking a range of approaches in response to these developments, including continued engagement with companies, closer scrutiny of governance and strategy, and consideration of implications for portfolio construction and voting decisions. Below, investors highlight a range of stewardship considerations associated with target regressions.
“Miller/Howard firmly believes the adage “you can’t manage what you don’t measure.” We have applauded the companies that not only measure and manage, but target performance improvements. But now, when we see companies removing those performance improvement targets, it not only raises governance and strategic concerns, it can hamstring us in our ability to balance risk and opportunities when making investments. Company transparency and public disclosure support informed investment decisions—and can reduce risk and drive improvements in the company’s operations and governance.” – Luan Jenifer, CEO & President, Miller/Howard Investments, Inc.
“These developments are particularly concerning. Emissions reduction targets are used by many investors to help define investable universes, inform product design and assess eligibility under regulatory reporting regimes such as the Sustainable Finance Disclosure Regulation (SFDR). Companies should not underestimate the potential implications of rolling back emissions targets, particularly for how such decisions are viewed by international shareholders and reflected in capital allocation decisions.” – Georgia Hall, ESG & Investment Director, Maple-Brown Abbott Global Listed Infrastructure
“In the face of increasing energy demand and shifting federal and state policies, a reasonable investor could expect a company that is committed to sustainability to adjust their greenhouse gas emission reduction target to reflect this new reality. The decision to completely remove targets is a missed opportunity and raises important questions about risk management and opportunities. We will be critically reviewing and engaging companies that remove targets about these governance-related concerns.” –Katie Carter, Director of Faith-Based Investing and Shareholder Engagement, Presbyterian Life & Witness
“For us, emissions reduction targets are far more than a tool for portfolio alignment with the European Sustainable Finance standards and regulations. They are the primary signal of the ongoing economic transition. By clarifying where capital will flow and which activities will be prioritized, they compel all market participants to adapt. The removal of a target, especially without a credible alternative strategy, creates significant uncertainty and calls into question a company’s accountability to its investors and the decarbonization pathway. This is a signal we cannot ignore in our investment and engagement decisions.” – Jean-Baptiste Rouphaël, Senior Impact & ESG Specialist, Mirova