Amundi engaged with RWE from 2016 onwards, pressuring them to adopt more climate targets and a Paris-aligned transition strategy. Amundi may have influenced the company’s 2019 pledge to reach carbon neutrality by 2040. Yet the main driver of RWE’s transition and target-setting is likely to be regulatory: it is subject to the EU Emissions Trading System and will have to comply with the German government’s ban of coal from 2038 onwards. RWE’s limited plans to phase out its coal assets are inconsistent with Carbon Tracker’s assessment that they must retire all coal by 2030 to be aligned with the Paris Agreement. In 2019, the company carried out a climate lobbying audit as requested by a CA100+ backed coalition, but failed to follow-through and actively change its trade association lobbying. Future engagers could push RWE to re-evaluate its lobbying audit and the activities of obstructionist trade associations, such as Business Europe.