Analysing the quality of oil & gas policies
The good, the bad and the in-between of the oil and gas policies adopted by financial institutions
of financial institutions assessed still have no oil and gas policy.
financial institutions assessed have committed to restrict their support to oil and gas developers.
of financial institutions assessed have not adopted any commitments to limit their support to the development of LNG infrastructure.
oil and gas policies adopted or updated since January 2023.
Why track oil and gas policies?
Science is clear. It is imperative to stop developing new upstream and midstream oil and gas projects and rapidly reduce the global oil and gas productionin order to avoid a climate breakdown.
Banks, insurers and investors are increasingly adopting decarbonization targets for the oil and gas sector but these are, on their own, insufficient to achieve a 1.5-aligned decline of the oil and gas industry. In fact, meeting this challenge requires banks, insurers and investors to also adopt robust oil and gas policies that immediately tackle oil and gas expansion while progressively drying up financial services to the whole industry.
The Oil and Gas Policy Tracker is designed to track the commitments taken by top financial institutions worldwide, highlight the good practices, and expose the flaws and loopholes to be avoided. Its primary objective is simple: to ensure that the financial sector is adopting effective oil and gas policies to forcefully contribute to the 1.5°C climate goal.
Financial institutions must tackle the oil and gas industry in addition to the coal sector, the exit of which remains a major challenge. Moreover, phasing out all financial services to the fossil industry won’t be possible without financial institutions increasing their support to sustainable energies. Please check our Coal Policy Tracker and Sustainable Power Policy Tracker.
Use the tracker
385 financial institutions are assessed in the Oil & Gas Policy Tracker. Last update: December 2025
This financial institution has one of the most robust oil and gas policies.
This financial institution has informed Reclaim Finance that it is working on a new policy which is expected to be published soon.
NA The criterion does not apply to this type of financial institution.
Reclaim Finance could not give a definite score and has contacted the financial institution for clarification.
How to read the results
This criterion rates the exclusion of financial services dedicated to oil and gas projects.
Grade PROJECTS 0 No public policy 1 Exclusion of financial services dedicated to upstream oil and gas projects in up to three unconventional sectors. 2 Exclusion of financial services dedicated to upstream oil and gas projects in four (or more) unconventional sectors. 3 Exclusion of some conventional and unconventional oil & gas projects: geographic disparities, potentially large exceptions, partial value chain, new oil OR gas fields/upstream projects, oil and gas exploration only, etc. 4 Exclusion of financial services dedicated to new oil & gas fields. 5 Exclusion of financial services dedicated to upstream oil & gas projects. 6 Exclusion of financial services dedicated to upstream oil and gas projects and some midstream projects. 7 Exclusion of financial services dedicated to upstream oil and gas projects and some midstream projects, including all LNG export terminals. 8 Exclusion of financial services dedicated to upstream oil and gas projects and some midstream projects, including all LNG export terminals and some LNG import terminals. 9 Exclusion of financial services dedicated to all oil & gas upstream projects and some midstream projects, including all LNG import and export terminals. 10 Exclusion of financial services dedicated to all oil & gas upstream projects and all midstream projects. BONUS / PENALTIES [Unconventional] Bonus +1 if midstream projects (infrastructure exclusively or mostly dedicated to unconventional) are excluded. [Unconventional] Bonus +1 when the definition of unconventional sectors is complete according to Urgewald’s Global Oil & Gas Exit List. Bonus +1 when some downstream projects (oil or gas-fired power plants, refineries, petrochemical plants) are excluded. [Unconventional] Penalty -1 when the exclusion is limited by a restrictive definition of the unconventional sector (e.g. limited/no definition of the Arctic region, offshore or onshore, oil or gas, etc.). Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -1 when the policy does not cover all financial services dedicated to a specific project. Remarks
Our assessment considers the following 4 unconventional sectors: Arctic oil & gas, shale oil & gas, tar sands, ultra deepwater oil & gas activities. The OGPT will also consider as a bonus a broader definition of unconventional oil & gas, as specified in the Global Oil & Gas Exit List: Arctic oil & gas, shale oil & gas, tar sands, ultra-deep water oil & gas, coalbed methane and extra-heavy oil.
We define upstream oil & gas projects as:
- Oil & gas exploration;
- Development of a new oil & gas field (not producing yet);
- Expansion or redevelopment of any field.
We define midstream oil & gas projects as:
- Infrastructure directly related to new oil & gas fields (not producing yet);
- Any new LNG infrastructure;
- Transportation vessels such as LNG carriers or oil tankers;
- Capacity increase of existing infrastructure.
This criterion rates the exclusion of corporate financial services to companies responsible for the expansion of the oil and gas sector.
Grade EXPANDING COMPANIES 0 No policy. 1 When assessing companies, “oil & gas expansion” is a criterion that can lead to unsystematic sanctions. 2 Conditions corporate financial services to the end of oil & gas expansion, but weak coverage of the O&G industry (broad exceptions, specialized companies only, one unconventional sector only, etc). 3 Conditions corporate financial services to the end of upstream oil and gas expansion in some unconventional sectors. 4 Conditions corporate financial services to the end of upstream oil and gas expansion in all unconventional sectors. 5 Conditions corporate financial services to the end of some upstream oil and gas expansion, including new oil and gas field development. 6 Conditions corporate financial services to the end of upstream oil and gas expansion. 7 Conditions corporate financial services to the end of upstream and some midstream oil and gas expansion. 8 Conditions corporate financial services to the end of upstream and some midstream oil and gas expansion, including some LNG export terminal development. 9 Conditions corporate financial services to the end of upstream and some midstream expansion, including all LNG export terminal development. 10 Conditions corporate financial services to the end of upstream and midstream oil and gas expansion. BONUS / PENALTIES Bonus +1 when the end of some downstream expansion (oil or gas-fired power plants, refineries, etc.) is a request leading to financing restrictions. [Unconventional] Penalty -2 if commitment is not applied immediately. [Unconventional] Penalty -1 when the definition of the unconventional sector is restrictive (e.g. limited/no definition of the Arctic region, offshore or onshore, oil or gas, etc.). [For scores between 1 and 8] Penalty -2 if commitment only applies to oil or gas. Penalty -2 when the policy does not cover lending and underwriting. Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -1 (-2) when new oil & gas upstream projects are defined as oil & gas upstream projects that received their Final Investment Decision after December 31st, 2021 (after a later date). Penalty -2 when the policy does not cover lending and underwriting. Penalties do not apply below score 1.
The total penalties in a sector cannot exceed the number of points earned by the financial institution regarding this specific sector.Remarks
We recommend that exclusion policies targeting companies expanding their oil & gas production be based on the Global Oil & Gas Exit List (GOGEL), and especially on the short-term expansion metric relying on resources under development and field evaluation (in mmboe) per company. This metric allows financial institutions to identify oil and/or gas resources that will come into production in the near future.
Reclaim Finance reserves the right to equate a commitment on expansion to the adoption of low exclusion thresholds for oil and gas production activities in the short term. E.g. a relative threshold of 1% on revenues derived from upstream oil and gas activities (score 3).
This criterion rates the quality of the oil & gas phase-out commitments made by banks (considering decarbonization targets, but also medium and long-term commitments).
Grade PHASE-OUT 0 No policy nor targets. 1 “Oil and gas phase-out” or “production plan” is a criterion that can lead to unsystematic sanctions. 2 Phase-out strategy for the oil and gas industry, but with weak coverage, unclear scope or inappropriate timeline.
OR
Any type of decarbonization target that does not ensure a decrease in real-world emissions (e.g. financed and facilitated emission targets using an attribution factor).
3 Phase-out strategy for unconventional oil and gas activities by 2030. 4 Phase-out strategy for all upstream oil and gas activities, but only after 2050. 5 Phase-out strategy for all upstream activities in the oil and gas sector by 2050.
OR
Sectoral portfolio financing volumes (SPFV) target for upstream oil and gas but only for lending or capital market activities (CMA), such as bond underwriting.
6 Phase-out strategy for all upstream activities in the oil and gas sector by 2040. 7 Phase-out strategy for all upstream activities in the oil and gas sector by 2035. 8 Phase-out strategy for all upstream activities in the oil and gas sector by 2030.
OR
SPFV target for upstream oil and gas for both lending and CMA.
9 Phase-out strategy for all upstream and midstream activities in the oil and gas sector by 2040. 10 Phase-out strategy for all upstream and midstream activities in the oil and gas sector by 2030.
OR
SPFV target for upstream and midstream oil and gas for both lending and CMA.
BONUS / PENALTIES Bonus +1 (+2) if additional commitment to phase out oil and gas-fired power generation activities by 2040 worldwide (and by 2030 in OECD and European countries). [Unconventional] Penalty -1 if phase-out commitment only covers a few unconventional sectors. [For scores between 1 and 8] Penalty -2 if commitment only applies to oil or gas. Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -2 when the policy does not cover lending and underwriting. [Targets] Penalty -1 (-2) if the targeted percentage of decrease in financing volumes/emissions is insufficient compared to (or unaligned with) a credible 1.5°C pathway. [Targets] Penalty -1 when transparency is too low. Penalties do not apply below score 1.
The total penalties in a sector cannot exceed the number of points earned by the financial institution regarding this specific sector.
Remarks
Reclaim Finance reserves the right to equate a long-term commitment with the adoption of robust relative and/or absolute thresholds in the short term:
- Unconventional thresholds considered as phase-out: a relative threshold of 5% based on a production metric or an absolute threshold of 2 mmboe (score 3);
- Conventional oil & gas upstream thresholds considered as phase-out: an absolute threshold of 20 mmboe OR a relative threshold of 1% on revenues derived from oil and gas upstream activities (score 6);
- Conventional oil & gas upstream & midstream thresholds: a relative threshold of 5% oil and gas/fossil fuel share of revenues (score 9).
Commitments to exclude/engage companies due to their production plans or share of CAPEX dedicated to oil and gas can also be considered.
This criterion rates how investors condition investments to the expansion plans of companies in the oil and gas sector.
Grade EXPANDING COMPANIES 0 No policy. 1 When assessing companies, “oil and gas expansion” is a criterion that can lead to undefined or unsystematic sanctions. 2 No new investments in companies that develop new upstream oil and gas projects, but weak coverage of the oil and gas industry (broad exceptions, specialized companies only, one unconventional sector, etc). 3 No new investments in companies developing new oil and gas upstream projects in some unconventional sectors. 4 Systematic and defined sanctions for companies in portfolio that continue to develop oil and gas projects. 5 No new investments in companies developing new unconventional oil and gas upstream projects. 6 No new investments in companies developing new oil and gas upstream projects. 7 For companies developing new oil and gas upstream projects, no new investments AND systematic and strong sanctions. 8 For companies developing new oil and gas upstream and some midstream projects, no new investments AND systematic and strong sanctions. 9 For companies developing new oil and gas upstream and some midstream projects, including all new LNG export terminals, no new investments AND systematic and strong sanctions. 10 For companies developing new oil and gas upstream and midstream projects, no new investments AND systematic and strong sanctions. BONUS / PENALTIES Bonus +1 when the end of some downstream expansion (oil or gas-fired power plants, refineries, etc.) is a request leading to investment restrictions. Penalty -1 or -2 if commitment not applied immediately. [Unconventional] Penalty -1 when the definition of the unconventional sector is restrictive (e.g. limited/no definition of the Arctic region, offshore or onshore, oil or gas, etc.). [For scores between 1 and 8] Penalty -2 if commitment only applies to oil or gas. Penalty -1 when no sanctions are taken for companies in portfolio that continue to develop new oil and gas upstream projects. Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -1 (-2) when new oil & gas upstream projects are defined as oil & gas upstream projects that received their Final Investment Decision after December 31st, 2021 (or a later date). Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -2 when the policy only covers new investments in shares. Penalty -1 or -2 when the policy does not apply to a significant part of assets/when passive management is not covered. Penalties do not apply below score 1. Remarks
We recommend that exclusion policies targeting companies expanding their oil & gas production be based on the Global Oil & Gas Exit List (GOGEL), and especially on the short-term expansion metric. It allows financial institutions to identify oil and/or gas resources that will come into production in the near future.
The following four unconventional sectors must be covered in order to score points at level 5: Arctic oil and gas, shale oil and gas, tar sands, and ultra deepwater oil and gas. Reclaim Finance recommends using the GOGEL’s definition of unconventional oil and gas, and the database to identify and exclude companies with unconventional oil and gas expansion plans.
In the assessment, sanctions taken by investors towards their investee companies are the following:
- Systematic votes against strategic/management-proposed resolutions (the re-election of directors, against executive remuneration and against the distribution of dividends) at the Annual General Meetings of companies.
- Divestment (bonds and/or shares).
Reclaim Finance reserves the right to equate a commitment on expansion to the adoption of low exclusion thresholds for oil and gas production activities in the short term. E.g. a relative threshold of 1% on revenues derived from upstream oil and gas activities (score 3).
This criterion rates the quality of the oil & gas phase-out commitments made by investors (considering both long-term and medium-term commitments).Grade PHASE-OUT 0 No policy. 1 “Oil and gas phase-out” or “production plan” is a criterion that can lead to unsystematic sanctions. 2 Adoption of a phase-out strategy for the oil and gas industry, but with weak coverage, unclear scope or inappropriate timeline. 3 Adoption of a phase-out strategy for unconventional oil and gas activities by 2030. 4 Adoption of a phase-out strategy for upstream oil and gas activities, but only after 2050. 5 Adoption of a phase-out strategy for upstream activities in the oil and gas sector by 2050. 6 Adoption of a phase-out strategy for upstream activities in the oil and gas sector by 2040. 7 Adoption of a phase-out strategy for upstream activities in the oil and gas sector by 2035. 8 Adoption of a phase-out strategy for upstream activities in the oil and gas sector by 2030. 9 Adoption of a phase-out strategy for upstream and midstream activities in the oil and gas sector by 2040. 10 Adoption of a phase-out strategy for upstream and midstream activities in the oil and gas sector by 2030. BONUS / PENALTIES Bonus +1 (+2) if additional commitment to phase out oil and gas-fired power generation activities by 2040 worldwide (and by 2030 in OECD countries). [Unconventional] Penalty -1 if phase-out commitment only covers a few unconventional sectors. [For scores between 1 and 8] Penalty -2 if commitment only applies to oil or gas. Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -1 or 2 when the policy does not apply to a significant part of assets. Penalty -2 when the policy only covers new investments in shares. Penalty -1 if phase-out commitment applies only to new investments and not divestment. Penalties do not apply below score 1. The total penalties in a sector cannot exceed the number of points earned by the financial institution regarding this specific sector. Remarks
A phase-out for unconventional sectors after 2030 falls in the “inappropriate timeline” category.
Reclaim Finance reserves the right to equate a long-term commitment with the adoption of robust relative and/or absolute thresholds in the short term:
- Unconventional thresholds considered as phase-out: a relative threshold of 5% based on a production metric or an absolute threshold of 2 mmboe (score 3);
- Conventional oil & gas upstream thresholds considered as phase-out: an absolute threshold of 20 mmboe OR a relative threshold of 1% on revenues derived from oil and gas upstream activities (score 6);
- Conventional oil & gas upstream & midstream thresholds considered as phase-out: a relative threshold of 5% oil and gas/fossil fuel share of revenues (score 9).
Commitments to exclude/engage companies due to their production plans or share of CAPEX dedicated to oil and gas can also be considered.
This criterion rates the exclusion of insurance coverage dedicated to oil and gas projects.
Grade PROJECTS 0 No public policy. 1 Exclusion of insurance coverage dedicated to upstream oil and gas projects in up to three unconventional sectors. 2 Exclusion of insurance coverage dedicated to upstream oil and gas projects in four (or more) unconventional sectors. 3 Exclusion of insurance coverage dedicated to all unconventional oil & gas upstream projects.
OR
Exclusion of some conventional and unconventional oil & gas projects: geographic disparities, potentially large exceptions, partial value chain, new oil OR gas fields, etc.
4 Exclusion of insurance coverage dedicated to all unconventional oil & gas upstream and midstream projects.
OR
Exclusion of insurance coverage dedicated to only oil OR gas upstream projects.
5 Exclusion of insurance coverage dedicated to new oil & gas fields. 6 Exclusion of insurance coverage dedicated to all oil & gas upstream projects. 7 Exclusion of insurance coverage dedicated to all oil and gas upstream projects and some midstream projects. 8 Exclusion of insurance coverage dedicated to upstream projects and some midstream projects, including some LNG export terminals. 9 Exclusion of insurance coverage dedicated to all oil & gas upstream projects and some midstream projects, including all LNG export terminals. 10 Exclusion of insurance coverage dedicated to all oil & gas upstream projects and all midstream projects. BONUS / PENALTIES [Unconventional] Bonus +1 if midstream projects (infrastructure exclusively or mostly dedicated to unconventional) are excluded. Bonus +1 when some downstream projects (oil or gas-fired power plants, refineries, petrochemical plants) are excluded. [Unconventional] Penalty -1 when the exclusion is limited by a restrictive definition of the unconventional sector (e.g. limited/no definition of the Arctic region, offshore or onshore, oil or gas, etc.). Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -1 when the policy does not cover all financial services dedicated to a specific project. Penalties do not apply below score 1.
The total penalties in a sector cannot exceed the number of points earned by the financial institution regarding this specific sector.
Remarks
Our assessment considers the following 4 unconventional sectors: Arctic oil & gas, shale oil & gas, tar sands, ultra-deep water oil & gas activities. The OGPT will also consider as a bonus a broader definition of unconventional oil & gas, as specified in the Global Oil & Gas Exit List: Arctic oil & gas, shale oil & gas, tar sands, ultra deepwater oil & gas, coalbed methane and extra-heavy oil. Excluding oil & gas extraction located in the Amazon can also be considered.
We define upstream oil & gas projects as:
- Oil & gas exploration;
- Development of a new oil & gas field (not producing yet);
- Expansion or redevelopment of any field.
We define midstream oil & gas projects as:
- Infrastructure directly related to new oil & gas fields (not producing yet);
- Any new LNG infrastructure;
- Transportation vessels such as LNG carriers or oil tankers;
- Capacity increase of existing infrastructure.
This criterion rates the exclusion of corporate-level insurance coverage to companies responsible for the expansion of the oil and gas sector.
Grade EXPANDING COMPANIES 0 No policy. 1 When assessing companies, “oil & gas expansion” is a criterion that can lead to unsystematic sanctions. 2 Conditions clients’ insurance coverage to the end of new oil & gas projects, but weak coverage of the O&G industry (exceptions, 1 unconventional sector, etc). 3 Conditions clients’ insurance coverage to the end of oil and gas upstream expansion in some unconventional sectors. 4 Conditions clients’ insurance coverage to the end of oil and gas upstream expansion in all unconventional sectors. 5 Conditions clients’ insurance coverage to the end of oil and gas upstream expansion, with some exceptions. 6 Conditions clients’ insurance coverage to the end of oil and gas upstream expansion, including all new oil and gas fields. 7 Conditions clients’ insurance coverage to the end of new oil & gas upstream projects. 8 Conditions clients’ insurance coverage to the end of new oil & gas upstream and some midstream projects, including some LNG export terminals. 9 Conditions clients’ insurance coverage to the end of new oil & gas upstream and some midstream projects, including all LNG export terminals. 10 Conditions clients’ insurance coverage to the end of new oil & gas upstream and all midstream projects. BONUS / PENALTIES Bonus +1 the end of some downstream expansion (oil or gas-fired power plants, refineries, etc.) is a request leading to restrictions of insurance coverage. [Unconventional] Penalty -2 if commitment is not applied immediately. [Unconventional] Penalty -1 when the definition of the unconventional sector is restrictive (e.g. limited/no definition of the Arctic region, offshore or onshore, oil or gas, etc.). [For scores between 1 and 8] Penalty -2 if commitment only applies to oil or gas. Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -1/2 when new oil & gas upstream projects are defined as oil & gas upstream projects that received their Final Investment Decision after December 31st, 2021/a later date. Penalty -1 when the policy does not apply to all the lines of business* of/all risks covered by the insurer. [For reinsurers/insurers with reinsurance activities] Penalty -1 when the restrictions do not apply to reinsurance treaties. Penalties do not apply below score 1. *By all lines of business, we refer to:
- P&C (Property & Casualty)
- Engineering Lines (Construction All Risk – CAR)
- Surety bonds
Remarks
We recommand that exclusion policies targeting companies expanding their oil & gas production be based on the Global Oil & Gas Exit List (GOGEL), and especially on the short-term expansion metric relying on resources under development and field evaluation (in mmboe) per company. This metric allows financial institutions to identify oil and/or gas resources that will come into production in the near future.
Reclaim Finance reserves the right to equate a commitment on expansion to the adoption of low exclusion thresholds for oil and gas production activities in the short term. E.g. a relative threshold of 1% on revenues derived from upstream oil and gas activities (score 3).
Grade PHASE-OUT 0 No policy. 1 “Oil and gas phase-out” or “production plan” is a criterion that can lead to unsystematic sanctions. 2 Adoption of a phase-out strategy for the oil and gas industry, but with weak coverage, unclear scope or inappropriate timeline. 3 Adoption of a phase-out strategy for unconventional oil and gas activities by 2030. 4 Adoption of a phase-out strategy for all upstream oil and gas activities, but only after 2050. 5 Adoption of a phase-out strategy for all upstream activities in the oil and gas sector by 2050. 6 Adoption of a phase-out strategy for all upstream activities in the oil and gas sector by 2040. 7 Adoption of a phase-out strategy for all upstream activities in the oil and gas sector by 2035. 8 Adoption of a phase-out strategy for all upstream activities in the oil and gas sector by 2030. 9 Adoption of a phase-out strategy for all upstream and midstream activities in the oil and gas sector by 2040. 10 Adoption of a phase-out strategy for all upstream and midstream activities in the oil and gas sector by 2030. BONUS / PENALTIES Bonus +1 (+2) if additional commitment to phase out oil and gas-fired power generation activities by 2040 worldwide (and by 2030 in OECD and European countries). [Unconventional] Penalty -1 if phase-out commitment only covers a few unconventional sectors. [For scores between 1 and 8] Penalty -2 if commitment only applies to oil or gas. Penalty -1 when exceptions are minimal, -2 when exceptions are significant. Penalty -1 if the commitment does not apply to all lines of business*. [For reinsurers/insurers with reinsurance activities] Penalty -1 when the restrictions do not apply to reinsurance treaties. Penalties do not apply below score 1. *By all lines of business, we refer to:
- P&C (Property & Casualty)
- Engineering Lines (Construction All Risk – CAR)
- Surety bonds
Remarks
For each level of commitment, we expect the financial institution to have committed to cease financial support for companies developing the new oil and gas projects concerned. For example, the announcement of an unconventional oil and gas phase-out must come with an exclusion of companies developing new unconventional oil and gas resources.
Reclaim Finance reserves the right to equate a long-term commitment with the adoption of robust relative and/or absolute thresholds in the short term:
- – Unconventional thresholds considered as phase-out: a relative threshold of 5% based on a production metric or an absolute threshold of 2 mmboe (score 3);
- – Conventional oil & gas upstream thresholds considered as phase-out: an absolute threshold of 20 mmboe OR a relative threshold of 1% on revenues derived from oil and gas upstream activities (score 6)
- – Conventional oil & gas upstream & midstream thresholds: a relative threshold of 5% oil and gas/fossil fuel share of revenues (score 9).
