Enel SpA

Enel's claim to "exit gas retail by 2040" and achieve "100% sales from GHG free sources by 2040" is directionally supported by substantial documented progress: an SBTi 1.5°C validation, a TPI Level 4 Strategic management rating, a 72% coal-fleet retirement/cancellation rate, and — critically — an explicit no-offsets policy that satisfies the strongest substantiation standard under the EmpCo Directive.

However, this progress sits in direct tension with three independent, high-confidence sources documenting active fossil fuel expansion. GOGEL classifies Enel as actively expanding oil and gas capacity with confirmed LNG expansion. EGT identifies the Porto Empedocle LNG Terminal as an asset in active development — infrastructure that typically locks in 40+ years of fossil demand, difficult to square with a full gas-retail exit inside 15 years. GOGET documents 12 O&G extraction fields, including one pre-FID field in Algeria, indicating continued upstream commitment rather than wind-down.

The claim's substantiation also contains genuine gaps: no disclosed 2035 interim checkpoint, no certified permanent carbon removal plan, and no verified transition plan for handling residual emissions at the 2040 target date. These gaps, combined with the fossil-expansion evidence, mean the "100% GHG-free sales" claim overstates the certainty of a full transition while the company simultaneously develops new gas infrastructure. This is not confirmed greenwashing — the supporting evidence base is too substantial and LobbyMap shows neutral engagement (B-, not the obstructive D/D+ band) — but it is a claim that exaggerates transition certainty. This is the first Prasine assessment of this specific claim; it is not a repeat.

(b) Green Claims Directive (enforcement from September 2026): This claim would require independent third-party verification under the GCD's mandatory substantiation regime. As currently disclosed, the claim would likely fail GCD scrutiny: the absence of a certified residual-emissions plan and the unreconciled tension with GOGEL/EGT/GOGET fossil-expansion data would not withstand an independent verifier's assessment of a "100% GHG-free by 2040" absolute claim.

Under UCPD Article 11 (as amended by the EmpCo Directive, EU 2024/825), this claim is subject to enforcement by national consumer protection authorities. Complaints may be filed with the Autorità Garante della Concorrenza e del Mercato (AGCM), Italy's national consumer protection authority, given Enel's headquarters location.