Between Compliance and Commitment: A Temporal Critical Discourse Analysis of How National and International Oil Companies Respond to Evolving Climate-Related ESG Regulations in Their Public Disclosures, 2016–2026
Main Article Content
Over the decade from the Paris Agreement to the EU Omnibus I deregulation, the regulatory landscape for corporate climate disclosure has shifted from voluntary frameworks toward mandatory reporting, before partially reversing. Yet how National Oil Companies (NOCs) and International Oil Companies (IOCs) have responded to these evolving demands remains underexplored. This research employed longitudinal hybrid Critical Discourse Analysis and thematic content analysis on 176 reports from sixteen NOCs and IOCs across four regions (2016–2026 Q1). Guided by regulatory-response theory, legitimacy theory, and institutional logics, it examines how NOC and IOC disclosures diverged or converged in response to successive regulatory regimes and what discursive strategies were employed. Findings reveal three key patterns. First, European IOCs rapidly adopted TCFD/ISSB frameworks, with "net-zero" rhetoric increasing 340%, while NOCs showed only 120% increase. Second, following Omnibus I, European IOCs immediately reduced Scope 3 details and removed sectoral ESRS references, confirming that regulatory pressure drives symbolic compliance rather than substantive commitment. Third, the talk-walk gap persists across all companies, with average low-carbon capital expenditure at 18% for IOCs and only 4% for NOCs. NOCs in the Middle East exhibited the widest gap between rhetoric and investment action. This research fills a clear gap: no peer-reviewed qualitative study has conducted a temporal NOC-versus-IOC comparison across multiple regions spanning the full Paris-to-Omnibus-I arc. The findings contribute to corporate sustainability disclosure, energy governance, and ESG regulation literatures, with implications for policymakers and investors evaluating the credibility of oil and gas companies' energy-transition commitments.
Al-Mana, A. A., Nawaz, W., Kamal, A., & Koç, M. (2020). Financial and operational efficiencies of national and international oil companies: An empirical investigation. Resources Policy, 68, 101701.
Alsaid, L. A. Z. A., & Alyousef, M. A. (2026). Reframing climate governance: How an internal audit makes smart-city resilience enforceable in an Egyptian state-owned enterprise. Sustainability, 18(7), 3610.
Andreasson, S. (2026). International oil companies, petrocultures and the transatlantic divide: A review of engagement with the energy transition and the future of oil and gas. Energy Research & Social Science, 135, 104668.
Aronczyk, M., McCurdy, P., & Russill, C. (2024). Greenwashing, net-zero, and the oil sands in Canada: The case of Pathways Alliance. Energy Research & Social Science, 112, 103502.
Carbon Tracker Initiative. (2023). National oil companies and the energy transition: Are NOCs prepared for a low-carbon future? https://carbontracker.org/
Dongo, D. F., Relvas, S., & Azevedo, D. P. (2025). A comparative study between international oil companies (IOCs) and national oil companies (NOCs) in relation to their energy transition strategies. SPE Energy Transition Symposium, D021S010R002.
Ebert, K., Gamazaychikov, B., Hacker, P., & Luccioni, S. (2026). The global landscape of environmental AI regulation: From the cost of reasoning to a right to Green AI (arXiv Preprint No. arXiv:2603.00068).
Edelman, L. B. (1992). Legal ambiguity and symbolic structures: Organizational mediation of civil rights law. American Journal of Sociology, 97(6), 1531–1576.
Gray, S. J., Hellman, N., & Ivanova, M. N. (2019). Extractive industries reporting: A review of accounting challenges and the research literature. Abacus, 55(1), 42–91.
Heller, P., & Mihalyi, D. (2019). Giant, not green: The challenge of national oil companies in the energy transition. Natural Resource Governance Institute. https://resourcegovernance.org/
Herzog-Hawelka, J., & Gupta, J. (2023). The role of (multi)national oil and gas companies in leaving fossil fuels underground: A systematic literature review. Energy Research & Social Science, 103, 103194.
International Energy Agency. (2023). World energy outlook 2023. IEA.
International Energy Agency. (2024). World energy investment 2024. IEA. https://www.iea.org/reports/world-energy-investment-2024
Megura, M., & Gunderson, R. (2022). Better poison is the cure? Critically examining fossil fuel companies, climate change framing, and corporate sustainability reports. Energy Research & Social Science, 85, 102388.
Nowiski, N. (2018). Rising above the storm: Climate risk disclosure and its current and future relevance to the energy sector. Energy Law Journal, 39(1), 1–46.
United Nations Framework Convention on Climate Change. (2015). The Paris Agreement.
Van de Graaf, T., & Colgan, J. D. (2017). Global energy governance: A review and research agenda. Palgrave Communications, 3, Article 17047. https://doi.org/10.1057/palcomms.2017.47
Vizcarra, H. (2019). Climate-related disclosure and litigation risk in the oil & gas industry: Will state attorneys general investigations impede the drive for more expansive disclosures?
Wang, Q., & Cheng, W. (2025). Climate discourses of petroleum corporations in China and the United States: A comparative stakeholder analysis. English for Specific Purposes, 80, 44–60.
World Benchmarking Alliance. (2023). Assessing national oil companies' transition plans: An essential tool for banks, investors, and regulators.
Zaczyk, M., & Semrau, J. (2026). Blockchain technology for ESG transparency and sustainability reporting in supply chains: A systematic literature review. Sustainability, 18(10), 4877.
