In our first post in this series, we documented how ExxonMobil Chairman and CEO Darren Woods spent years lobbying to preserve the Paris Agreement — the policy architecture that justified the company’s multi-billion-dollar low-carbon investment program.
In our second post, we showed how Woods acquired Denbury Inc. for $4.9 billion to build the largest CO2 pipeline network in the United States, financed the buildout in part with taxpayer dollars, and is now lobbying for government carbon intensity mandates that would require his industrial customers to pipe their emissions into ExxonMobil’s network.
This post is about the next layer of that same strategy — one that is more ambitious in scope and more revealing about how Woods actually thinks about ExxonMobil’s commercial future.
It involves a new global coalition called Carbon Measures, which ExxonMobil helped found in October 2025 to reshape how carbon emissions are measured and reported worldwide. On its surface, Carbon Measures is a technical accounting initiative. Underneath, it is a lobbying vehicle designed to get governments around the world to adopt the specific policy framework — product-level carbon intensity standards — that would make ExxonMobil’s CCS infrastructure commercially indispensable to every major industrial company on the Gulf Coast and beyond.
ExxonMobil is not just building a carbon tollroad and asking Washington for mandates to send traffic down it. It is now working to rewrite the global accounting rules so that the traffic has nowhere else to go.
What Carbon Measures Is
On October 20, 2025, a coalition of 19 major companies launched Carbon Measures with ExxonMobil, BlackRock‘s Global Infrastructure Partners, BASF, Nucor Steel, Linde, Mitsui, NextEra Energy, Honeywell, and CF Industries among the founding members. The coalition is led by Amy Brachio, former Global Vice Chair for Sustainability at EY, and has the formal backing of the International Chamber of Commerce, which assembled a technical expert panel to develop the new framework.
The stated purpose is to build a “ledger-based” carbon accounting system — modeled on financial accounting — that tracks carbon emissions as a liability attached to each product as it moves through the supply chain. The coalition says its goal is to eliminate double-counting in emissions reporting and enable more precise measurement of the carbon intensity of specific industrial products: steel, cement, electricity, fuel, and chemicals.
But Carbon Measures is not merely a measurement project. It is explicitly a policy lobbying vehicle. The coalition’s own materials state that it “will also advocate for policies that support emissions reductions and push for carbon intensity standards that governments could use to set corporate policies.” This is the sentence that matters. Carbon Measures is not simply proposing a new accounting methodology for voluntary corporate use. It is organizing major global companies to press governments worldwide to adopt carbon intensity standards as regulatory policy.
Those standards — if adopted — would require industrial companies to demonstrate that the products they sell meet government-mandated carbon intensity thresholds. The most commercially available mechanism for doing so, in the Gulf Coast industrial corridor, is carbon capture and storage.
ExxonMobil’s Stated Position
This is not inference. ExxonMobil has said it explicitly and repeatedly.
The company’s own policy advocacy page states: “To achieve a lower-emissions future, government GHG policy should set carbon-intensity standards on products. We believe this is the best way to engage the collective efforts of industry and leverage competitive market forces.” Its published lobbying disclosures state that the company “advocates for a carbon intensity-based fuel standard” and supports “policies that encourage the use of CCS” — policies that would require industrial manufacturers and fuel producers to meet government-mandated carbon intensity thresholds, with CCS as the primary compliance tool.
Woods put it plainly at the Carbon Measures launch: “If you can’t measure it, you can’t manage it. The first step to reducing global emissions is to know where they’re coming from — and today, we don’t have an accurate system to do this.”
The accounting framework Carbon Measures is building is designed to provide exactly the measurement foundation that carbon intensity regulations require. ExxonMobil’s policy page acknowledges the connection directly, stating that carbon intensity standards “must be underpinned by a well-designed carbon emissions accounting framework that reliably tracks CO2 emissions” — and that Carbon Measures is precisely the effort to build that framework.
In short: ExxonMobil wants new government regulations. It is simultaneously building the global accounting infrastructure to make those regulations technically feasible. And it has already constructed the physical infrastructure — the pipelines, the storage sites, the commercial agreements — to be the primary large-scale beneficiary when those regulations are enacted.
The Complete Picture
Image created with Nano Banana AI.
Read together, the three posts in this series describe a single integrated strategy with three mutually reinforcing components.
First, ExxonMobil spent years lobbying to preserve and extend the Paris Agreement climate architecture — the framework of government commitments that justified the company’s low-carbon investment program and secured federal subsidies. Second, it spent $4.9 billion acquiring Denbury to build the largest CO2 pipeline network in the United States, and pursued a $331 million federal grant for its Baytown hydrogen project — later cancelled by the Trump administration — while lobbying for the carbon intensity mandates that would fill those pipelines with paying customers. Third, it co-founded a global coalition to establish the carbon accounting framework that makes those intensity standards technically operable at the international level.
Each component reinforces the others. The Paris architecture provides the political pressure for national governments to act on emissions. The carbon intensity standards provide the regulatory mechanism. The accounting framework provides the measurement infrastructure those standards require. And ExxonMobil’s Gulf Coast pipeline network is the only infrastructure operating at commercial scale today to serve the customers those standards would compel.
This is what government-dependent corporate strategy looks like when it is operating at full scale: not a company seeking to compete on the merits in a free market, but a company working to engineer the regulatory environment so that the market has no alternative but to route through its assets.
NLPC has been consistent: we oppose government-mandated carbon schemes in all their forms, including the carbon intensity standards and accounting frameworks ExxonMobil is working to create. The irony is that ExxonMobil — whose CEO publicly questioned what “drill, baby, drill” meant as national policy — has become one of the most aggressive corporate advocates for new government carbon regulation in the world, because the regulations it is lobbying for happen to require the infrastructure it already owns.
What Shareholders Should Know
NLPC has filed a shareholder proposal for ExxonMobil’s 2026 annual meeting calling for separation of the Chairman and CEO roles. The Carbon Measures story is a direct illustration of why that separation matters.
Darren Woods is simultaneously the CEO who committed $4.9 billion to CCS infrastructure, the lobbyist who advocates for the government carbon intensity standards that would require customers to use it, the co-founder of the global coalition building the accounting framework those standards depend on — and the board chairman responsible for independently evaluating whether any of this serves shareholders’ long-term interests. That is not independent oversight. It is one person constructing a strategy, lobbying to impose it on the broader economy through government mandate, and sitting in judgment of his own work.
ExxonMobil shareholders deserve a board chair who is not also the architect of the strategy being scrutinized — one who can ask plainly whether Woods is building the company’s future or using its balance sheet to lobby the world’s governments into building it for him.
(Image above created via NanoBanana AI).
