Opportunity Green has filed an unprecedented complaint under the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, arguing that Europe’s largest steel producer, ArcelorMittal, is failing to address its climate impact.

Climate change NGO Opportunity Green has filed Europe’s first climate-related complaint in the steel sector to the Luxembourg National Contact Point (NCP) under the OECD Guidelines, with support from SteelWatch, BankTrack and Ecologistas en Acción. It requests that steel giant ArcelorMittal publish a revised climate action strategy to address its ongoing climate impact.

The complaint raises significant concerns for financial institutions exposed to the company, including BBVA, ING Group, JPMorgan Chase, Société Générale, BNP Paribas, and Crédit Agricole, who supported ArcelorMittal to raise new, unconditional finance in September 2025. 

ArcelorMittal is the world’s second-largest steelmaker – but around 75% of its steel is still produced using coal. It is also the largest steel client of the global banking sector, having received USD 13.1 billion in bank finance between 2016 and June 2024 – more than any other steelmaker in the world including the world's largest steelmaker Baowu. 

Nearly all of ArcelorMittal’s financiers have commitments to decarbonise their steel portfolios, including adopting requirements for clients to have credible climate transition plans, and follow the OECD Guidelines. The complaint highlights ArcelorMittal’s lack of a robust, science-based climate strategy and outlines how it is failing to take adequate action to reduce its emissions at the pace and scale required to adhere to the 1.5ºC global temperature limit. Opportunity Green argues that this contravenes the OECD Guidelines, which expect multinational enterprises to adopt – and fundamentally, to implement – science-based targets and strategies consistent with international climate commitments.

Despite indicating on several occasions that a revised climate strategy would be published in 2024, the steelmaker has not published a new version of its climate strategy since July 2021, citing policy uncertainty as a reason. But in the face of an undeniable climate emergency, waiting for a ‘settled’ policy environment is not any justification for not meeting expectations under the OECD Guidelines.

Julia Hovenier, Banks and steel lead at BankTrack says: “This complaint shows ArcelorMittal’s financiers that they cannot continue writing blank cheques to a company that’s been sitting on its hands since 2021 when it comes to climate action. It’s long past time that ArcelorMittal lives up to its responsibilities, starting with following the OECD guidelines.”

Kirsty Mitchell, Legal Manager at Opportunity Green says: “If ArcelorMittal is going to live up to its promise of achieving net zero emissions by 2050, it needs to take decisive, transformative action right now. Instead, the company is signalling a retreat from action and a lack of strategic clarity – with alarming knock-on effects for the climate and communities. By bringing this complaint, we hope to engage with ArcelorMittal on the actions it must take to address its climate impacts in line with the OECD Guidelines, and demonstrate that the company – and the wider industry – are accountable for climate action.”

Notes to editors

Read the legal complaint in full here.

• The complaint, also known as a ‘specific instance’, is being filed by Opportunity Green against ArcelorMittal to the Luxembourg National Contact Point (NCP) pursuant to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines).
• The OECD Guidelines are endorsed by OECD governments and set non-binding expectations for multinational corporates across a range of issues, including the environment, climate change and human rights. To ensure the guidelines are adhered to, governments establish a non-judicial body called a National Contact Point to promote the OECD Guidelines and handle complaints about harmful business activity in contravention of the OECD Guidelines. Civil society can file complaints to NCPs when companies fall below the standards expected if they have an ‘interest’ in the matter.
• In short, Opportunity Green’s complaint submits that the targets, strategies and actions undertaken by ArcelorMittal to address its adverse climate impact fall short of the expectations set out in Guidelines A.12 of Chapter II (General Policies), Guidelines 1(b), 1(c), 1d, and 5(b) of Chapter VI (Environment) and Guidelines 1 and 2 of Chapter IV (Human Rights).
• The complaint is being filed with the support of SteelWatch, BankTrack, and Ecologistas en Acción.
• The NCP will now assess the complaint and decide whether it is admissible based on a set of criteria in the OECD Guidelines. This initial assessment normally takes up to three months. If the NCP accepts the complaint, it will offer its ‘good offices’ to contribute to the resolution of the alleged issues, typically through mediation.

Opportunity Green is an NGO working to unlock the opportunities from tackling climate change using law, economics, and policy. We do this by amplifying diverse voices, forging ambitious collaborations and using legal innovation to motivate decision makers and achieve climate justice.