ABSTRACTHow have petroleum and power companies and their European industry associations responded to the EU emissions trading system (ETS)? Responses can be political, directed externally towards the initiation and reforms of the EU ETS itself, or internally and market-based, directed at low-carbon solutions. Proactive response strategies shape companies’ leadership potential. Variation in responses is explained by two models that differ in assumptions about corporate behaviour as well as the wider multilevel regulatory context in which companies operate. Responses are found to have converged within the two industries, with reactive companies following the proactive ones. Secondly, responses between the two industries increasingly diverge, with the power industry becoming much more proactive than the petroleum industry. The main explanation is found in the differing relevance of the two models and the wider regulatory context, particularly differing exposure to international competition and weak international climate agreements.