Purpose

The purpose of this paper is to explore how, in unpredictable policy environments, specific managerial choices play a vital role in designing lobbying capabilities through the choice of levels of investment in human capital, network relationships and structural modification.

Design/methodology/approach

Using an inductive case study approach, data were collected through 42 in‐depth, semi‐structured interviews and documented archival data. Cross‐case pattern sequencing was used to construct an interpretive model of lobbying capability design. Data were framed by the dynamic resource‐based theory of the firm.

Findings

Heterogeneous lobbying capabilities are adapted differently in private and state‐owned airlines as a result of diverse ownership structures and time compositions that interplay with organizational processes. The result is a divergence between private‐ and state‐owned airlines in how they engage with governmental actors and policies.

Research limitations/implications

The paper contributes to ongoing discourse in and between the dynamic capabilities and corporate political activity literatures, particularly on how state/non‐state‐owned airlines design their political lobbying capabilities. The research is limited in so far as it only studies the European airline industry.

Originality/value

The paper illustrates how a specific and far‐reaching unanticipated external policy stimulus (the 9/11 terrorist attacks) impacted on management choices for lobbying design in the European airline industry.