We appreciate the significant progress reflected in the latest updates to the SBTi’s Corporate Net-Zero Standard (v2). The SBTi has listened to feedback, and the working groups have incorporated important improvements. In particular, we welcome:
- The explicit recognition of carbon credits as a critical tool on the pathway to net zero-complementary to emissions reductions, not competing.
- Acknowledging a role for both avoidance and removal credits, reflecting the reality of what is needed to deliver climate impact at scale.
- Future mandatory responsibility for ongoing emissions on the pathway to net zero - ensuring companies act on what they cannot yet abate.
- Creating a claims structure that gives corporates recognition for taking responsibility today.
- Understanding the positive impact of nature today and its role in long-term sustainability strategies, even as more durable removals become available.
At Climate Impact Partners, we believe there is no credible pathway to net zero without the use of high-quality carbon credits. They are a critical component of global climate action, working hand in hand with deep decarbonization to deliver meaningful impact.
Below, we outline key recommendations to improve the draft standard and ensure companies can meet their net-zero commitments in a way that is both ambitious and achievable:
Introduce an Additional Tier Between Recognition and Leadership
The current two-tier system creates a gap:
- Recognition tier (1%) is achievable but may not stretch ambition for some sectors, especially those with a lower carbon-intensity.
- Leadership tier is highly aspirational and a strong north star but, for most companies, an $80 carbon price and covering 40% of emissions with carbon credits is out of reach. This could inadvertently discourage ambitious climate action because companies doing more than the recognition tier but less than leadership may reduce their action down.
We propose a middle tier that:
- Pushes companies beyond basic action without being unattainable.
- Accounts for sectoral differences and emissions intensity (e.g., manufacturing vs. professional services).
- Encourages broader participation and avoids creating an “elite-only” category.
- A reasonable percentage of emissions to cover with carbon credits for a middle tier could be 10% and 50%, aligned with the VCMI’s Claims Code of Practice.
Align with Existing Standards and Frameworks
SBTi must make it clear to corporates how its standard aligns with other leading frameworks – there should be no ambiguity. Rather than creating any competing rules and structures it should leverage and align with established frameworks such as the GHG Protocol (e.g. accounting rules, application of EACs), VCMI (e.g. percentage of emissions to cover with carbon credits), and RE100 (e.g. application of EACs).
Corporates already navigate multiple standards, and adding new, divergent requirements risks complexity and slows action. Alignment will:
- Simplify compliance for companies.
- Ensure consistency across global climate frameworks.
- Avoid duplication and confusion in reporting and assurance.
- Enable carbon markets to scale rapidly and ensure improved transparency and high quality.
Ensure Feasibility and Avoid Unintended Barriers
Mandatory requirements must not discourage companies from engaging. Key considerations:
- Assurance: Current auditor-led verification is costly and impractical for smaller companies. Scalable solutions - such as consultant-reviewed letters -can maintain integrity without excessive burden.
- Minimum thresholds for carbon credit use from 2035: The threshold should be meaningful but achievable, ensuring companies are incentivized rather than excluded. This could include sector specific requirements so that those which are more carbon intensive, e.g. manufacturing, have more realistic routes to net zero.
- Phase-in approach: Allow time for companies to adapt to new requirements without jeopardizing participation.
Reflecting on COP30, the message from governments, businesses, and civil society was clear - now is the time for delivery. The SBTi is uniquely positioned to make this happen. It is trusted by thousands of corporates worldwide and sets a benchmark for credible climate ambition. If SBTi can demonstrate that its Corporate Net-Zero Standard creates a pathway that is both actionable and impactful, its influence will only grow - mobilizing greater investment, innovation, and collaboration across the private sector.
