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VCM Series • SBTi Net Zero Standard

SBTi Net Zero Standard V2: From Abatement Only to Abatement Plus Responsibility

The most significant revision to corporate net-zero target setting in a decade. What V2 proposes, why it matters for the voluntary carbon market, and what sustainability teams should be doing now.

By Abhishek Das • 14 min read

10,000+
Companies with validated SBTi targets
100M+
Credits/year minimum demand at Recognised tier
2035
Ongoing emission responsibility becomes mandatory
 

This Standard Is Not Yet Final

This article analyses the second consultation draft of the SBTi Corporate Net Zero Standard V2, published November 2025. The final standard is expected mid-to-late 2026 after Technical Council review and Board of Trustees adoption. Over 900 stakeholders submitted feedback during the second consultation. Key provisions — particularly Ongoing Emission Responsibility thresholds, the avoidance-to-removals timeline, and credit eligibility criteria — may change in the final version. We cover the adoption outlook and contentious areas in Section 2b below.

1

Why V2 Exists: The Problem V1 Couldn’t Solve

The SBTi Corporate Net Zero Standard V1, published in 2021, established the gold standard for corporate climate target setting. Its core premise was uncompromising: companies must reduce at least 90% of their emissions across all scopes before any residual neutralisation can begin. Carbon credits were relegated to a footnote — useful for Beyond Value Chain Mitigation (BVCM), but explicitly not countable toward reduction targets.

That purity had a purpose. It prevented greenwashing, forced companies to prioritise direct abatement, and created a credible floor for climate ambition. But it also created a structural problem: for companies in hard-to-abate supply chains — cement, steel, aviation, agriculture — the 90% reduction threshold was often theoretically achievable but practically unreachable within the required timeframes.

 

The V1 Implementation Gap

Scope 3 paralysis: Companies reporting that 80–95% of their total emissions sit in Scope 3 found the V1 framework offered no viable pathway for emissions they could influence but not directly control.

Validation backlogs: SBTi faced growing demand with limited capacity to validate increasingly complex targets, particularly net-zero submissions.

One-size-fits-all: V1 applied identical requirements to a 200,000-employee multinational and a 500-person mid-cap in a developing economy. The standard didn’t account for capacity, geography, or resource constraints.

Credits sidelined: By treating carbon credits as entirely separate from target achievement, V1 inadvertently suppressed corporate demand for high-quality credits — weakening the very markets that could accelerate abatement in hard-to-reach sectors.

The result was a growing tension between the standard’s scientific rigour and its practical applicability. Companies were committing to targets they couldn’t implement, or worse, quietly abandoning SBTi altogether. V2 is the course correction — an attempt to maintain scientific integrity while acknowledging that purity without pragmatism doesn’t decarbonise the economy.

SBTi released the first consultation draft in March 2025, followed by a second consultation draft in November 2025. The final standard is expected in late 2026, becoming mandatory for all new targets from January 2028.

2

The V2 Architecture: What’s Actually Changing

V2 is not a minor revision. It is a structural redesign of how corporate net-zero targets are set, measured, and recognised. The changes span four interconnected pillars that collectively shift the standard from a single rigid pathway to a modular, tiered framework.

 

Pillar 1: Company Categorisation (A / B / C)

Different rules based on size, geography, and resources

For the first time, SBTi differentiates requirements by company type. Category A covers large and medium enterprises in higher-income countries — the cohort with the most resources and the greatest obligation. Category B targets large enterprises in lower-income countries, while Category C covers SMEs globally.

This tiering is significant: it means the most stringent requirements — particularly around ongoing emission responsibility — fall squarely on the companies best positioned to act. For most readers of this article, that is Category A.

 

Pillar 2: Scope-Specific Target Flexibility

Multiple pathways for each emission scope

Scope 1 now offers three target-setting approaches: linear reduction on a pathway to net-zero, increasing the share of low-carbon activities over time, or implementing Asset Decarbonisation Plans tied to technological readiness. Companies choose the approach that matches their sector and asset profile.

Scope 2 introduces enhanced requirements for Environmental Attribute Certificates (EACs), including new spatial and temporal matching criteria. Companies must demonstrate that the EACs they purchase are geographically and temporally linked to their consumption patterns — tightening the rules on where and when renewable energy claims count.

Scope 3 becomes “focused and flexible.” All Category A companies must set ambitious Scope 3 targets, but V2 opens pragmatic engagement pathways that acknowledge the limits of supply chain control. Near-term targets must cover at least 67% of Scope 3 emissions (where Scope 3 exceeds 40% of total emissions); long-term targets must reach 90% reduction by 2050.

 

Pillar 3: The 90/95 Long-Term Threshold

Deep decarbonisation remains non-negotiable

V2 maintains the fundamental ambition: companies must reduce at least 95% of Scope 1 and 2 emissions and 90% of Scope 3 emissions before their net-zero target year (no later than 2050). The flexibility is in how you get there, not in how far you go.

 

Pillar 4: The Language Shift

Subtle but significant

V1 required companies to “publicly commit to reaching net-zero greenhouse gas emissions by no later than 2050.” V2 shifts this to: “Companies shall set an ambition to transition their operations and value chains to align with the goal to be net-zero by no later than 2050.” The change from “commit to reaching” to “set an ambition to transition” is a recognition that net-zero is a direction of travel, not a binary outcome — and that the journey matters as much as the destination.

 
Draft Status

Adoption Outlook: What’s Likely to Survive — and What May Change

The provisions analysed in this article are drawn from the second consultation draft, not a final standard. Understanding the adoption pathway — and the political dynamics surrounding it — is essential context for any strategic planning.

The Consultation Process

V2 has gone through two public consultation rounds. The first draft was released in March 2025, attracting broad feedback. The second consultation draft followed in November 2025, with over 900 stakeholders submitting responses. This is now with the SBTi Technical Council for review. Once finalised, it goes to the Board of Trustees for formal adoption, with publication expected mid-to-late 2026.

Mar 2025
First consultation draft
 
Nov 2025
Second draft • 900+ responses
 
2026
Technical Council → Board adoption
 
Jan 2028
V2 mandatory for new targets
 

The Backstory: Why This Is Contentious

V2’s journey has not been smooth. In April 2024, the SBTi Board of Trustees released a statement signalling openness to allowing carbon credits within abatement pathways — a sharp departure from V1’s credits-only-for-neutralisation stance. The statement triggered significant backlash, with coverage across the Financial Times, Bloomberg, and the Guardian.

A coalition of over 80 NGOs publicly opposed the move, arguing it risked undermining abatement ambition. SBTi staff members published an open letter calling for Board resignations, and the internal rift became one of the most visible governance crises in climate standard-setting history.

Separately, SBTi commissioned a Carbon Credit Synthesis Report to evaluate risks and opportunities. The report acknowledged that credit markets face quality, permanence, and additionality challenges — while also recognising that well-structured credit use can accelerate climate finance at scale. The second consultation draft reflects these competing pressures.

Likely to Survive

Company categorisation (A/B/C) — Broad consensus that differentiated requirements are necessary for global adoption. Unlikely to be removed.

Scope flexibility framework — Three Scope 1 pathways and focused-and-flexible Scope 3 address long-standing corporate pushback without weakening ambition.

OER as a concept — The shift from voluntary BVCM to structured OER has strong support from both corporate and civil society stakeholders.

95/90 reduction thresholds — Scope 1+2 at 95% and Scope 3 at 90% are carried from V1 and remain the scientific baseline.

May Change in Final Version

OER tier thresholds — The 1% / 40% coverage levels and $20 / $80 carbon price floors are the most debated numbers. Expect adjustment, particularly upward pressure on the Recognised floor.

Avoidance phase-out timeline — The 2035 cut-off for avoidance credits faces pushback from developing-country stakeholders who argue it undervalues NBS and deforestation prevention.

41/59 removal split — The specific ratio of long-lived to short-lived removals at neutralisation is technically derived but could shift based on updated IPCC scenarios or CDR cost trajectory modelling.

Credit eligibility criteria — How “high quality” is defined, which registries are accepted, and alignment with ICVCM Core Carbon Principles are all still being refined.

Climate Decode’s Assessment

The structural architecture of V2 — company categories, scope flexibility, and the OER framework — will almost certainly make it into the final standard. These address real implementation failures from V1 and have broad stakeholder support.

The numbers — tier percentages, carbon price floors, phase-out dates — will move. But the direction of travel is clear: SBTi is building a framework where companies take quantified, priced responsibility for their ongoing emissions. Whether the Recognised floor lands at 1% or 3%, whether avoidance phases out at 2035 or 2037, the fundamental demand signal for high-quality credits is locked in.

Our recommendation: Plan for the framework, not the exact numbers. Build procurement infrastructure now; adjust thresholds when the final standard drops.

3

Ongoing Emission Responsibility: The Engine Room of V2

If Sections 1 and 2 describe the architectural redesign, this section is the engine that makes V2 transformative for the carbon market. SBTi has retired the term “Beyond Value Chain Mitigation” (BVCM) and replaced it with Ongoing Emission Responsibility (OER) — a deliberate rebranding that signals a fundamental change in how carbon credits fit into the net-zero picture.

Under V1, BVCM was a voluntary add-on: companies were “encouraged” to invest in mitigation beyond their value chain, but it carried no weight in target achievement or recognition. Under V2, taking responsibility for ongoing emissions becomes a structured, tiered system that moves from voluntary to mandatory over the next decade.

3a. How the Recognition Tiers Work

Requirement Recognised Tier Leadership Tier
Minimum Coverage ≥1% of ongoing emissions ≥40% of ongoing value chain emissions
Internal Carbon Price USD $20 / tCO₂e minimum USD $80 / tCO₂e minimum
Credit Types (Pre-2035) Any high-quality (avoidance + removals) Any high-quality (avoidance + removals)
Disclosure Annual: volume, type, rationale Annual: volume, type, rationale
Opt-Out Option Companies that choose not to participate must publicly explain their rationale (“comply or explain”)

The $20 vs $80 internal carbon price floor is a defining distinction. At $20/tCO₂e, a company with 10 million tonnes of ongoing emissions would invest $2 million/year at the 1% minimum. At $80/tCO₂e and 40% coverage, that same company would invest $320 million/year — a 160x difference that separates symbolic participation from market-moving commitment.

3b. The Timeline: From Voluntary to Mandatory

Now
Voluntary

Earn Recognised or Leadership badges. Build credit portfolio.

2028
V2 Mandatory

All new targets under V2. OER disclosure required (participate or explain).

2035
Mandatory

Cat. A must participate. Avoidance credits phase out. Removals only.

2035–NZ
Linear Ramp

Scale from starting % to 100% of ongoing emissions covered.

Net Zero
Neutralisation

100% of residual emissions neutralised. 41% long-lived removals.

3c. Avoidance vs Removals: The Phase-Out

This is the detail that will reshape the voluntary carbon market. V2 draws a clear line through the middle of the carbon credit universe:

Pre-2035: Full Flexibility

All high-quality credits accepted

• REDD+ and forest conservation
• Cookstove and energy access projects
• Renewable energy certificates
• Nature-based removals (afforestation, soil carbon)
• Technology removals (DAC, biochar, enhanced weathering)
• Direct investment in mitigation projects

Post-2035: Removals Only

Avoidance credits no longer count

• Nature-based removals (afforestation, reforestation, soil carbon, BECCS)
• Technology-based removals (DAC, biochar, enhanced mineralisation, ocean CDR)

At net-zero neutralisation:
• 41% must be long-lived removals (DAC, biochar, enhanced mineralisation)
• 59% can be short-lived removals or additional long-lived removals

The Bottom Line

The transition from avoidance to removals is the single biggest demand signal the voluntary carbon market has ever received from a standards body. It tells the market: avoidance credits have a shelf life. Companies that build removal portfolios early will be positioned for V2 compliance. Those that wait will face a supply squeeze.

4

Quantifying the Demand: What V2 Means for VCM, NBS & Tech CDR

Most analyses of V2 stop at the policy detail. What sets this section apart is quantification: translating what V2 proposes into concrete demand signals for the voluntary carbon market, nature-based solutions (NBS), and technology-based carbon dioxide removal (Tech CDR).

The Scale of SBTi-Aligned Emissions

10,000+
Companies with validated targets
~40%
of global market capitalisation
>10 Gt
Combined Scope 1+2+3 emissions (CO₂e)
7+ Gt
Scope 3 gap projected by 2030

Demand Modelling: Credits and Capital

If all SBTi-aligned organisations signed up to the Recognised tier at the minimum 1% level, this implies demand for carbon credits totalling approximately 100 million credits per year. For context, the entire voluntary carbon market retired around 160 million credits in 2023.

At the Leadership tier — 40% of ongoing value chain emissions — demand scales to potentially billions of credits per year, a volume the current market cannot supply.

Financial value: MSCI estimates the additional capital flowing into mitigation could reach $19 billion in the near term, rising to $65+ billion by 2030.

What Gets Bought: Three Phases of Demand

Phase 1: Now–2035

NBS Avoidance Dominates

REDD+, mangrove conservation, and cookstove credits dominate on price. Forward-looking companies also start building removal portfolios (afforestation, biochar, early DAC offtakes) to position for the post-2035 transition.

Phase 2: 2035–2045

Removals Transition

NBS removals (afforestation, soil carbon) become the workhorse for the 59% short-lived allocation. Tech CDR (DAC, enhanced weathering, biochar) scales for the 41% long-lived requirement. Offtake agreements signed today will determine supply availability.

Phase 3: Net Zero

Full Neutralisation

100% of residual emissions neutralised. The 41/59 split requires a diversified removal portfolio. DAC at scale, ocean-based CDR, and enhanced mineralisation compete for the long-lived allocation. Current supply is nowhere near these volumes.

The Supply Gap

Current global CDR capacity is approximately 0.01 GtCO₂/year (excluding conventional afforestation). V2’s mandatory removal requirements for 10,000+ companies will demand orders of magnitude more. This creates a massive origination opportunity for removal project developers — and a procurement headache for sustainability teams that delay portfolio construction.

5

What This Means for Your Net Zero Strategy (2025–2028)

V2 doesn’t arrive in 2028 — it arrives in phases, and the preparation window is now. Here is what sustainability leads should be acting on at each stage:

When Action
Now Map your company category (A/B/C). Complete a granular Scope 3 assessment. Determine whether you qualify for Recognised or Leadership tier. Begin due diligence on credit procurement partners and removal offtake agreements.
Late 2026 V2 final standard published. Review final OER requirements. Update internal carbon price and budget for credit procurement. Align with VCMI Claims Code for complementary positioning.
2027 Last year to validate under V1.3. Make a strategic decision: lock in a V1.3 target now, or wait for V2 flexibility. For most companies with complex Scope 3, V2 will be more practical.
Jan 2028 V2 mandatory for all new targets. OER disclosure required: participate and report, or publicly explain why not. Early movers with established credit portfolios gain competitive and reputational advantage.
2030 Scope 3 gap projected at 7+ GtCO₂e. Credit prices likely rising as demand outpaces supply. Companies with long-term offtake agreements for removals are insulated. Those buying spot will face premium pricing.
2035 OER mandatory for all Category A companies. Avoidance credit phase-out begins. You need an established removal pipeline — NBS for the 59% short-lived allocation, Tech CDR for the 41% long-lived requirement.

Related: EACs & Book and Claim

V2’s supply-shed EAC rules directly validate emerging frameworks like the RMI/GMA Book and Claim framework for cement and concrete. If your Scope 3 includes hard-to-abate materials, EACs could become a critical component of your V2 strategy alongside carbon credits and removals.

6

Canopy: Calculate. Curate. Procure. Report.

V2 creates a structured demand for carbon credits and removals. But demand without procurement infrastructure is just a target on paper. Once your Scope 3 assessment is complete and your OER tier is determined, you need an end-to-end system that takes you from residual calculation through to audited retirement — not another spreadsheet.

Climate Decode’s Canopy is an AI-powered residual emission procurement platform built for exactly this challenge — replacing fragmented workflows with a single, auditable workspace for managing the last 20%.

Built for Sustainability, Procurement, and Reporting teams, Canopy saves hundreds of hours on residual management — from AI-curated procurement of offsets, RECs, EACs, and removals to audit-ready compliance reporting that protects your reputation. Here is the full journey:

1
Calculate
2
Curate
3
RFQ
4
Optimise
5
Procure
6
Report
1

Residual Calculation

Quantify What Compliance Doesn’t Cover

Calculate your residual emissions at corporate, product, or customer level across Scope 1+2+3. Set neutralisation targets, benchmark against peers, and choose your procurement strategy — Spot or Multi-Year. SBTi V2 OER tier alignment, VCMI Claims Code, and regulatory standard updates built in. Inventory snapshot and red flag alerts keep your team ahead of target drift.

2

AI Curator

Discover & Shortlist the Right Instruments

Canopy’s AI Curator matches your residual profile with curated offsets, SAF credits, RECs, and EACs — ranked by value chain relevance, geography, quality rating, and peer alignment. Smart filters for country, type, price, vintage, and rating. Match scoring with quality, durability, and SBTi/VCMI badges. Policy guardrails and saved procurement policies ensure you only shortlist what meets your standards. Filter by avoidance, NBS removals, or Tech CDR to position for the 2035 transition.

3

RFQ Builder

Send RFQs. Compare Quotes. Move Fast.

Send Requests for Quotes directly to project developers and suppliers from your shortlist. Track RFQ responses with price and validity windows. Compare developer quotes side-by-side. Keep your procurement cycle on track — all from one workspace. No more days chasing limited bidders through brokers or navigating complex evaluations in unknown jurisdictions. Get best market price without intermediaries.

4

Portfolio Optimisation

Build the Optimal Portfolio for Your Target & Budget

Choose from AI-generated portfolio strategies — High Quality, Removals-focused, Balanced, or Cost Effective — each with full project-level detail, budget awareness, and inventory integration. Target, budget, and inventory-aware optimisation with within-budget / over-budget visibility. The 41/59 long-lived vs short-lived removal split for V2 compliance is factored into every strategy. Generate POs directly in Ariba or Coupa.

5

Procurement Management

End-to-End Procurement. Spot & Multi-Year.

Track every procurement stage — PO, invoicing, counter-PO, supplier payment, credit delivery, and retirement. Supports both Spot and Multi-Year contract structures with Client ↔ Climate Decode ↔ Supplier tracking. Credit transfer options: retire, hold in custody, or transfer. Ariba and Coupa sync ensures your procurement system of record stays current throughout the entire pipeline.

6

Reporting & Compliance

Audit-Ready Reports. Verified Claims.

Generate structured compliance reports for CSRD, AB1305, and VCMI disclosures. Maintain a full inventory ledger of offsets, RECs, and EACs with retirement status, permanence classification (short-lived vs long-lived), and OER tier tracking. Build your project impact library for CSR storytelling. Push data directly to CDP Portal, Ariba ESG, and Coupa Climate Suite. Verified claims, not just promises.

 

Sustainability Teams

Planning, benchmarking, and pre-vetted instruments aligned to your target guidance — at competitive prices.

 

Procurement Teams

Best market price, no intermediaries. No more chasing brokers or navigating unfamiliar jurisdictions.

 

Reporting & Compliance

Audit-ready exports for CSRD, AB1305, VCMI, and CORSIA. Full ledger and CDP Portal push in clicks.

Platform + Expertise

Canopy works seamlessly with Climate Decode’s advisory team. From target setting and residual strategy through procurement, due diligence, and reporting across CORSIA, TNFD, and SBTi FLAG — your advisory team works directly alongside the platform. Canopy’s AI handles discovery and optimisation; our experts handle the nuance and relationships.

V2 Readiness Starts with Infrastructure

The companies that build their residual emission procurement infrastructure now — before V2 becomes mandatory in 2028 — will secure the best pricing on removal offtakes, establish relationships with high-quality project developers, and enter the mandatory OER era with portfolios that meet both Recognised and Leadership tier requirements.

References

SBTi, Corporate Net Zero Standard V2 Second Consultation Draft, November 2025. SBTi, 10,000 Company Validations Milestone, January 2026. IETA & AlliedOffsets, Scope 3 Emissions Gap Analysis. MSCI, Carbon Credit Market Demand Projections. BeZero Carbon, SBTi Corporate Net-Zero Standard 2.0: What Does It Really Mean for the Carbon Credit Market? Climate Impact Partners, Navigating the SBTi’s Proposed Net-Zero Revisions. Planet2050, SBTi Net-Zero Standard V2: Key Changes & New Removal Requirements.

Ready to Build Your SBTi V2 Procurement Strategy?

Climate Decode’s Canopy is an AI-powered residual emission procurement platform that helps organisations manage the last 20% — from calculating residual emissions and curating credits, EACs, and RECs, to portfolio optimisation and audit-ready compliance reporting aligned with SBTi V2, VCMI, and CSRD.

Get in Touch →
Abhishek Das — Climate Decode, VCM Series, SBTi Net Zero Standard V2

About the Author

Abhishek Das

Climate Decode

Abhishek works on Climate Decode’s voluntary carbon markets and residual emission procurement strategy, bridging corporate net-zero target setting with emerging carbon credit and EAC frameworks.

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