Response to the SBTi's Corporate Net-Zero Standard Version 2.0 — Second Public Consultation Draft

The Nature+ Coalition welcomes the updated draft of the SBTi Corporate Net-Zero Standard and many of its core orientations: linking short-term and long-term action, a recognition mechanism for early movers that have already taken voluntary action on ongoing emissions, and corporate transparency. Together they raise the ambition of corporate climate trajectories and better recognise the efforts companies undertake, while keeping the standard science-driven, actionable and operational for economic stakeholders.

In brief: four recommendations

1. Advance to 2030 the mandatory timeline for compensating residual emissions (type-A companies) and add mandatory interim targets to transition plans.
2. Recognise nature-based carbon removals as long-lived storage when the risk of reversal is mitigated.
3. Account carbon credits only when they meet the ICVCM Core Carbon Principles.
4. Stop treating credits counted in a national NDC and used in a corporate net-zero path as double counting.

1. Advance the compensation timeline for residual emissions and add interim targets

We welcome the recognition mechanism for companies already committed to voluntary action on ongoing emissions, whether through carbon credits or "supplementary climate contributions". We question, however, the timeline for making it mandatory (2035 for type-A companies) and suggest advancing it to 2030: carbon removal projects take time to identify and develop, especially those with the highest quality standards.

A 2030 target would also give companies a more progressive trajectory towards net zero by 2050, and thus more credible, Paris-aligned pathways. This position is shared by many companies and business alliances, including the World Business Council for Sustainable Development. We further recommend mandatory interim targets (2035, 2040, and so on) in the upcoming transition-plan requirements.

2. Recognise nature-based removals as long-lived storage

The draft acknowledges, in its post-2035 requirements, that engineered removals ("long-lived carbon storage") and nature-based removals must coexist, but marks the latter as "shorter-lived". The coalition suggests that nature-based removals be recognised as long-lived when the risk of reversal is mitigated, putting both types on an equal footing, because:

• SBTi acknowledges that both types of removals are needed now and beyond 2050, yet its current wording creates a de facto hierarchy between them;
• engineered removals can also release carbon in case of disturbance, a risk SBTi itself recognises ("actual permanence may be affected by human or natural disturbances. This applies even to storage types with high durability potential"), while nature-based removals can store carbon for centuries when appropriate permanence safeguards are in place (buffer pools, insurance mechanisms).

Nature-based removals are also available today and more financially accessible: small and medium companies with smaller budgets can finance them more readily. The standard should therefore endorse Nature-based Solutions more strongly.

3. Account credits only when they meet the ICVCM Core Carbon Principles

We welcome the draft's recognition of the central role of carbon credits, including those generated by NbS, on the path to net zero. Yet many companies remain hesitant to engage in carbon markets because of concerns about integrity and greenwashing. To boost confidence and corporate climate action, SBTi should set minimum quality requirements: the coalition suggests the ICVCM Core Carbon Principles as the minimum requirement guaranteeing the environmental impact of the credits accounted.

4. NDC co-claiming is not double counting

Paragraph C29.6 stipulates that "removals used for neutralization shall not be simultaneously claimed by another entity for compliance or NDC accounting purposes. Where removals are authorized for use under Article 6 of the Paris Agreement, a corresponding adjustment by the host country shall be demonstrated. In the absence of such adjustment, the activity may only be reported as a contribution under the Ongoing Emissions Responsibility recognition framework, not as neutralization".

The Nature+ Coalition maintains that carbon credits counted in a Nationally Determined Contribution (NDC) while used in a company's net-zero trajectory should not be considered double counting. Double claiming (a contribution to an NDC and corporate neutralisation) is legitimate: voluntary corporate action and national climate targets already coexist and reinforce one another. All emission reductions by private stakeholders are co-claimed today, since a company reducing its footprint contributes both to its corporate target and to its host country's national inventory. The same principle should apply to carbon removal activities. Moreover:

• Article 6 of the Paris Agreement considers that double counting only occurs when two countries, or a country and CORSIA, register the same carbon credit; corporate purchases are not counted;
• such a rule would de facto exclude corporate engagement from publicly recognised carbon removal frameworks such as the EU CRCF, which have been designed primarily to be accounted within NDCs.

The Nature+ Coalition's members remain at the disposal of SBTi's standards team to discuss these recommendations further.

Who we are

The Nature+ Coalition is an international association that gathers the voices of organisations committed to the conservation, protection and restoration of natural ecosystems across the whole value chain: field operators, project developers, financial intermediaries, investors, corporates and other non-governmental stakeholders. Its members promote high-integrity Nature-based Solutions that address climate change (mitigation and adaptation), biodiversity protection and socioeconomic development at the same time. Join the coalition.