Published June 11, 2026

SBTi published the final Corporate Net-Zero Standard V2.0 today, with an effective date of February 1, 2027. This is the most consequential update to the science-based targets framework since its launch — and for companies that buy or plan to buy carbon credits, several key provisions shifted materially between the November 2025 draft and today's final text.

We analyzed the second consultation draft in November 2025. In this piece, we walk through what changed, what stayed the same, and what it means for your carbon market strategy.

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Renamed framework: OER replaces BVCM

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The standard retires the term "Beyond Value Chain Mitigation" (BVCM) and introduces Ongoing Emissions Responsibility (OER) in its place. The concept, voluntary carbon market engagement beyond what's required by a company's science-based target, is the same. The OER framework, however, comes with a more structured recognition program, clearer three-tier architecture, and, from 2035, mandatory requirements for large companies (Category A).

OER operates entirely outside of target compliance. Credits used for OER recognition cannot be double-counted toward near-term or net-zero target progress. This separation is now a formal requirement, not just good practice.

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Change #1: Three recognition tiers for Ongoing Emissions Responsibility (OER)

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What the draft said: Two tiers: Recognized and Leadership.

What the final standard says: Three tiers: Engaged, Advanced, and Leadership.

Ongoing Emissions Responsibility (OER) is a voluntary framework—set to become mandatory for large companies in 2035—that enables organizations to purchase carbon credits to take responsibility for the emissions they continue to generate while transitioning toward net zero.

The new Engaged tier is designed as a low-barrier entry point. It requires companies to support verified mitigation outcomes (or contribute to a contribution budget) equivalent to ≥1% of their total ongoing Scope 1+2+3 emissions. There's no mandated price floor at this tier.

Engaged Tier:

• Coverage required: Total ongoing, Scope 1-3
• Volume: ≥1%
• Price floor: None

Advanced Tier:

• Coverage required: 100% Scope 1 and 2 + enough Scope 3 to reach 10% of total
• Volume: Full Scope 1 and 2 coverage, Scope 3 where necessary
• Price floor: $20/tCO2e (contribution budget route)

Leadership Tier:

• Coverage required: 100% of total ongoing Scope 1-3
• Volume: 100% coverage
• Price floor: $80/tCO2e AND verified mitigation outcomes (both required)

The Leadership tier is actually stricter than the draft proposed. The draft required either a $80/tCO2e carbon price or verified credits covering at least 40% of emissions - a mix-and-match approach. The final standard requires both: the full $80/tCO2e contribution budget and using the contribution budget towards verified mitigation outcomes for 100% of ongoing emissions. 

For buyers with ambitions to achieve Leadership recognition, this means high-quality, ex-post, independently verified credits are non-negotiable.

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Change #2: The NDC double-claiming rule was softened

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This was the most watched issue of the entire V2.0 process.

What the draft said: A hard prohibition. Credits where the host country has claimed the mitigation outcome toward its own Nationally Determined Contribution (NDC) without a corresponding adjustment, also called an ITMO under Article 6 of the Paris Agreement, could not be used for OER recognition or neutralization at net zero. In practice, this would have made the entire EU Carbon Removal Certification Framework (CRCF) ineligible, since EU member states claim certified removals toward EU NDC contributions. 

What the final standard says: Requirement R46.1 converts the prohibition to a recommendation, companies are encouraged to prefer credits with corresponding adjustments, but are not required to. Requirement C46.6 mandates disclosure: companies must report whether the credits they use have corresponding adjustments.

This is a significant, market-softening change. EU CRCF credits, which are expected to become a major near-term supply source for European buyers as the framework matures, remain eligible for use under V2.0. Article 6 instruments are back in scope. The market may still attach a quality premium to credits with corresponding adjustments, and some buyers may choose to only source from that pool, but there is no formal requirement.

This removes a massive source of uncertainty for European buyers. Through CEEZER’s unified operating platform, you can seamlessly source emerging EU CRCF credits and track framework eligibility criteria dynamically at the registry level, keeping your compliance disclosures automated and audit-ready.

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Change #3: Neutralization follows durability, not a fixed formula

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At net zero, companies must neutralize residual emissions — the emissions that remain after applying maximum feasible reductions. The approach to what kinds of removals count for neutralization changed substantially from the draft.

What the draft said: An explicit split derived from IPCC AR6 — roughly 41% long-lived removals / 59% short-lived removals. This gave nature-based solutions (which are generally short-lived) a significant co-equal role with engineered removals.

What the final standard says: A durability-based approach enshrining the like-for-like principle. The rule is:

• Long-lived* GHG emissions must be neutralized with long-lived removals (geological or equivalent storage: DACCS, BECCS, enhanced weathering with permanent storage)
• All other residual emissions can be neutralized with either long-lived or short-lived removals (nature-based solutions remain eligible here)

* Long- and short-lived here refer to the to the atmospheric lifetime of the specific greenhouse gases

For most industrial and commercial companies, the majority of Scope 1 and 2 residuals are CO₂, meaning the dominant neutralization requirement will be long-lived removals. The durability-based approach means the balance will be heavily weighted toward engineered removals for most companies.

This creates a clearer product hierarchy: long-lived engineered removals are the primary vehicle for neutralizing long-lived GHG residuals; nature-based solutions play a complementary role for remaining residuals and are fully eligible for OER recognition.

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What didn't change: The post-2035 mandatory removal requirement

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One of the most structurally important provisions of V2.0 remains: carbon removals become mandatory for Category A companies from 2035.

Category A companies (≥€450M turnover OR ≥1,000 FTEs, or mid-sized companies in high-income countries with large Scope 1 and 2 footprints) must:

• From 2035: support carbon removals equal to ≥1% of ongoing total Scope 1-3 emissions
• Rising linearly to 100% of total ongoing emissions by their net-zero year
• Within that, a phased long-lived removal requirement: 10% of ongoing long-lived GHG emissions in 2035, rising to 100% by the net-zero year

This is not a small signal. It means demand for carbon removals, particularly long-lived engineered removals, will grow as a formal compliance requirement from 2035 onward, not just as a voluntary aspiration. For buyers who want to be ahead of that curve, building removal portfolios now under V2.0's voluntary OER framework is the clear strategic choice.

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Market instruments now count for Scope 3 target implementation

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One provision that hasn't received as much attention: V2.0 introduces a formal implementation hierarchy for Scope 3 target implementation, and explicitly recognizes commodity certificates with chain-of-custody models at the "activity pool level."

This matters for buyers with hard-to-abate Scope 3 categories, particularly purchased goods and services from diffuse supply chains. Where direct supplier-level engagement isn't feasible, companies can now use book-and-claim mechanisms (EACs and SAFc), and other commodity certificates to demonstrate progress on Scope 3 targets — not just as voluntary OER action, but as counting toward the target itself.

The caveat: companies must demonstrate that structural constraints prevent activity-level implementation before falling back to market instruments. But where that demonstration is credible, this opens a meaningful pathway for market-based Scope 3 solutions.

CEEZER is built for multi-asset orchestration. You can manage your climate strategy from a single platform—deploying Energy Attribute Certificates (EACs) for Scope 2 market-based footprints alongside Sustainable Aviation Fuel certificates (SAFc) to address Scope 3 business travel and logistics.

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What this means for your carbon market strategy

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The final V2.0 standard is more workable than the draft on several dimensions: a lower OER entry bar, a larger pool of eligible instruments, and a principled (rather than formulaic) approach to neutralization. At the same time, the Leadership tier became stricter, and the mandatory removal requirement from 2035 remains firmly in place.

For buyers thinking about OER: Start with the Engaged tier. The ≥1% threshold is achievable for most companies with existing procurement budgets. Credits must be verified, ex-post, independently assured, and ring-fenced from your target compliance claims.

For buyers planning for neutralization: Start mapping your residual emissions by GHG type. The share of CO₂ in your residuals determines how much of your neutralization portfolio needs to be long-lived. Engineered removal supply is still growing, but securing it early gives you pricing and sourcing advantages as demand increases post-2035.

For EU-headquartered buyers: The EU CRCF is back on the table. Track the development of the CRCF's registry infrastructure, this framework will produce some of the most visible and politically credible European removal credits over the next few years.

Want to see how SBTi V2.0 shifts your current carbon market strategy? Contact our team for a portfolio health check.

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References:

• SBTi Corporate Net-Zero Standard V2.0, June 2026
• SBTi Corporate Net-Zero Standard V2.0 Executive Summary, June 2026
• CEEZER analysis of the November 2025 second consultation draft