
The Science Based Targets initiative (SBTi) just published its updated Corporate Net Zero Standard. This is a big deal: the standard is the world’s most influential rubber stamp for corporate climate claims. At ASL, we’ve been urging the SBTi to cut greenwashing loopholes out of the standard. But five major weaknesses in the final version make it easier for companies to keep the SBTi accreditation while missing their climate targets.
Our briefing digs into each of these weaknesses. They range from a “best-efforts” framework, that lets companies miss targets by blaming external technology and political constraints – never mind that some of these same companies are working hard to weaken climate policy – to a reliance on unproven technologies, and low-rigour energy accounting that lets companies claim compliance without operational or system-wide decarbonisation.
We can’t rely on SBTi to hold companies accountable, so take action on greenwash with us here.
Key Points
- This briefing identifies five broad weaknesses in the updated SBTi Corporate Net-Zero Standard that can enable greenwashing or stall deep decarbonisation.
- The first weakness is the “best-efforts” framework, which undermines accountability by allowing companies to miss targets while retaining certification if underperformance is attributable to external barriers such as technology or policy constraints.
- The second weakness is the inclusion of speculative technologies, including carbon removals, carbon capture and storage, and delayed durability requirements that may allow companies to rely on technologies with uncertain or dubious future scaling potential.
- The third weakness is the technology-agnostic treatment of ‘low-carbon’ energy sources, which places nuclear, bioenergy, and hydropower on equal footing to wind and solar despite their weaker performance on waste, biodiversity, health and other environmental dimensions.
- The fourth weakness is low-rigour target setting, including optional long-term targets and supplier-alignment targets, which substantially lowers barriers to entry by reducing pressure for real, direct and deep decarbonisation.
- The fifth weakness is low-rigour energy accounting, including energy attribute certificates (EACs), and voluntary hourly matching mechanisms that can enable target compliance without operational or system-wide decarbonisation.
SBTi has updated its performance-based criteria to validate company net-zero targets
The updated SBTi Corporate Net-Zero Standard Version 2.0 (the Standard) sets normative, prescriptive criteria that commercially operated companies worldwide can follow to have their net-zero targets validated by the SBTi. This version adopts a largely technology-agnostic, performance-based approach defined by either absolute emissions volumes or specific emissions intensity thresholds.1
Under the updated Standard, companies are required to set a ‘target value’ for the level of emissions reached within a specified timeframe. Companies prove they are on track for their net-zero targets by undergoing an ‘end-of-cycle assessment’ by an SBTi-recognised validation body.
Specifics of the validation requirements vary depending on company attributes. One of the key changes in the updated Standard is the introduction of company categories which account for capacity differences between large-scale, high-income ‘Category A’ companies and smaller, lower-income ‘Category B’ companies. Differentiations in practice include that Category B companies are not required to undergo third-party assessment, and only need to set scope 1 and 2 targets.
For all companies – regardless of size or location – the Standard applies a ‘best-efforts’ framework (see Box 1). This framework makes allowances for companies when targets are missed due to factors outside their direct control, such as technology availability, supplier readiness or policy barriers.
Additionally, to achieve corporate certification, only short-term (5-year) goals are requisite. Long-term net-zero goals (targets to reach residual emissions levels by 2050 at the latest) are optional for all companies at scope 2 and 3, and target-dependent at scope 1.
| Box 1: What does STBi mean by the ‘best-efforts’ framework? |
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| The updated Standards are built on a best-efforts framework under which a company’s failure to meet its net-zero targets does not result in punitive action, so long as the company can demonstrate it utilised all available levers within its control.2 A company that has failed to meet its targets must set more ambitious targets in the next cycle, disclose barriers (such as technology readiness or policy gaps) that inhibited progress, and report targets and progress updates. These best efforts are validated through an implementation hierarchy that prioritises emissions reductions by their proximity to the source. Companies must first prioritise direct operational and supply-chain emissions reductions before using more indirect measures, and they must demonstrate that all technically and commercially feasible actions have been assessed and implemented before moving to lower-priority options. While companies are required to submit a ‘credible’ transition plan to achieve their targets, the approval of this plan by SBTi “does not constitute an assessment or endorsement of the overall quality, completeness, or feasibility of the transition plan.” The credibility of a company’s transition plan is determined by adherence to the implementation hierarchy, not the plan’s feasibility.3 |
Persistent issues and weaknesses weaken the updated Standard
While the updated Standard represents a significant advancement and addresses several shortcomings of previous approaches, it nevertheless contains blind spots and concessions that may limit its effectiveness.
Technology agnosticism ignores the advantages of wind and solar
The Standard uses the terms ‘low carbon’ and occasionally ‘zero carbon’ to describe electricity, assets, commodities, technologies and funding for research activities. This can include any technology that may enable the company to reach its emission-reduction targets.
Table 1: Technology-agnostic terms and potential technologies that fall under these terms.
| Category | Usages | Definition | Potential Technologies / Materials Included |
| Low-carbon electricity (LCE) | Scope 2 emissions target setting, mandatory reporting for Category A companies, primary lever for decarbonising electricity consumption, particularly through behind-the-meter (captive, not purchased) generation | Electricity produced by an individual generator with direct GHG emissions ≤ 0.048 kg CO₂/kWh (dropping to 0.024 kg CO₂/kWh in 2035) | Variable renewable energy (wind, solar), nonvariable renewable energy (hydro, bioenergy), nuclear energy and electricity generation fitted with carbon capture and storage |
| Low-carbon assets | Scope 1 emissions asset transition | A physical unit or infrastructure under a company’s control that performs a function generating Scope 1 emissions. ‘Lower carbon’ performance is consistent with a trajectory toward net-zero by 2050 | Non-emitting or net-zero-aligned alternatives to GHG-emitting assets relating to the technologies above (e.g., wind turbines, solar farms and bioenergy facilities) |
| Low-carbon commodities | Scope 3 emissions procurement, market instruments using commodity certificates | Standardised industrial or land-based materials that are tangible and uniform with dedicated decarbonisation pathways, have emissions performance consistent with a science-based net-zero trajectory | Emissions-Intensive Activities (EIA) materials that are responsible for a significant share of global industrial and land-use emissions and for which dedicated decarbonisation pathways exist to align production with a net-zero trajectory |
| Low/zero-carbon R&D and innovation funding | Voluntary recognition as a category of ‘other climate action’ under the Ongoing Emissions Responsibility (OER) recognition program | Providing finance for R&D, demonstration, and early deployment of technologies or practices that accelerate the availability and cost-effectiveness of climate solutions | Energy storage, hydrogen infrastructure, carbon capture and storage, and low-carbon materials |
While the Standard does acknowledge solar, wind and energy storage as key technologies in the energy transition due to favourable economics and technological maturity,4 important climate- and environment-related considerations beyond emissions accounting are excluded. This includes, for example, biodiversity, human environmental health, land and water impacts, waste, social outcomes and food security, dimensions in which wind and solar technologies are already the highest performers (see Table 2 for examples).
Table 2: Non-exhaustive examples of poor social and environmental outcomes from low-carbon technologies permitted by the Standard within net-zero targets
| Dimension | Risk posed by low-carbon technologies |
| Health | Non-combustion technologies such as wind, solar and nuclear are associated with far lower mortality rates from air pollution and accidents than combustion technologies like biofuels. |
| Biodiversity | Hydropower projects can flood extensive areas of critical wildlife habitat and disrupt aquatic ecosystems.5,6 |
| Food security | The increased demand for biofuels is linked to exacerbated food insecurity, particularly in developing countries (See Box 2). |
| Waste | The AR6 identifies toxic waste as a primary barrier for nuclear energy and solar energy. However, modern recycling can recover up to 95% of the materials in solar panels, while nuclear waste necessitates permanent disposal in strictly controlled environments. |
Because these dimensions are outside the scope of the Standard, they do not affect a company’s net-zero assessment. Consequently, companies can maintain net-zero certification despite negative impacts in these areas, creating a risk of greenwashing.
| Box 2: Technology agnosticism in the updated Standard is a major oversight regarding the significant barriers and limitations of biofuels |
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| While bioenergy qualifies as low-carbon electricity under the Standard, its emissions performance neglects resource-related considerations. Companies may adopt biofuels as a compliance option without any differentiated treatment within the Standard, despite these serious constraints to the energy transition. One such consideration is land-use efficiency and the opportunity cost of biofuel-dedicated land. The area currently dedicated to bioenergy feedstocks is approximately equivalent to the size of Germany. If that land were instead used for solar power generation, it could produce roughly 23 times more electricity, an amount greater than the total global electricity generated in 2024. The Standard’s safeguards for food security regarding biofuels may be insufficient. Although it prohibits deforestation for bioenergy production, including indirect leakage effects, it does not restrict the conversion of food-producing agricultural land. Sustainability certifications that account for these impacts are only required where such schemes are available. Consequently, food security considerations may remain unaddressed, particularly in underdeveloped regions where expanded biofuel production is expected to exacerbate food insecurity. The Standard ignores issues concerning the strategic allocation of limited biofuel resources across sectors. If sectors with readily available decarbonisation alternatives rely heavily on biofuels, they may divert limited feedstocks away from hard-to-abate sectors such as maritime shipping and aviation. As the Clean Air Task Force notes, anticipated demand for biofuels in aviation and maritime shipping substantially exceeds current supply, while scaling sustainable feedstocks and supply chains presents significant technological challenges. |
Technological over-optimism may stall progress towards net-zero goals and push companies out of the Standard in the long term
Some low-carbon technologies are not yet commercially viable at scale and require significant investment and research to become deployable in certain industries. If these technologies do not develop as anticipated in a company’s predetermined transition plan, the company’s SBTi accreditation is protected by the best-efforts framework.
While the Standard does prevent companies from using cost or internal business decisions as a justification for underperformance, it permits limited availability of less mature technologies as a structural constraint under the best-efforts framework.
Overall, this lowers the risk of participation, but simultaneously creates the risk of companies retaining the reputational benefits of certification despite minimal tangible action toward actual emissions reductions and repeated failure to meet their net-zero targets over a long period of time.7
It might also create the risk that companies will back out of the Standard once low-effort methods to maintain certification have been exhausted and continued certification requires more ambitious, costly targets.
| Box 3: Carbon removals, credits, and carbon capture and storage offer examples of technical over-optimism |
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| The Standard has taken steps to improve the permanence and credibility of carbon removals within a company’s transition plan, particularly by adding durability requirements, which ensure the storage timeframe matches the atmospheric lifetime of the neutralised emissions for long-lived residual, unabated GHG emissions. This requires companies to include risk assessments and safeguards that monitor and account for or compensate for reversals or leakages and prove causality and additionality.8 The rules also disallow forecasting and double-counting. Despite these safeguards, it remains unclear whether carbon removals can be cost-effective at scale. Reliance on carbon capture and storage (CCS) to meet net-zero goals has been called into question in other contexts. For example, the UK’s transition strategy relies on CCS as a ‘clean’ priority for hard-to-abate sectors,9 but the UK’s Climate Change Committee found in 2025 that viable business models for carbon removal projects had not been established, limiting private investment and putting 2030 targets at risk. This echoes the IEA’s 2023 Net-Zero Roadmap, which found that CCS ambitions have historically not been met due to challenges with funding, managing long-term liabilities, and deploying at scale. The Standard’s phased-in durability approach to removals allows companies to postpone taking credible responsibility for ongoing, unabated emissions until 2035. This approach is designed to permit time for technology development and there is an expectation that V3 of the Standard – due to be published in 2035 – will be revised to reflect the best available science. However, critics argue that carbon removal investments must occur sooner, adding that even if every removal is additional, durable, and verified, the Standard may still rely on a future supply of high-quality carbon removals that is far larger than what can realistically be delivered at scale. |
Energy Attribute Certificates (EACs) allow companies to hit scope 2 and scope 3 net-zero targets without adopting or incentivising systemic change
Among the implementation levers to transition to the use of low-carbon electricity (scope 2 targets), the Standard allows for energy purchases to be accounted for by renewable energy certificates, including unbundled energy attribute certificates (EACs).10 These EACs allow companies to hit their emissions targets by buying certificates linked to low-carbon products they have not used.
The certificates typically represent investments in low-carbon electricity generation equal to the electricity a company consumes, even if that electricity is produced at another place11 or point in time12 from the company’s operations.
| Box 4: Companies can get leadership tier status for hourly matching, but this remains voluntary |
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| SBTi notes that hourly matching of energy contracts to consumption is preferable to annual matching as it aligns demand with supply, drives effective price signals and encourages load shifting. This level of granular accounting incentivises critical technology such as energy storage, demand response, grid flexibility and other net-zero grid innovations. The Standard introduces a voluntary Scope 2 Hourly Matching Program where companies can earn a leadership recognition on the SBTi dashboard if they meet the following hourly matching thresholds: 50% hourly matching until 2030, 75% hourly matching until 2035, 90% hourly matching from 2035 onwards. For transparency, Category A companies consuming 10 GWh or more in their grid must calculate and report the percentage of electricity that was matched with a low-carbon EAC on an hourly basis. By not mandating hourly matching, the Standard cannot stimulate system-wide changes to improve grid-readiness for renewable energy. |
Climate and clean energy stakeholders criticise the lack of ambition implied by EACs and voluntary opt-ins
The use of EACs and the voluntary opt-in for hourly matching mean that the Standard offers a very weak incentive for meaningful decarbonisation.
As reported by the Financial Times, it allows technology companies to claim that the emissions generated by a gas-powered data centre are offset by clean energy investments via renewable power certificates disconnected from their own electricity use. This arrangement creates no additionality and is generally priced at levels too low to stimulate investment, even if the producer were obliged to invest this revenue into low-carbon electricity expansion. As a result, the benefits of EACs are largely borne by the company buying the EAC.
The inclusion of EACs in the Standard has drawn fierce criticism from a coalition of 25 climate and clean-energy organisations for weakened scientific rigour in favour of corporate flexibility. In a letter to the STBi dated 10 June 2026, they argue this could allow companies to claim net-zero progress through low-carbon energy certificates and annual matching mechanisms without supply chain or operational changes, particularly if real energy was procured from carbon-intensive grids.
Inclusion of supplier alignment in scope 3 target-setting prioritises operational feasibility over demonstrable emission reductions
Scope 3 emissions depend on the decisions of thousands of suppliers and customers at different stages of their net-zero transition. To manage this challenge, the Standard presents supplier alignment targets as an alternative to absolute emissions-based targets for managing scope 3 emissions.
Companies can be certified if they set targets to increase their share of in-transition or net-zero aligned tier 1 suppliers and/or customers.13 In practice, this means progressively increasing the percentage of suppliers/customers that meet this criterion, measured by share of spend (how much the company pays the partner), revenue (how much the partner pays the company), or the emissions the partner represents.
While alignment targets allow companies to manage scope 3 targets more effectively, it also represents a shift in emphasis towards management feasibility over science-based emissions-reduction outcomes. This proxy may allow alignment with the Standard in the absence of demonstrable additional emissions reductions.
1 Companies may choose emissions intensity reduction metrics for their Scope 1 targets to reflect restricted decarbonisation opportunities unique to high-emitting industries, such as steel or cement. This allows high-emitting companies to retain certification, even if their real emissions are growing (e.g. through increased production).
2 Provided annual progress reporting and end-of-cycle assessments were conducted properly.
3 Companies are required to share key assumptions and external dependencies such as technology readiness that might affect implementation for transparency purposes, not for credibility or feasibility.
4 The Standard makes this comparison in regards to carbon capture and hydrogen, but not bioenergy or nuclear.
5 Hydropower can also flood agricultural land, culturally important landscapes, and displace local communities.
6 The Koukoutamba Dam in Guinea, for example, will flood land that was previously designated as a biodiversity offset for mining activities, with the likely outcomes being the drowning of 1,500 of 4,000 critically endangered Western Chimpanzees living in the area and the creation of conflict between groups as ranges are restricted.
7 Provided they satisfy the minimum progress criteria set out in the forthcoming Assurance Manual.
8 This means the company must prove that the removal would not have occurred without the company’s contribution.
9 The 2023 Net Zero Plan emphasises that industrial decarbonisation will be linked to 4 carbon capture usage and storage (CCUS) clusters.
10 Scope 2 targets can also be achieved through power purchase agreements and contracts for difference.
11 This is only the case if the company can prove a structural limitation, i.e., there is no low-carbon energy produced in their region.
12 Within a 12-month period.
13 The Standard defines “In-Transition” on page 92 and “Net-zero aligned” on page 95.