One of the biggest changes in SBTi’s new standard is missing from the NY Climate Week agenda.

The mechanism is called Ongoing Emissions Responsibility (OER). Here’s what it does, and why I think it deserves far more attention than it is getting. 

Under SBTi, a company will focus on cutting emissions as fast as its engineering and balance sheet allow. Along the way, it will be honest about the parts of its footprint it cannot solve yet. 

But every year between now and net zero, that company is still emitting. So what does it do about those tonnes? 

For years, SBTi’s answer was “nothing.” Decarbonize, report your progress, and deal with the residual emissions at the end. What you emitted along the way was largely treated as part of getting there. 

Version 2.0 of the standard gives a different answer. 

While you decarbonize, you carry an ongoing responsibility for what you are still emitting.  This, of course, makes sense, because the impacts of those emissions create real harm for real people all across the planet. One way to act on that responsibility is by buying and retiring high-integrity carbon credits to mitigate the impact of your ongoing emissions. SBTi has paired this idea with a recognition program, so companies that accept responsibility for their ongoing emissions and take action beyond their value chain are formally acknowledged for doing so. 

Until 2035, this framework is voluntary. From 2035 onward, it is not. The companies in the SBTi system will be required to support eligible carbon removals equal to at least 1% of their ongoing emissions, rising to 100% in their target net-zero year, with the share of long-lived removals rising over time. 

Why “voluntary” understates it 

I understand the instinct to skim past anything labelled voluntary. Most of us have seen enough voluntary commitments come and go. 

This one is different, for three reasons. 

First, under SBTi 2.0, a company must disclose why it is not participating in the OER framework. They will need to set down on paper a justification for why they feel it is acceptable for them to ignore the impacts of their ongoing emissions. There are not many great answers to this question, and I suspect that as companies realize this aspect of the framework, they will see participation in OER as the lesser risk.  

Second, OER is voluntary only until 2035. In corporate planning terms, that is not a long time. A company that wants to be ready will need a high-integrity pipeline in place well before then. The companies that start now will build supplier relationships and a credit pipeline and portfolio while the market is still nascent. As a bonus, they earn formal recognition and can make credible claims along the way. 

The third reason is how decisions get made inside companies. Beyond-value-chain action used to rely heavily on goodwill. It was a budget line a sustainability lead had to defend to a CFO who could quite reasonably ask: what exactly are we getting for this? There was no framework to point to, no recognition attached, and very little consequence for walking away. In a lean year, it was an easy thing to cut. 

Now there is something to point to. 

It sits inside the standard the company is already working against, with formal recognition attached today and a requirement waiting at the end of it. A strategy team can plan around that. A finance team can budget for it. And that is how something moves from being a good intention to something that shows up, year after year, in a corporate plan. 

Two things I think should happen 

SBTi’s validation portal opens for Version 2.0 in the first quarter of 2027, and from February 2028 it becomes mandatory for new submissions. Companies are already building their next round of targets against these rules. So we have roughly the next eighteen months to shape how this works in practice: what buyers ask for, what suppliers are expected to deliver and, ultimately, what good looks like. 

First, somebody needs to explain this. Standard-setters, market bodies and those of us working in this space talk endlessly about targets. We talk surprisingly little about OER. Many companies haven’t even begun to digest what OER is and what opportunities it offers to ambitious and smart companies.   

A framework cannot create demand if the companies that could use it do not know it exists. Explaining this clearly to corporate teams is not glamorous work. But I think it could do more to move actual volume than another panel discussing integrity (as important as those panels are!). 

Second, companies should start contracting now, even if they do not plan to take delivery for years. 

This is the point I would most like corporate teams to take away. You do not need to buy a single credit before 2035 for OER to change what you do today. A long-term offtake agreement that starts in 2035 gives a developer contracted cash flow it can finance against now. That is how supply gets built in time to meet the requirement. It is also how a company secures the high-quality portfolio it will need before everyone else is looking for the same tonnes. 

So, if you’re heading to New York, put OER on your personal agenda. Ask about it. Talk about it.  Identify gaps in our collective understanding. The discussions we have today will shape what meaningful corporate action means in the decades to come.