A guide to the SBTi Corporate Net-Zero Standard V2’s Ongoing Emissions Responsibility (OER) Framework
Turning climate liabilities into strategic action.
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Historically, corporate carbon procurement has operated under a narrow paradigm in which carbon credits were viewed almost exclusively as a last resort, to be used only after deep internal emissions reductions were fully realized. While the imperative for internal decarbonization remains vital, this legacy framing often leaves companies paralyzed regarding unabated emissions during the long transition to net zero.
The Science Based Targets initiative (SBTi) Corporate Net-Zero Standard (CNZS) V2 fundamentally shifts this approach through its Ongoing Emissions Responsibility (OER) Framework. Rather than treating unabated emissions as a liability while awaiting distant net zero target dates, the OER framework establishes a legitimate, SBTi-aligned pathway to manage ongoing operational impact today.
What is the SBTi OER Framework?
The Ongoing Emissions Responsibility Framework is an optional, structured pathway under the SBTi Corporate Net-Zero Standard V2 that encourages organizations to take immediate responsibility for unabated scope 1, 2, and 3 emissions during their net zero transition.
The OER framework outlines a progression for corporate involvement, defined by distinct tiers of engagement and clear threshold requirements:
Companies can choose from three participation levels, Engaged, Advanced, or Leadership level, via two primary pathways: the Volume Matching Approach (matching a percentage of physical emissions with carbon credits) and/or the Contribution (Budget-Based) Approach (allocating a monetary carbon budget across eligible climate solutions).
At entry, both tiers require a minimum baseline commitment tied to 1% of a company’s total scope 1–3 emissions (or a recommended $20/ton benchmark under the budget approach).
| Recognition level | Climate contribution delivery approach | |||
|---|---|---|---|---|
| Level name | Coverage | Contribution budget approach (US$) | Required application | Verified mitigation approach (tCO₂e) |
| Engaged | 1% of total ongoing emissions | Covered emissions x $/tCO₂e (no mandated price set) | OR | Verified mitigation outcomes equal in volume (tCO₂e) to covered emissions |
| Advanced | 10% of total ongoing emissions (including 100% of scope 1 and scope 2) | Covered emissions x $20/tCO₂e | OR | Verified mitigation outcomes equal in volume (tCO₂e) to covered emissions |
| Leadership | Category A companies: 100% of total ongoing emissions; Category B companies: 10% of total ongoing emissions (including 100% of scope 1 and scope 2) |
Covered emissions x $80/tCO₂e | AND | Verified mitigation outcomes equal in volume (tCO₂e) to covered emissions |
Engagement under OER evolves from optional OER participation in the current transition phase to mandatory emissions removals by 2035, and ultimately to mandatory full neutralization in the company’s net zero target year.
OER Framework Evolution
(Current Transition)
(Beginning in 2035)
(At Net-Zero Target Year)
Reframing the carbon credit narrative
Under earlier net zero guidance, organizations were implicitly encouraged to delay their carbon market participation until deep internal abatement was complete. This created an unintended incentive to delay taking climate action on unavoidable emissions that occurred during decarbonization journeys that can span multiple decades.
The OER framework reframes this narrative by shifting corporate action from passive carbon credit purchasing to active, ongoing responsibility. By formalizing OER, SBTi validates the need to take immediate action. Companies no longer need to wait until 2030 or 2050 to address their unabated scope 1, 2, and 3 emissions. Instead, OER legitimizes carbon market engagement as a core component of a modern, comprehensive climate strategy.
Transparency, thresholds, and the cost of opting out
A key component of the OER framework is its low barrier to entry, featured in accessible thresholds across two primary pathways:
Companies can meet the entry threshold by matching as little as 1% of their total scope 1–3 emissions with validated carbon credits.
Organizations establish a dedicated carbon budget based on 1% of their scope 1–3 emissions. SBTi recommends a benchmark of $20 per metric ton.
Explicit opt-outs and public benchmarking
Crucially, SBTi’s default structure requires companies to explicitly opt out of OER. And for the first time, SBTi’s target dashboard will publicly disclose when an organization chooses not to address its ongoing emissions under the OER framework.
This structural choice introduces an opportunity for organizations to do direct peer-to-peer benchmarking, where choosing not to participate creates a visible distinction on the public dashboard. Non-participation raises very real potential for reputational risk and investor scrutiny.
Unlocking procurement flexibility via the contribution approach
While standard volume matching links procurement on a 1-to-1 metric ton ratio, the Contribution Approach instead focuses on budget-based capital allocation. This unlocks significantly higher strategic flexibility, allowing sustainability teams to allocate a fixed carbon budget across a spectrum of high-impact climate solutions. Because OER recognition is tied to the qualifying contribution itself, buyers are not dependent on credit issuance or delivery within a specified timeframe to fulfill their obligation. Upfront funding through the Contribution Approach provides certainty of OER recognition while enabling catalytic investments and removing delivery risk from the equation.
Organizations can implement different, more creative strategies to address ongoing emissions, like:
| Strategy | Operational Mechanism | Key Strategic Benefit |
|---|---|---|
| High-cost, long-duration carbon dioxide removal (CDR) | Allocate budget to higher-priced CDR (e.g., biochar, BECCS) without requiring 1:1 volume coverage. | Builds long-term removal capacity ahead of mandatory 2035 SBTi removal requirements while claiming immediate OER recognition. |
| Ex-ante upfront capital | Direct upfront equity or catalytic funding to project developers at project initiation. | Fulfills the buyer’s OER obligation when the qualifying upfront contribution is made, removing pressure of credit issuance and delivery within a specified timeframe; also secures low-cost future supply, and establishes clear causal claims of corporate involvement. |
| Ex-post verified credits | Procure issued, verified credits for immediate warming mitigation impact. | Guarantees short-term atmospheric reduction/removal claims and grounds the portfolio in verified metrics. |
The blended OER portfolio framework
To maximize both short-term warming impact and long-term compliance, corporate procurement should employ a blended OER portfolio that balances immediate ex-post reductions with forward-looking catalytic investments.
- High-potency reductions (e.g., superpollutants)
- Immediate “Warming Match” mitigation
- Guaranteed emissions reduction impact*
* Only OER option that delivers this
- Early-stage project funding
- Multi-year off-take agreements
- Capacity building for 2035 removal rules
Balancing immediate impact and long-term compliance
Relying exclusively on ex-ante funding or catalytic investments risks funding efforts that may fail to yield verified emissions reductions down the line. By utilizing a blended portfolio that incorporates verified, ex-post carbon credits, your organization ensures it delivers guaranteed, measurable climate impact.
Two tips to keep in mind when structuring your blended portfolio are:
- Warming matching & superpollutants: Incorporating ex-post credits targeting short-lived, high GWP climate pollutants (such as methane and hydrofluorocarbons) delivers outsized short-term cooling benefits, maximizing atmospheric return per dollar spent.
- Internal carbon pricing alignment: By updating internal carbon pricing mechanisms to fund a blended portfolio, sustainability teams can seamlessly link operational emissions to both immediate atmospheric mitigation and future CDR pipeline security.
Strategic next steps
SBTi’s OER framework provides a structured opportunity for sustainability leaders to turn climate liabilities into flexible portfolios that meet OER obligations today while balancing immediate verified impact with long-term climate action.
To prepare before V2 of the CNZS and public dashboard disclosures take effect, 3Degrees recommends organizations take the following immediate actions:
Complete a comprehensive review of your scope 1, 2, and 3 emissions baseline.
Utilize the Contribution Approach to set an initial baseline OER budget (using the $20 benchmark as a starting guide).
While many companies will continue to volume match, 3Degrees supports the contribution approach because it’s flexible, blends catalytic funding, and guarantees measurable impact.
Build a portfolio that pairs immediate ex-post atmospheric impact with forward-looking CDR and ex-ante funding to hedge against future supply constraints and regulatory shifts before public dashboard peer comparisons take effect.
Looking for help building your OER strategy?
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