On June 11, 2026, the Science Based Targets initiative (SBTi) published version 2.0 of its Corporate Net-Zero Standard. This global framework sets out the rules by which companies with SBTi-validated targets must structure their climate trajectories. More than 11,000 companies worldwide have SBTi-validated targets, including 431 French companies as of the end of 2025.
For the carbon dioxide removal (CDR) sector, this publication marks a turning point. CCS will become a mandatory component of net-zero strategies for large and medium-sized companies in high-income countries starting in 2035—15 years earlier than indicated in the previous version. This is a step forward that AFEN welcomes.
A careful reading of the standard reveals other significant trade-offs—some favorable, others still to be clarified—which, as currently drafted, will have concrete consequences for French and European companies seeking to incorporate EDC into their climate strategies.
2035: A strong signal, in line with scientific requirements
In the previous version of the standard, carbon elimination was deferred until the net-zero target—that is, for most companies, until 2050. Version 2.0 moves this requirement up by fifteen years. This sends an important signal to the market about the role of EDC in corporate climate strategies.
The underlying logic is consistent with what science has been calling for for several years. Even with massive decarbonization efforts, certain sectors—such as heavy industry, agriculture, and transportation—will not be able to eliminate all of their emissions. For these unavoidable residual emissions, EDC is the only available lever. Reduction and elimination must proceed in parallel, and the new standard enshrines this complementarity within a binding framework.
The standard also reinforces the «like-for-like» equivalence principle: greenhouse gases with a long atmospheric lifetime must now be offset by volumes of EDCs with equivalent permanence. The previous draft allowed more room for solutions with shorter permanence to offset these emissions, with a 40/60 split between permanent and temporary removals. The final version tightens this requirement and strictly aligns it with the lifetime of the relevant emissions in 2050. This sends a strong signal in favor of high-permanence EDC approaches (direct air capture (DAC), bioenergy with carbon capture and storage (BECCS), mineralization, and geological sequestration), whose volumes are becoming the benchmark solution for the residual emissions that are most difficult to offset.
The OER Framework: What It Actually Entails
The central mechanism of Version 2.0 is the OER framework: Ongoing Emissions Responsibility. It replaces the more vague concept of “Beyond Value Chain Mitigation” and, for the first time, establishes a pathway for purchasing carbon credits within SBTi commitments.
The framework operates in three phases:
- Starting today, it is possible to voluntarily report EDC purchases in SBTi reporting.
- Starting in 2035, Category A companies—large and medium-sized enterprises in high-income countries—will be required to offset 1% of their residual emissions through carbon credits, with a gradual linear increase up to 100% by the net-zero target date.
- By that date, residual emissions are expected to be completely eliminated.
The standard also introduces a phased sustainability requirement for permanent removal credits, set at 10 % starting in 2035 and set to increase proportionally.
On the issue of double counting among companies, the rule is clear: an EDC credit used under the OER framework cannot be claimed simultaneously by another company. This is a welcome safeguard for integrity.
Three questions that need answers
The outlook is positive. For companies that want to plan ahead, several issues still need to be resolved.
The Tension Between the SBTi Standard and European CRCF Credits
This is the most sensitive issue for French and European companies, and one that AFEN has committed to addressing directly. In December 2025, AFEN, along with 58 other industry stakeholders, co-signed an open letter calling on the SBTi to revise, among other things, this provision.
The standard includes a recommendation, provision R46.1, encouraging companies to use, to the extent possible, EDC credits that are not simultaneously claimed by countries in their Nationally Determined Contributions (NDCs).
However, Article 1.2 of the European Carbon Removal and Carbon Farming Regulation (CRCF) stipulates that certified removals must be incorporated into the European NDC.
If this SBTi recommendation were interpreted strictly, or if it were to evolve into a requirement, CRCF credits would effectively be excluded from the SBTi framework. This would represent a direct contradiction for companies seeking to balance European regulatory compliance with voluntary ambition.
The open letter advocated a different approach: it is not double counting for a write-off to be recorded in both a company’s balance sheet and a government’s balance sheet, provided that it is not claimed simultaneously by two companies. This is, in fact, how public-private mechanisms currently operate in Sweden, Norway, Denmark, and the United Kingdom, and it is on this model that the CRCF was designed.
The final version of the standard did not include this interpretation. The framework for implementing market-based solutions and carbon credits—which the SBTi is set to release for public comment in the fourth quarter of 2026—must clarify this point. We will be monitoring this closely.
Without intermediate milestones, the supply side risks becoming the Achilles’ heel of the 2035 goal
Earlier versions of the draft included short-term EDC procurement targets—a provision that several industry stakeholders had helped draft. These were ultimately incorporated into the general OER framework.
This setback has tangible consequences. Developing a carbon capture and storage (CCS) project—whether it’s a biochar facility, a direct-air capture pilot, or a BECCS facility—takes several years from concept through financing, construction, and commissioning. Without an early signal of demand, the financial viability of these projects remains fragile. And if these projects are not funded today, the industry will face even greater difficulty in supplying the necessary volumes by 2035.
By setting a nine-year deadline without mapping out a path to achieve it, the standard risks creating a paradoxical situation: companies legally required to purchase EDC credits in 2035 will face an insufficient supply because investment decisions will not have been made in time.
The SBTi justified this decision based on the current geopolitical context. We understand the constraints. We maintain that interim milestones are still necessary to make the 2035 deadline truly achievable.
Implementation Pending Legislation Yet to Be Enacted
Operational guidance on market instruments and carbon credits is not expected to be released for public comment until the fourth quarter of 2026. Validation of the first commitments under Version 2.0 will not begin until the first quarter of 2027. There remains a significant gap between the announcement and implementation.
Our Reading
The SBTi Corporate Net-Zero Standard V2.0 represents a landmark milestone. It embeds carbon removal into corporate obligations with a concrete timeline and formally recognizes its role in net-zero pathways as a necessary complement to residual emissions.
For French and European companies, two conditions must be met in the coming months: clarification of the rules governing CRCF loans, and an implementation framework that is sufficiently precise to guide concrete purchasing decisions.
AFEN will continue to closely monitor this work, in collaboration with stakeholders in the EDC sector, its European counterparts, and the relevant authorities.
Companies that wish to plan ahead can already draw on the resources available on our website and begin thinking about their EDC path. The 2035 target will only be credible if it translates into decisions made today.
