SBTi published Corporate Net-Zero Standard V2.0 (CNZS V2.0) in June 2026. More than 2,000 companies have active targets validated under SBTi's framework. The update contains meaningful departures from previous guidelines across target-setting, ongoing emissions responsibility (OER), and carbon market engagement. It creates specific decision points with specific deadlines. Some have dates attached. Others don't, but they compound in cost and complexity the longer you wait.

The seven decisions below are organized in the order most sustainability teams will need to face them.

One definition to keep in mind throughout: CNZS V2.0 splits companies into two groups. Category A covers large companies and medium-sized companies in high-income countries. All others are Category B. Category A carries the heavier obligations, including mandatory third-party assurance, board-approved transition plans, and mandatory OER from 2035.

The CNZS V2.0 timeline at a glance

• June 2026 — CNZS V2.0 published
• Late 2026 — Carbon credit and EAC program recognition guidance expected
• Early 2027 — Formal validation against V2.0 opens
• 2027 — GHG Protocol AMI standard draft expected
• Through 2028 — Companies can still set or renew targets under V1.3.1
• 2035 — Mandatory OER begins for Category A at 1% of ongoing emissions, scaling linearly to 100% by the net-zero year
• By 2050 (net-zero year) — Neutralize 100% of residual emissions; roughly 90% reductions vs. 2020

Decision 1: V1.3.1 or V2.0, and when?

CNZS V2.0 is live. Companies can still set or renew targets under V1.3.1 through 2028, and formal validation against V2.0 doesn't open until early 2027. That combination of timelines gives you room to choose, and a decision you cannot avoid making.

That means there are three scenarios for your company. Here's what each suggests:

1. No SBTi commitment yet

You have two options. Commit under V1.3.1 now, which buys time to build the data infrastructure V2.0 requires, particularly for scope 3. Or wait and go straight to V2.0 when validation opens in early 2027: faster to implement in the long run and no transition overhead later.

2. Validated target, next review due in 2027 or later.

You likely have time to wait. Nothing in the standard requires early action. Monitor Q4 2026 guidance before deciding (more on that in Decision 7).

3. Validated target, next review due in 2026 or early 2027.

This is the most time-sensitive scenario. Revalidating under V1.3.1 may make sense if your scope 3 data isn't ready for V2.0's expanded target forms. Moving to V2.0 directly is viable if the foundation is in place. Weigh the readiness of your scope 3 data against the benefit of validating early under the new standard.

Whatever the scenario, waiting without a clear position is not a neutral move. 2028 arrives regardless of whether a plan is in place.

One reassurance for moving sooner rather than later: CNZS V2.0 includes a specific provision (C39) that lets companies still operating under a prior standard claim OER recognition tiers, as long as they meet their targets or demonstrate best effort. Together with the standard's best-efforts basis, these provisions materially reduce the risk of building toward V2.0 early.

Decision 2: Which OER tier, and what does it cost?

Ongoing Emissions Responsibility (OER) is how CNZS V2.0 handles the emissions companies haven't yet reduced. It combines what were previously beyond-value-chain mitigation and neutralization into a single framework, operates as a separate recognition program from your scope 1-3 targets, and is measured against the physical inventory, not the market-based inventory. OER contributions take two forms: Mitigation Impact Contributions, measured in tonnes (tCO₂e), and Climate Finance Contributions, measured financially. The two accounting systems are separate, and that distinction makes a difference for how you budget (more on this in Decision 6).

Pre-2035, OER recognition is voluntary and structured across three tiers. Companies publicly report their tier status alongside their internal carbon price (ICP) and verified climate contributions, so the tier you choose becomes a public signal. Your investor relations and sustainability leadership should align on that position before V2.0 validation opens in early 2027.

The three tiers:

• Engaged: $20/tCO₂e suggested, or retire credits for the covered share | ≥1% of scope 1-3 (five-year cumulative)
• Advanced: $20/tCO₂e, or matched mitigation volume | ≥10% of scope 1-3, incl. 100% of scope 1+2
• Leadership: $80+/tCO₂e AND matched mitigation volume | 100% of scope 1-3 (Cat B: ≥10% incl. 100% of scope 1+2)

Eligibility of mitigation types is set by the OER timeline, not by tier:

• Pre-2035 (voluntary): Avoidance credits and removals
• From 2035 (mandatory for Category A): Removals only, with a rising share required to be durable removals

The durable-removal share starts at 10% of the long-lived GHG portion of covered emissions in 2035 and rises linearly to 100% by the net-zero year (see Decision 4).

Three inputs drive the tier decision:

1. Scope 1-3 volume.

This determines the absolute cost of coverage, not just the percentage. A company with 200,000 tCO₂e of ongoing emissions faces a very different Advanced-tier cost than one with 2,000,000 tCO₂e. Run the math on your actual volume before anchoring to a tier.

2. Whether a funding mechanism is in place.

The financial vehicle for OER, whether an ICP, a dedicated procurement budget, or forward offtakes, needs finance approval before you can commit to a tier. A tier choice your treasury can't support in practice isn't a tier choice.

3. What you want your public tier status to signal.

Leadership is the only tier that makes a near-unambiguous statement to investors and stakeholders. Engaged and Advanced need the rest of your disclosure to carry that weight.

One note on Category B companies: reaching Leadership requires only 10% coverage rather than 100%, which makes the Leadership signal achievable without the financial exposure of full scope 1-3 coverage.

Decision 3: How to set an internal carbon price that works for V2.0

To set an internal carbon price (ICP) for CNZS V2.0, anchor it to the OER tier you are targeting: the financial commitments set practical price floors of $20/tCO₂e at Advanced and $80+/tCO₂e at Leadership. An ICP is not mandatory under V2.0, but it is the primary mechanism most companies use to fund OER coverage.

To see how different companies have approached this, here are two anonymized examples from Patch's advisory work:

Tiered ICP by emissions source.

One e-commerce company committed to 50% carbon market coverage of its full emissions footprint, funded by a tiered ICP: $100/tCO₂e on scopes 1, 2, and business travel (category 3.6), and $15/tCO₂e on remaining scope 3 emissions. This raises more capital from the areas where the company has the most control, without applying a single flat price across the whole footprint.

Phased ICP with a modeled escalation pathway.

A European luxury goods company built a board-level business case for an ICP through cross-functional modeling across Finance, Operations, and Sustainability. The company started at €25/tCO₂e applied to business travel, with a modeled pathway toward €75/tCO₂e across scopes 1 and 2 as ambition scales. The business case demonstrated that an ICP is strategic infrastructure with the potential to generate cost savings and regulatory readiness, not solely a sustainability initiative.

What to decide now: which structure fits your treasury and procurement operations. An ICP needs finance and executive sign-off before it becomes a reliable OER funding mechanism, so start that approval path early. This is where executive sponsorship matters. CFO and CEO buy-in is critical, because an ICP is strategic infrastructure with cost-savings impact, not just a sustainability initiative.

Decision 4: How to plan your carbon removal supply before 2035

The mandatory removal requirement for Category A companies begins in 2035. That is nine years from now, and it should be informing procurement decisions in 2026.

Durable, engineered removals are supply-constrained today. There simply is not the volume of engineered carbon removal to meet these requirements now, and it is unclear whether there will be by 2035 without a strong demand signal from buyers. That scarcity is exactly why acting early matters: building supply relationships and securing offtakes now buys cost advantage and supply security while the rest of the market waits.

The math:

A Category A company targeting net-zero by 2050 must ramp removal coverage from 1% of its ongoing scope 1-3 emissions in 2035 to 100% by 2050, a fifteen-year linear ramp confirmed in V2.0. To illustrate the scale: that works out to about 6.6 additional percentage points of coverage each year. For a company with 500,000 tCO₂e of ongoing emissions, that is roughly 33,000 additional tonnes of removal capacity needed every year from 2035 onward.

Companies building supply relationships now can lock in forward commitments at current prices. Companies that wait until 2033 will enter a market where mandatory demand is concentrated, high-quality project supply is constrained, and developers have their pick of buyers.

Three portfolio decisions to work through now:

Short-lived vs. long-lived removal split.

V2.0 requires that a growing share of the long-lived GHG portion of covered emissions be addressed by durable removals: starting at 10% in 2035 and rising to 100% by the net-zero year. A portfolio built entirely on nature-based solutions won't satisfy this durability requirement in later cycles. Start building relationships with engineered removal providers, such as DACCS and mineralization-based approaches, early enough to evaluate counterparty risk, run pilot purchases, and negotiate offtake terms before scale becomes mandatory.

Neutralization at the net-zero year.

By the net-zero year, all companies must neutralize 100% of residual emissions with eligible removals, or ensure indirect value chain emissions are neutralized by value chain counterparties. Building consistent annual delivery capacity into your supply portfolio is more defensible than relying on lump purchases.

Scope 3 Shared Responsibility.

V2.0 introduces a mechanism that can materially reduce your OER obligation. If a supplier delivers verified OER contributions against their own scope 1-2 emissions, they can formally share that coverage with you, reducing your OER requirement for the corresponding scope 3 emissions. Mapping your ten largest scope 3 suppliers and assessing their OER trajectories is a near-term action that can meaningfully lower your long-term removal bill. Two important limitations: Shared Responsibility applies to OER only, not to other target types, and the supplier's reduction must be formally verified and applied to OER specifically, not simply claimed through their own target reporting.

Decision 5: What to do if you miss a near-term target

The best-efforts basis in CNZS V2.0 (Section 5) allows a company that falls short at its end-of-cycle assessment to remain in good standing. In most of the recent summaries, it's mentioned in one sentence, but none of them explains what it actually requires.

To remain in good standing, a company must demonstrate that it deployed all available levers, documented structural barriers, and reported transparently. CNZS V2.0 is explicit that cost and procurement preference are not valid reasons to deprioritize direct reductions. The best-efforts provision applies to the standard as a whole, not just OER.

The practical implication for teams setting targets in 2027.

In our view, the most defensible way to prepare is to document a target's key assumptions when it is set, not after a shortfall occurs: which abatement technologies the target depends on, which sector-wide conditions it assumes will hold, and what supply chain dynamics could disrupt delivery. The standard rewards companies that can document structural barriers and report transparently, so building that documentation into the target-setting process puts you in a stronger position if you ever need to rely on best efforts.

Decision 6: Where EACs fit, and where they don't

Environmental Attribute Certificates (EACs) and OER do two different jobs under CNZS V2.0, and conflating them is a common mistake procurement teams make. EACs, including RECs, SAF certificates, and other commodity EACs, adjust the market-based GHG inventory. They are tools for reducing market-based scope 2 and scope 3 figures to hit reduction targets. They are not OER mechanisms.

OER is measured against the physical inventory, and market instruments used against your reduction targets are explicitly excluded from it. The two run on separate accounting bases. Treat them as one and you will either over-claim OER coverage that doesn't count or under-fund the obligation.

A concrete example: a company using SAF certificates to reduce its market-based aviation scope 3 figure does not receive OER credit for those certificates. The SAFc satisfies part of its scope 3 reduction target. The company's OER obligation is calculated on its physical inventory independently.

What this means for how you set up your environmental procurement program: EAC budgets and OER budgets are two separate line items. They are funded separately, measured separately, and used against different accounting frameworks. If they sit in the same budget line, you will eventually lose track of which spend actually counts toward OER.

Interim program recognition guidance from SBTi, expected Q4 2026, will specify which EAC types and registries qualify for OER purposes. Until then, the standard's integrity criteria serve as the working bar: ex-post delivery, robust quantification, additionality, appropriate permanence, no double-counting, third-party verification, and public disclosure.

Decision 7: What to watch in Q4 2026 before finalizing anything above

Several of the decisions above depend on guidance SBTi has signaled for Q4 2026. Moving too early on Decisions 1, 4, and 6 creates rework risk. Moving too late on supply creates cost exposure that compounds.

Interim carbon credit and EAC program recognition guidance.

This will specify which registries, standards, and credit types qualify for OER recognition. It directly affects which removal counterparties to prioritize in Decision 4 and how to structure EAC procurement in Decision 6. Building supply relationships now is still the right action. Finalizing long-term offtake commitments with counterparties whose program status is uncertain may create quality compliance issues later.

Further SBTi and standards-body guidance.

In our experience, within any 6-to-18-month implementation window SBTi may release two or three documents or revisions, and other standards bodies will publish more. Expect the picture to keep moving, and revisit Decision 1 as clearer guidance on setting or renewing under V1.3.1 lands.

GHGP AMI standard draft (expected 2027).

This update will formalize the EAC and OER accounting separation at the framework level. Decision 6 becomes much cleaner once this draft is available and the accounting treatment is settled across both SBTi and GHG Protocol frameworks. If your finance or legal team needs formal framework alignment before approving an expanded EAC procurement program, this is the date to plan around.

What to do now: Put a Q4 2026 review on the calendar. Decisions 2, 3, and 5 are largely independent of Q4 developments and can move on the current standard's language. Decisions 1, 4, and 6 are worth holding for review against Q4 guidance before being finalized.

What comes next

The standard is finalized. Guidance on which credits qualify is still coming. Supply relationships for 2035 are being built now by companies that have done the math on the removal ramp and started acting on it.

These seven decisions affect procurement budgets, finance policy approvals, investor disclosure, and legal documentation. Working through them in 2026 is what positions a sustainability team to move quickly when V2.0 validation opens in Q1 2027.

We put together a complete guide to CNZS V2.0 that walks through the standard's requirements and the decisions behind them. Download it here.

The full recording of our June 30 webinar is also available. Watch here.

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