December 2025

The Value Change Initiative (VCI) welcomes the SBTi’s second draft of the Corporate Net Zero Standard 2.0 and its ambition to modernize Scope 3 target-setting. While we support the shift toward more flexible, actionable pathways, this flexibility must be matched with guardrails, transparency, and alignment with other global standards—particularly the GHG Protocol’s forthcoming Actions and Market Instruments (AMI) framework. Above all, companies need a system that supports reporting decarbonization in a fair, credible, and comparable way.

The consultation survey presents limitations in capturing certain feedback not explicitly addressed in the questions. While the survey focuses on specific criteria and guardrails, VCI members have emphasized the importance of raising additional considerations that fall outside the scope of the current questionnaire. In response, we have compiled a summary below that reflects both our input to the survey questions and high-level feedback on other key issues identified as critical by the VCI membership.

Reintroduce absolute reduction targets to level the playing field

Although not directly addressed in the consultation survey, VCI’s most significant concern is the removal of Scope 3 absolute reduction targets. These targets have long served as the foundation for comparability, accountability, and ambition across sectors. Without them, the new system risks inconsistent ambition levels, and increased reporting complexity. Additionally, and notably, absolute reduction targets also help maintain a level playing field across companies.

Many organizations, including VCI members, have already built systems aligned with CNZS v1.0. Eliminating absolute targets now creates uncertainty and significant rework. Retaining absolute reduction targets, even as an option for companies to choose from different target systems, would preserve continuity and avoid penalizing first movers.

Intensity benchmarks in FLAG sectors

Related to the above mentioned absolute reduction targets, the introduction of intensity benchmarks for Forest, Land and Agriculture (FLAG) sectors carries significant risks if methodologies, assumptions, and data boundaries are not fully transparent. These benchmarks are technically complex, data intensive, and vary widely by region. Using single benchmarks for commodities can result in a competition on using models and quantification methods that lead to desired results rather than engaging in actual emissions reductions. Regional variability can lead to unequal competition in the achievement of single sector intensity benchmarks.

Absolute targets remain a clearer and more equitable reference point and should continue to be available to companies.

Activity pools and stratified emission factors: recognize what works

VCI strongly supports the use of activity pools and stratified emissions factors (EFs) in situations where direct traceability to individual sources is impractical, which is an operational reality for most global supply chains. When supported by functional equivalence, geographic clarity, and reliable data, these approaches provide meaningful mitigation signals, even in complex landscapes.

However, the draft limits stratified EFs to volume alignment targets and only when tied to Environmental Attribute Certificates (EACs). This risks discouraging companies from investing in real, supply‑chain specific interventions. VCI urges SBTi to allow stratified EFs, when integrity safeguards are met, to count toward emission reduction targets and net zero pathways.

Align with AMI: Recognize both physical and contractual links

Traceability should not be narrowly defined as physical-only. The forthcoming Actions and Market Instruments Standard is establishing a credible system that recognizes contractual inventories when physical traceability using Chain of Custody models is not feasible. To avoid unnecessary divergence and to ensure practicality, the SBTi should harmonize with the AMI’s direction for the framing of physical and contractual links.

Consequential accounting should be recognized

Draft 2 excludes EACs based on consequential accounting from the focused targets. This is a major concern: many transformative interventions such as regenerative agriculture, soil carbon, or early-adopters of low‑emission inputs and practices deliver systemic effects that cannot be captured with attributional accounting alone. These transformative interventions often require consequential accounting to capture their broader market or ecosystem effects. Furthermore, it must be recognized that some of these interventions occur within the value chain or are value chain associated, therefore they should be accounted towards net-zero pathways, as they are equally important. Not accepting these types of interventions risks hindering resilience-focused projects. The SBTi should offer a safeguarded pathway for consequential approaches (e.g., specific category) to contribute towards net zero, ensuring companies can invest in solutions that unlock real change. Furthermore, this also brings closed the alignment with other accounting and reporting frameworks.

Recognize diverse Market‑Based Instruments beyond EACs

SBTi should consider mitigation-related contractual agreements to establish credible rights to claim emissions reductions from value chain interventions in activity pools and other interventions—not just through Commodity Certificates. If relevant, SBTi should provide specific quality criteria for these contractual instruments, while also acknowledging the practical realities and diversity of activity pool structures in current markets.