The extended consultation period for the CNZS V2 has ended on December 12th. Everyone was encouraged to read through the changes and participate in a questionnaire. The final approval is expected to be published in early 2026 and will take effect on January 1, 2028.
This sends a strong and clear signal to 1716 companies who already set a target (like ALDI SOUTH Group, H&M Group, SONY and many more [^1] - and all their suppliers) and 1143 companies who committed to such (like The LEGO Group, RENAULT, HYUNDAI and many more [^1] - and all their suppliers).
The key changes are: [^2][^3]
1. Validation becomes a cycle, not a one-off
SBTi is replacing its one-time validation model with a cyclical process
2. Scope 1: More flexible ways to cut direct emissions
There are now tree approaches to reduce Scope 1 Emissions:
- Reducing emissions on a linear pathway to net-zero
- Increasing the share of low-carbon activities over time
- Implementing Asset Decarbonization Plans, a company-specific carbon budget linked to investment and retrofit decisions
3. Scope 2: Tighter integration of low-carbon electricity
This latest draft expands to a full framework where electricity purchases (Scope 2) now come with stricter integrity rules:
- Companies must reach 100 % low-carbon electricity by 2040.
- Energy contracts must be geographically matched to where power is used.
- Hourly matching of renewable generation and consumption will phase in from 2030 (50 %) to 2040 (90 %). This means companies should align when their renewable electricity is generated with when they use it.
- Eligible generation sources must be new or re-powered within 10 years, tightening to 5 years by 2035. This means when you buy renewable energy or certificates, they must come from power plants that are newly built or re-powered (upgraded) within the last 10 years.
- “Low-carbon electricity” is defined as ≤ 0.024 kg CO₂ per kWh.
4. Scope 3: More focused and practical framework.
- Focus on significant sources
The old rule - covering 67 % of total Scope 3 emissions - is gone. Now, companies must target all categories that represent at least 5 % of their total Scope 3 footprint.
- Three target-setting types:
- Emissions intensity targets - cut CO₂ per unit of product or service.
- Activity alignment targets - increase the share of sourcing or transport already meeting SBTi benchmarks.
- Counterparty alignment targets - ensure suppliers and customers have validated science-based targets, with expectations cascading through the chain.
- Limited use of high-quality environmental attribute certificates. (EACs)
EACs act like receipts proving that a credible low-carbon action happened somewhere in the value chain.
This flexibility allows companies to choose the approach that best fits their influence - from direct operational control to supplier engagement.
5. Taking responsibility for ongoing emissions
- Category A companies (large companies, and medium-sized companies in high-income countries) are required to address part of their ongoing emissions with removals from 2035 onwards. This is designed to increase progressively each year until net-zero is reached.
- Every other company takes part in a two-tiered recognition system:
- Recognized
Requirement: Take responsibility for at least 1 % of ongoing emissions.
- Leadership
Requirement: Take responsibility for 100 % of ongoing emissions.
6. Stronger rules for assessment, assurance, and claims
One of the biggest changes between the March and November drafts is that SBTi moved from guidance to governance. The March 2025 draft outlined principles for monitoring and reporting, but left most of the “how” undefined.
The November 2025 draft turns those principles into enforceable requirements that determine how companies prove progress, get re-validated, and talk about their achievements publicly.
- Performance tracking:
Introduces quantitative formulas (Annex C) for assessing progress against targets.
- Assurance:
Independent third-party verification is now mandatory, at least at a “limited assurance” level (i.e. an independent verifier checks your emissions and target-progress data and finds no evidence of major errors).
- Renewal validation:
Required every five years to update targets and confirm ongoing alignment.
- Claims framework (Annex D):
Sets approved language for what companies can publicly claim - from “target validated” to “net-zero achieved.”
- Disclosure:
All validated companies must publish their target data and progress within six months of validation.
This summary does not claim to be complete in any way. Please read the sources if you are interested in more details about the SBTi and the CNZS V2 (or read the full version). However it should give you some basic understanding of the draft and on what is happening on the corporate site of things.
I think this is a big step in the right direction. Nevertheless,I would like to see point 5 introduced earlier, but I believe the decision was made in view of the tight labour market / inflation rates / high prices, you name it, as these costs are very likely to be passed on directly to consumers.
I'm interested in your opinion about the changes, the SBTi or corporate action in general.
[^1]: SBTi Dashboard
[^2]: CarbonMaps Blog
[^3]: CNZS V2 Second Public Consultation
Thanks, good point! But lets be real honest: