Beyond value chain mitigation (BVCM) in SBTi’s 2026 standard

A company’s value chain is everything upstream and downstream of its own operations, and its scope 1, 2 and 3 emissions are counted inside it. Beyond value chain mitigation is money or action that cuts, avoids or removes greenhouse gases somewhere else, such as a methane capture project, a forest or a direct air capture plant, on top of the company’s own reductions. SBTi, whose standards more than 11,000 companies have used to set validated climate targets, introduced the term beyond value chain mitigation in its Corporate Net-Zero Standard in October 2021, and its new standard of June 2026 turns it into a program with three levels of recognition and, from 2035, a requirement for large companies and many mid-sized ones.

SBTi’s 2021 standard recommended beyond value chain mitigation and set no level for it

SBTi’s Corporate Net-Zero Standard V1.3.1, the version companies can submit targets against until 31 January 2028, defines beyond value chain mitigation as “mitigation action or investments that fall outside of a company’s value chain”, including activities that avoid or reduce emissions and those that remove and store greenhouse gases. Recommendation R12 says companies should take that action “in addition to their near-term and long-term science-based targets” and report on it every year. The standard calls it an addition to the rapid and deep reduction of a company’s own emissions and not a substitute for it.

SBTi’s February 2024 report Above and Beyond separated a compensation claim, which tells the audience that the funded mitigation counterbalances the company’s own emissions, as a carbon neutrality claim does, from a contribution claim, which tells the audience that the company funded mitigation elsewhere without implying that its own emissions are cancelled. SBTi wrote that it had no plans to validate BVCM claims.

In SBTi’s survey of 212 respondents, mostly companies, published in September 2023, beyond value chain mitigation was the most commonly cited reason for buying and retiring carbon credits. Under SBTi’s Corporate Net-Zero Standard V1.3.1, beyond value chain mitigation stayed a recommendation, with no level to reach and no check on what a company said about it.

SBTi’s Corporate Net-Zero Standard V2.0 turns beyond value chain mitigation into Ongoing Emissions Responsibility

SBTi’s Technical Council approved the Corporate Net-Zero Standard V2.0 on 8 May 2026, its Board of Trustees adopted it on 21 May 2026, and SBTi published it on 11 June 2026. Companies can submit targets against Version 2.0 from 1 February 2027, and Version 1.3.1 stays open for submissions until 31 January 2028. SBTi’s summary of the changes says Version 2.0 “standardizes the ‘beyond value chain mitigation’ recommendation into a broader ‘ongoing emissions responsibility’ optional recognition framework”.

Ongoing emissions are the emissions a company still releases each year on its way to net zero, across all three scopes. Ongoing Emissions Responsibility asks a company to take responsibility for a share of them through climate contributions, which SBTi defines as funding for verified mitigation and other climate action that sits apart from the work of meeting the company’s targets and does not cancel out any of its actual emissions. Chapter 6 of Version 2.0 sets the program out in three phases:

1. From 2027, optional recognition. A company that covers a share of its ongoing emissions with climate contributions is recognized on the SBTi Dashboard at one of three levels, Engaged, Advanced and Leadership. The program opens to companies with targets under either Version 1.3.1 or Version 2.0 of the standard.
2. From 2035, a requirement for Category A companies. They fund carbon removals equal to at least 1% of their ongoing scope 1, 2 and 3 emissions in 2035, rising in a straight line to 100% by their net-zero target year, and no later than 2050.
3. At net zero, every company neutralizes all of its residual emissions, the emissions it still releases in its net-zero target year, with eligible carbon removals.

Category A is SBTi’s name for large companies everywhere and medium-sized companies in high-income countries. A company is in Category A if it has a net turnover of at least €450 million or at least 1,000 full-time staff, or if it is based in a high-income country and either has scope 1 and 2 emissions of at least 10,000 tonnes of CO2e or meets two of three thresholds, a balance sheet of at least €25 million, a net turnover of at least €50 million and at least 250 full-time staff. Every other company is in Category B.

Every company that sets targets under SBTi’s Corporate Net-Zero Standard V2.0 has to say at validation whether it intends to take part in Ongoing Emissions Responsibility, so a company that chooses not to fund mitigation outside its value chain says so on the record.

Ongoing Emissions Responsibility recognizes a company for covering 1%, 10% or 100% of its ongoing emissions

A company picks a level and covers a share of its ongoing emissions over the five most recent consecutive years of its inventory. There are two ways to cover an emission. The verified mitigation approach funds verified mitigation outcomes equal in tonnes of CO2e to the emissions covered, and a verified mitigation outcome is a reduction or removal outside the value chain that has already happened and been checked by an independent third party, such as the outcome a carbon credit records. The contribution budget approach turns the covered emissions into a budget at a carbon price per tonne of CO2e that SBTi sets for each level, and spends that budget on eligible climate action.

The Leadership level is the only one that asks for the tonnes of verified mitigation and the contribution budget at once. At the Leadership level of Ongoing Emissions Responsibility, a large company in SBTi’s Category A covers every tonne of CO2e of its ongoing scope 1, 2 and 3 emissions with verified mitigation outcomes and funds further climate action on top of them.

Recognition under Ongoing Emissions Responsibility rests on five years of measured and assured emissions

Under criterion C40.1 of the Corporate Net-Zero Standard V2.0, a company calculates its coverage on the physical greenhouse gas inventory, which counts emissions from the physical flows of goods and energy and uses the location-based method for scope 2, with market instruments such as renewable energy certificates reported separately. Criterion C40.2 counts the five most recent consecutive years of ongoing scope 1, 2 and 3 emissions. A company in the program reports a full scope 3 inventory every year and spends all its funds within the same five years.

At the end of its target cycle the company reports its total ongoing emissions by scope, the volume and percentage of them it covered, its level and approach, and the tonnes of verified mitigation outcomes and the funds it deployed. It obtains independent third-party assurance that it met the integrity criteria and disbursed all the funds, and it consents to the result appearing on the SBTi Dashboard. A company in Category A also needs independent assurance of the inventory for its target base year.

The standard says that neither SBTi nor any validation body it recognizes independently verifies the emissions data that companies submit, and that responsibility for the accuracy and completeness of the data stays with the company and its assurance provider. A company seeking recognition under Ongoing Emissions Responsibility needs every line of its inventory, AI usage included, measured on a physical basis, by one method for five consecutive years, in a form an assurer can check.

A carbon credit counts toward Ongoing Emissions Responsibility only once it is verified, retired and kept out of the inventory

SBTi’s Corporate Net-Zero Standard V2.0 sets out what a verified mitigation outcome has to be. It is measured ex-post in tonnes of CO2e and assured by an independent third party, and it reduces emissions from a source outside the company’s value chain, protects or restores a natural carbon sink, or removes carbon and stores it. It occurred within the five years before the year in which the company seeks recognition. Avoided emissions from the use of a company’s own sold products do not count.

The activity behind the outcome meets SBTi’s minimum integrity criteria, as well as recognized third-party criteria where they apply. It is recorded once in a transparent registry, quantified against a conservative baseline with leakage addressed, additional to what would have happened without the funding, protected against reversal, and assured by an accredited third party. At the Engaged level it also has to go beyond what regulation already requires.

The accounting rules keep the contribution apart from the footprint. Outcomes funded for Ongoing Emissions Responsibility are accounted for separately from the inventory, are not counted toward scope 1, 2 or 3 targets, and are not netted from the inventory. A carbon credit used for the program is permanently retired at the time it is claimed, and its outcome counts as a contribution only when no other party claims the same outcome for compliance or compensation.

As of 6 November 2026, SBTi had not published a list of the crediting programs it recognizes for Ongoing Emissions Responsibility. Its 11 June 2026 announcement expected a process to recognize instruments for the program in Q4 2026 and a Claims Policy from Q1 2027. Until SBTi publishes its list of recognized crediting programs, a company that retires carbon credits for Ongoing Emissions Responsibility checks each credit against chapter 6 of the Corporate Net-Zero Standard V2.0 itself, with the retirement record, the registry serial numbers and the assurance in hand.

The UN, VCMI, ISO and EU law differ on what a company may claim for the credits it retires

Four other bodies set rules or guidance on what a company may claim when it retires credits for mitigation outside its value chain. The UN High-Level Expert Group on net zero commitments, which the UN Secretary-General appointed to review the pledges of companies and cities, published its report Integrity Matters in November 2022. VCMI, the Voluntary Carbon Markets Integrity Initiative, writes guidance for companies on claims about carbon credits and published version 3.2 of its Claims Code of Practice on 23 September 2026. ISO, the International Organization for Standardization, published ISO 14068:2026 on carbon neutrality on 11 September 2026, the text of ISO 14068-1:2023 under a new title and number. The EU’s Directive 2024/825, on empowering consumers for the green transition, has applied since 27 September 2026.

The UN High-Level Expert Group, VCMI and SBTi agree that retired credits stay off a company’s reduction targets. Integrity Matters says high-integrity credits “should be used for beyond value chain mitigation but cannot be counted toward a non-state actor’s interim emissions reductions required by its net zero pathway”. VCMI’s Claims Code says carbon credits cannot be counted toward within-value-chain reduction targets, and it calls the credits behind its claims beyond value chain mitigation.

ISO 14068:2026 lets a company or a product claim carbon neutrality with credits, once reductions and removals inside its value chain come first, which is a compensation claim in SBTi’s terms. Directive 2024/825 bans telling consumers that a product is neutral, or has a reduced or positive greenhouse gas impact, on the strength of credits. The European Commission’s questions and answers on the directive, dated September 2026, add that the ban does not apply to claims at company level, which remain under the EU’s general rules on unfair commercial practices, that generic claims such as “carbon-neutral” or “climate neutral” are prohibited unless the trader can demonstrate recognised excellent environmental performance, and that the directive covers business-to-consumer practices only. VCMI stopped issuing its Carbon Integrity claims on 23 September 2026 and keeps the Claims Code as best-practice guidance.

A contribution claim, backed by retired credits that are reported apart from the inventory, is the claim that SBTi, the UN High-Level Expert Group, VCMI, ISO and EU law each leave open to a company.

Every billion AI tokens adds about 97 to 482 kg of CO2e to a company’s scope 3 emissions

AI usage bought through an API sits in a company’s scope 3, in category 1, purchased goods and services, because the electricity and hardware behind each token belong to the provider. CrbonFree methodology v1.2, which adopts Watershed’s open framework for measuring emissions from AI usage, counts for each token the energy it takes to compute, the overhead of the data centre that houses the chips, and a share of the emissions from making the hardware and training the model. It sorts models into four tiers by size, from small-tier models such as Claude Haiku through medium-tier models such as Claude Sonnet and large-tier models such as Claude Opus to reasoning-tier models, which use extended thinking, and for a count of tokens with no split it assumes three quarters input and one quarter output.

The CO2e per billion tokens on CrbonFree methodology v1.2 runs from about 96.8 kg of CO2e on small-tier models to about 482.3 kg of CO2e on reasoning-tier models, with medium-tier models at about 220.7 kg of CO2e and an uncertainty band of 158.3 to 283.2 kg of CO2e.

Google said its products and APIs processed over 480 trillion tokens a month in May 2025 and over 3.2 quadrillion tokens a month in May 2026, about 6.7 times as many in a year. OpenRouter, a gateway that sends API calls to models from many providers, routed 22.3 trillion tokens in October 2025 and 575.9 trillion tokens in September 2026, 26 times as many in eleven months, as our post on a year of OpenRouter’s tokens shows month by month. Watershed’s framework notes that AI emissions are a small share of the footprint of many companies today and that the share is unlikely to stay small for long.

A company that runs a billion tokens a month on medium-tier models adds about 2.65 tonnes of CO2e a year to its scope 3 emissions, or 13.2 tonnes of CO2e over the five consecutive years that Ongoing Emissions Responsibility counts. If its usage doubles every year, a slower pace than Google’s or OpenRouter’s, the five years come to 372 billion tokens and about 82.1 tonnes of CO2e, and the fifth year alone, at about 42.4 tonnes of CO2e, is 16 times the first year.

The emissions behind a token are the AI provider’s scope 1 and 2 and its customer’s scope 3. Under the shared responsibility rule in criterion C40.7, an AI provider that covers its data centres’ emissions under Ongoing Emissions Responsibility and its customer can agree in writing which of them covers the customer’s share of those tonnes of CO2e, so no tonne is covered twice or left out.

At the Leadership level a Category A company covers every tonne of CO2e of its AI line, and at the Engaged and Advanced levels the AI line increases the total of ongoing emissions that the 1% and the 10% are taken from. Because Ongoing Emissions Responsibility adds up five consecutive years of emissions, AI usage that doubles every year adds more to the coverage a company needs with each year that passes.

AI emissions are hard for a company to measure accurately and consistently from its own records

A company that uses AI at scale buys it from several places at once, with one team calling OpenAI or Anthropic directly, another going through AWS Bedrock, Google Vertex AI or a gateway such as OpenRouter, and staff using AI tools that the company pays for per seat. Each provider keeps its own usage record in its own format, and the invoice that reaches finance shows the money spent rather than the tokens per model that the emissions depend on.

Most providers do not publish the energy per token of each model, so the factor that turns tokens into CO2e has to come from a method, and the methods disagree. Watershed’s framework reports that published estimates for a single query differ by several orders of magnitude, depending on what is counted, which provider is measured and what is assumed about electricity use and the grid, and that companies, regulators and auditors are asking for estimates that hold up under scrutiny while no widely accepted method exists. Google’s paper on Gemini measured the median Gemini Apps text prompt in May 2025 at 0.10 watt-hours when it counted only the active chips in Google’s most efficient data centres, and at 0.24 watt-hours when it counted the host machines, idle capacity and cooling across its whole fleet, 2.4 times as much energy for the same prompt.

Emissions that a provider publishes per prompt can sit on a different basis from the physical inventory that Ongoing Emissions Responsibility counts. Google gives 0.03 grams of CO2e for its median Gemini prompt on market-based accounting, which counts its purchases of clean energy, while the physical inventory uses the location-based method, and Google does not disclose how many prompts it serves or how many tokens a prompt carries, so a customer cannot scale the per-prompt emissions to its own usage. Our post on market-based and location-based emissions explains the difference between the two methods.

The models in use change within a quarter, and the most used model on OpenRouter in September 2026, GLM 5.3 Flash from the Chinese lab Z-AI, had a version date of 26 August 2026, five weeks before the month ended. A table of emission factors chosen at the start of a year can miss the models a company runs by the end of it.

Ongoing Emissions Responsibility asks for the AI line five years running, and one year’s count compares with the next only when every year uses the same boundary, the same model tiers and a recorded version of the emission factors, so that an assurer can recompute any year. A spend-based estimate, which multiplies the AI bill by an emissions factor per dollar, follows the provider’s prices rather than the tokens, so in a year when the price per token falls and usage grows it can show AI emissions going down while the token count goes up.

For a company that wants SBTi to recognize its beyond value chain mitigation, AI usage is a line of scope 3 that can grow severalfold in a year and is hard to measure the same way each year, and the coverage SBTi recognizes is only as accurate as that measurement. A large company at a billion medium-tier tokens a month whose usage doubles each year has about 82.1 tonnes of CO2e of AI emissions to measure, to have assured and to cover at SBTi’s Leadership level over the five years that Ongoing Emissions Responsibility counts, and AI emissions that are undercounted, or counted one way in the first year and another way in the fifth, leave the company unable to show what share of its ongoing emissions it has covered.

SBTi recognition for a company that uses AI starts with five years of AI emissions measured by one method

SBTi’s Corporate Net-Zero Standard V2.0 has turned beyond value chain mitigation into a recognition program, Ongoing Emissions Responsibility, that opens in 2027 and sizes a company’s coverage on five consecutive years of measured and assured emissions, and on CrbonFree methodology v1.2 every billion AI tokens adds about 96.8 to 482.3 kg of CO2e to the scope 3 part of those emissions, depending on the model tier. A sustainability officer preparing for recognition is looking at about 13.2 tonnes of CO2e over the five years for a team at a billion medium-tier tokens a month, and about 82.1 tonnes of CO2e if that team’s usage doubles each year, with every tonne measured per model, on a physical basis and in a form an assurer can check, before SBTi can recognize the share covered.

CrbonFree meters AI usage per call, per model and per provider across OpenAI, Anthropic, OpenRouter, AWS Bedrock, the Vercel AI Gateway and Google Vertex AI, and calculates every month with CrbonFree methodology v1.2, which integrates Watershed’s open framework for measuring emissions from AI usage, and it records the factor version on every billing period, so an assurer can see which version counted each year. Usage-based billing adds signed carbon receipts and a monthly audit pack, a zip with a manifest hash, that the company can hand to its assurer, and Crbon Labs retires verified credits it originates in a quantity that matches the measured footprint, with their serial numbers on the American Carbon Registry or the BCarbon Registry, while the measured footprint is reported unchanged beside them. A company that measures its AI usage with CrbonFree has its AI emissions per model and per month, measured by one method in every year that SBTi’s recognition counts, ready for its assurer and with a receipt for each verified credit retired against them.