What the NCS Alliance and IETA said
The NCS Alliance, whose consultation response included CI, TNC, WWF, and other conservation organisations, welcomed the Corporate Net-Zero Standard (CNZS) V2 as a step forward, specifically the Ongoing Emissions Responsibility (OER) framework’s recognition that high-integrity nature-based solutions and carbon removals can play a role in addressing ongoing emissions during the transition to net zero. Their response to the earlier consultation had called for nature-based credits to be recognised as legitimate solutions available now, arguing that there is no net zero without nature. IETA’s December 2025 submission welcomed progress on credit recognition but pushed for further practical refinement, particularly around Scope 3 emissions where nature-based interventions in supply chains could play a meaningful role.
A real demand signal, subject to the integrity bar
CNZS V2 does create a real demand signal for forest carbon. REDD avoidance credits are eligible in OER throughout the voluntary phase and beyond, subject to meeting the C42 integrity bar. CCP-labelled REDD, for example under Verra’s VM0048 or ART’s jurisdictional TREES programme, is emerging as the preferred choice for buyers operating under CSRD and SBTi frameworks, and those credits carry the potential for a meaningful price premium as quality differentiation sharpens. SBTi’s own publication on OER explicitly recognises that companies can earn recognition for actions that protect, manage, or restore natural ecosystems, framing forest protection as a legitimate component of corporate climate leadership, not an afterthought.
Permitted everywhere, required nowhere
The problem is that REDD remains permitted throughout OER, but it is not mandated anywhere. FLAG (Forest, Land and Agriculture) mandates removals within land-sector supply chains, but has no reach outside them. If we want to incentivise protecting standing forests, these are obviously outside or adjacent to supply chains. OER creates voluntary recognition for forest protection, but the only obligation it builds toward is a removals requirement from 2035.
Avoided deforestation is not a second-best option
This matters because of the function REDD serves in climate terms. Avoided deforestation is not a second-best option to be used while the world waits for removal technology to mature. Griscom et al. (2017) found that natural climate solutions, with forests and avoided deforestation dominating, could provide 37% of the cost-effective mitigation needed by 2030 to hold warming below 2°C. These forests also provide significant ecosystem services from pollination to water management. Most of those pathways rely on avoiding deforestation and related emissions, not removals. The urgency is real: planetary tipping points won’t wait for the pipeline of removals to appear. A framework that creates structured demand for removals and permissive eligibility for avoidance puts these activities on unequal ground and essentially chooses which mitigation levers get financed, without ever having to argue for it explicitly.
The Q4 2026 Claims System consultation is the intervention point
FLAG’s scope compounds the gap further. FLAG reaches only land-sector companies with significant AFOLU emissions. For the majority of SBTi signatories, including companies in finance, technology, retail, and services, REDD has no structural home in either framework. The Q4 2026 consultation on the SBTi Claims System, which will define credit eligibility under OER in operational detail, is the intervention point. If that guidance creates specific recognition pathways for high-integrity avoided deforestation alongside removals rather than treating avoidance as merely eligible within a framework designed around a removal mandate, the contribution SBTi could make to forest finance would change materially.
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