Ongoing Emissions Responsibility: How to take action on what you can’t yet eliminate
June 25, 2026By Lena Koch, Climate Policy Advisor at ClimatePartner and co-author of the Report, “Ongoing Emissions: Taking Responsibility”
Some companies have been funding climate projects for years. Others are only now asking whether, and how, they should start.
Both are facing the same underlying challenge: your company will continue to emit greenhouse gases while you work toward net zero. So, what's the responsible thing to do about those emissions today?
For too long, the available answers were either too risky to communicate ("carbon neutral") or too vague to act on. That is changing now. A new framework called Ongoing Emissions Responsibility (OER), recognised for the first time in SBTi's Corporate Net-Zero Standard V2.0, gives companies a credible, structured way to take responsibility for ongoing emissions, and talk about it confidently.
What is Ongoing Emissions Responsibility (OER)?
Gold Standard published, "Ongoing Emissions: Taking Responsibility”, a new report that I co-authored alongside experts from Gold Standard, Pinwheel, and other organisations. It introduces and consolidates a framework called Ongoing Emissions Responsibility (OER): a structured approach for companies to take credible responsibility for the greenhouse gas emissions they continue to generate on their path to net zero.
OER is not a new obligation invented out of thin air. It’s the answer to a question that companies have been struggling with for years: what do we do about the emissions we haven't yet been able to reduce?
Even the most ambitious organisations will continue generating significant emissions on their journey to net zero. That's not a failure of ambition but rather an honest recognition of where the world is. Decarbonisation takes time. It requires technologies not yet commercially available at scale, and depends on supply chain, infrastructure, and policy changes that no single company can drive alone.
Ongoing emissions have real-world consequences. They draw down a rapidly depleting global carbon budget. They carry growing financial, regulatory, and reputational risk. And for years, corporate climate strategies have largely left them unaddressed or addressed them through increasingly untenable approaches.
OER provides the framework to act responsibly on those emissions without implying they have been cancelled out.
The shift from compensation to contribution, and why it matters for your climate strategy
For years, companies supported climate projects and communicated that action through claims like "carbon neutral" or "climate neutral." The investments behind those claims were genuine. But over time, as expectations around corporate climate action matured, the framing became harder to sustain. It implied a one-to-one equivalence between a company's emissions and the outcomes of the projects it funded, a degree of certainty that was difficult to defend, and easy to misread, as a substitute for reducing emissions.
The result? Growing scrutiny, legal exposure, tightening regulations, and the rising trend of "greenhushing": companies quietly financing climate projects while saying nothing publicly, for fear of getting the communications wrong. In 2025, over 40% of carbon credit retirements were anonymous (Carbon Direct, 2026).
OER offers a way out of this impasse. And importantly, it validates, rather than discredits, what many companies were already doing.
The key shift is from compensation to contribution: openly acknowledging ongoing emissions and directing finance toward global climate action without claiming those emissions have been resolved.
This reframing matters for three reasons:
It's honest. OER doesn't require organisations to claim they have resolved their emissions. It requires them to acknowledge those emissions, establish a financial commitment proportional to them, and direct that finance toward credible climate action.
It broadens what qualifies. An OER portfolio can include high-quality carbon credits for near-term mitigation, but also R&D into hard-to-abate technologies, policy advocacy, biodiversity restoration, adaptation, and capacity building in the Global South.
It shifts the question. No longer: "Have we compensated for our emissions?" But: "Are we contributing meaningfully to limiting global warming?" That is a more honest, more robust, and ultimately more defensible position.
Good news: If you've been funding climate projects, you're already doing OER
If your organisation has been purchasing carbon credits, funding climate projects, or supporting beyond-value-chain initiatives, OER almost certainly describes what you've been doing even if you haven't been calling it that.
And now there is a recognised standard and a recognised claim for it.
SBTi's Corporate Net-Zero Standard V2.0 (CNZS 2.0) formally incorporates OER as a structured framework. Organisations can achieve 'Recognised', 'Advanced', or 'Leadership' status depending on the scope of their financial commitment and portfolio ambition. From 2035, OER will be mandatory for many organisations under the standard; for all companies setting new SBTi targets, CNZS 2.0 will be required from January 2028.
This means organisations that have already been engaging in this way, and doing so with integrity, now have the language, the Standard, and the recognition to communicate their efforts clearly and confidently.
Ready to understand what OER means for your company?
The role of carbon credits in an OER portfolio
Carbon credits are not the only instrument in an OER portfolio, but they remain an important one, and their role is now better defined.
When used as part of an OER approach, carbon credits function as a mechanism for contributing to global mitigation, not as a balance sheet offset. This distinction matters: it decouples credit use from compensation claims, reduces the risk of double-counting, and allows organisations to fund climate action without overstating the impact on their own emissions profile.
The voluntary carbon market infrastructure (established methodologies, independent verification, public registries, additionality standards) provides exactly the transparency and accountability that contribution claims require. High-integrity credits, including those aligned with the ICVCM's Core Carbon Principles, can play a central role in a well-designed OER portfolio.
What changes under OER is not whether to use carbon credits, but how to position and communicate them; as tools for funding global climate action on the path to net zero, not as substitutes for internal decarbonisation.
What the report covers
“Ongoing Emissions: Taking Responsibility” gives organisations the practical foundation to move from intention to implementation. It covers the business case for OER, how to set a credible budget, how to build and communicate a high-quality portfolio, and the role of carbon credits.
Download the full report on the Gold Standard website →
How ClimatePartner can support you
ClimatePartner supports companies across the full scope of climate strategy, from carbon footprint calculation and target setting to carbon credit procurement and OER portfolio development. Whether you are starting from scratch or building on years of climate investment, we can help you design a credible, strategic OER approach that stands up to scrutiny and delivers real impact.
If you are new to the voluntary carbon market, or looking to build a stronger foundation before diving into OER, our guide “Beyond carbon offsetting” is a practical starting point. It covers how certified climate projects and the voluntary carbon market work, how Article 6 and double counting shape what companies can credibly claim, and how contribution approaches differ from traditional offsetting.