Guest post by: Ella Ward Parsons, Corporate Responsibility Officer, and Co-author: Daniel Magrath, Head of Corporate Best Practice, Gold Standard
If we are to reach the Paris Agreement’s goal of limiting warming to 1.5 °C above pre-industrial levels by 2050, the actions companies take are critical. Expectations, in both voluntary and regulatory contexts, are evolving. Increasingly, businesses are being encouraged to focus not only on reducing the emissions released through their operations and supply chain processes, but also to take responsibility for the emissions that remain unabated annually as they transition to net zero. This concept is called Ongoing Emissions Responsibility (OER).
Historically, the conversation about corporate action has focused on direct mitigation, particularly through the voluntary carbon market (see Box 1). While mitigation efforts are a vital support for global sustainability goals, there is also a wider picture to consider. OER can enable critical transition investment in areas essential to net zero that have historically sat outside corporate standards. These include research and development, policy engagement, capacity building, and infrastructure support.
This article focuses on this dimension: how businesses can use OER to support non-mitigation investments, and how to structure these investments.
What is OER?
OER is a framework for how organisations can take responsibility for their emissions (Scopes 1, 2 and 3) that remain unabated each year. While deep and rapid decarbonisation remains the priority, a credible OER strategy enables organisations to take accountability for the continued impact of their operations while transitioning to an operational model in line with net zero by 2050.
The universe of potential OER investments is vast. To provide a practical structure, we suggest thinking in three overarching categories:
- Unlocking near- to mid-term decarbonisation.
Support activities that drive market, sector and policy transformation to remove barriers to value chain action. Examples include capacity building with suppliers, peer collaboration, policy lobbying and advocacy, and sector-wide initiatives.
- Laying the groundwork for long-term net zero.
This includes funding research and development to scale nascent climate solutions, such as durable carbon dioxide removal, as well as innovation in infrastructure and technology.
- Contributing to global mitigation now.
This focuses on directing funding to high-impact projects that deliver near-term mitigation outcomes, such as high-integrity carbon credits.
Carbon credits and responsible business practices
High-quality, third-party verified carbon credits are an immediate and credible mechanism for businesses to take responsibility for ongoing emissions. They complement internal decarbonisation efforts by directing finance toward priority investments – often in regions where it is most needed – while companies address structural and operational barriers within their own value chains. In doing so, they enable organisations to contribute meaningfully to global mitigation outcomes.
When developed under robust standards, carbon credits represent credible, additional, and independently verified impact, providing a clear and trusted link between investment and outcomes. They serve as a practical and immediate lever within an OER strategy, supporting global sustainability goals and allowing companies to demonstrate climate leadership.
Why invest in non-mitigation OER?
Many non-mitigation activities act as enabling investments that unlock system transformation and the transition to net zero. Activities like policy engagement and lobbying can strengthen market and policy environments, creating the conditions needed for decarbonisation at scale. By testing new technologies and approaches for climate action, companies can innovate and support the growth of essential climate solutions. Capacity building across processes and supply chains can give stakeholders the skills, knowledge and tools needed to implement and sustain sustainable practices and empower communities to be economically productive whilst delivering sustainable outcomes.
Importantly, these investments can remove barriers to value chain action. They complement direct mitigation efforts, enabling companies to show their climate leadership while providing globally impactful value aligned with their transition goals.
Where should companies start?
- Identify dependencies – review the company’s transition plan and identify external dependencies and barriers, such as technology development, infrastructure, policy, regulation, or consumer behaviour.
- Target investments to address these barriers – prioritise strategic investments aligned with company needs, leveraging the company’s expertise, networks and influence to maximise impact.
- Support a fair and just global transition – companies can also fund non-mitigation activities in underfinanced sectors or countries that lack adequate resources.
A range of publications from WWF, Carbon Market Watch, Gold Standard and SBTi explore approaches for delivering credible OER. Organisations may also draw on resources from InfluenceMap or the We Mean Business Coalition, which help companies identify policies and advocacy needed to deliver on their transition plans.
What challenges are there for non-mitigation OER?
While many of the activities funded by OER are critical enablers of decarbonisation, they are inherently uncertain. Research and development may not produce immediate results. Advocacy does not guarantee regulatory change. Behaviour change initiatives can take years to show a measurable impact.
Measurement is also often less straightforward. These investments typically rely on estimates and counterfactual assessments. Unlike mitigation OER, which generally delivers clearly quantified emissions reduction outcomes, non-mitigation investments can be harder to measure, verify, and communicate.
These challenges require careful design, transparent reporting, and appropriate quality criteria. But just because something is hard doesn’t mean it’s not worthwhile.
Adopting a money-for-tonne approach enables organisations to generate a budget that can be allocated to a wide range of sustainability activities by applying an internal carbon fee to emissions. Unlike a tonne-for-tonne approach, typically used in compensation claims, this model is based on the level of finance invested rather than a specific volume of verified emission reductions, and can therefore support carbon, non-carbon, and enabling activities. While this reduces the need for each investment to deliver a specific, verified mitigation outcome, civil society and standard setters must still develop robust quality criteria to recognise credible action, even when outcomes are uncertain.
The role of non-mitigation OER
As expectations around corporate climate action continue to evolve, OER provides a pragmatic bridge from ambition to action. By investing in OER, companies can channel finance towards critical investment types that help maintain credibility during the transition and strengthen their climate strategies.
The upcoming SBTi’s Corporate Net Zero Standard 2.0 is expected to include a multi-tiered recognition framework for OER, enshrining these efforts into a recognisable label that can translate these investments to consumers, investors and society.
Gold Standard aims to support the growth of OER activity. In summer 2026, we will launch a report that will explore key topics such as the business case for OER, portfolio design and claims.
OER has the potential to unlock climate finance and barriers to decarbonisation and innovation. Those who consider and deliver both mitigation and non-mitigation OER will be positioned to achieve their sustainability goals, contribute effectively to the planet’s sustainability targets and cement their position as leaders.
