Submission to the High-Level Expert Group on the Net-Zero Emissions Commitments of Non-State Entities

In June 2022, the UN Secretary-General’s High-Level Expert Group on the Net-Zero Emissions Commitments of Non-State Entities launched a public consultation on how to hold non-state of entities accountable for net zero pledges and deliver immediate climate action.

This report consists of a submission to this consultation. It focuses on the topics of standards, credibility criteria, transparent governance and regulation, drawing on work from the Climate Change Laws of the World project, the Grantham Research Institute’s Sustainable Finance research theme and the Transition Pathway Initiative.

Main messages and recommendations

• While there has been recent wave of net zero pledges made by a range of actors, including companies, investors, civil society and subnational governments, more needs to be done to ensure the accountability and credibility of these commitments.
• Standards for net zero must be sector-specific and include interim targets. They should include sectoral benchmarks aligned with the target of limiting warming to 1.5°C to result in effective decarbonisation. Emissions reductions must be the priority, with high-integrity offsets used only for residual emissions.
• Examples of how existing standards have been used in legal challenges relating to net zero commitments can advance our understanding of what credible commitments look like and also indicate where credibility most urgently needs to be strengthened.
• An important credibility consideration is whether a company’s climate lobbying – direct or indirect – is aligned with its stated climate commitments and goals. The HLEG should incorporate into its recommendations on the credibility of non-state actor commitments a set of core principles on corporate climate lobbying derived from the academic literature.
• Standards for net zero should also include transparency requirements, such as setting clear plans and targets, carrying out high-integrity monitoring, reporting and verification, and clarifying processes by which grievances may be raised by civil society and others. Transparency should also be conceived of broadly, including, for example, financial information as well as information regarding emissions reductions.
• The net zero transition will be most effectively governed by regulatory action from national and subnational governments. Net zero governance should be aligned with existing international standards and frameworks for responsible business conduct. It is also important to account for differences in regulatory capacity across states.