Originally published on Illuminem

Companies do not need to wait before taking responsibility for ongoing emissions during their transition to net zero. Through Ongoing Emissions Responsibility (OER), recognised in the SBTi Corporate Net-Zero Standard V2.0, they can direct finance towards credible climate action and communicate those investments transparently as contributions.
For an introduction to OER and how carbon credits fit within it, see Part 1 of this series. Read How carbon credits fit into a credible net-zero strategy
Many companies are already applying the principles of OER without realising it. Businesses that are investing in high-integrity carbon credits or funding climate advocacy efforts are already following a form of OER. Framing this within an OER strategy now helps claim this credibly as a contribution to climate action within the bounds of the SBTi Net Zero Standard.
Here's how to get started in three simple steps.
Step 1 – Define goals
Once a company has calculated its emissions, established a credible carbon fee, and produced its budget, the first step is to define what goals that investment should achieve.
In practice, most OER investments will support one of three goals:
- Unlocking near-term decarbonisation by helping the company, its suppliers or its sector overcome practical barriers to emissions reductions. This can include capacity building, innovation and more.
- Laying the groundwork for long-term net zero through research and development (R&D), infrastructure investment and policy advocacy.
- Contributing to global mitigation now by directing finance towards projects that deliver verified emissions reductions or removals beyond the company’s value chain, including by using high-integrity carbon credits.
The right balance will depend on a company's circumstances. A business waiting for a major infrastructure investment to mature might choose to direct more of its carbon fee proceeds to verified emission reductions to communicate impact in the interim. A company that has struggled to identify the right solutions might shift its balance towards longer-term capacity building or R&D.
Step 2 – Choose the right investments
With goals defined, the next step is to identify the specific investments best suited to deliver them. This is where scope, action type and mechanism come together.
Organisations can work through these in sequence:
- Scope: Define explicitly what you are trying to achieve. This means deciding which outcomes the OER investment should deliver, and how these connect to your broader climate strategy and organisational priorities. The goals set out above are the destination. For example, a company aiming to contribute to global mitigation will focus on projects and programmes beyond its value chain, whereas a company prioritising near-term decarbonisation may focus on its own suppliers or sector.
- Actions: Identify the actions that need to happen to deliver within that scope. This means specifying the types of activity your investment should support, from carbon abatement, nature protection, advocacy, capacity building, or a combination. This step moves from what you want to achieve to what actually needs to occur. A company focused on global mitigation and waiting for longer-term infrastructure investments to reduce its own emissions may decide to contribute to global mitigation in the meantime.
- Mechanisms: Select the tools that credibly deliver those actions. Choose mechanisms that can deliver the activities identified above and meet relevant quality criteria. The same goal can often be served by more than one mechanism; the right choice depends on what the action requires. In the mitigation example above, this could include verified carbon credits, other certified projects, or portfolio approaches.
Where companies use carbon credits, they should prioritise credits that are independently verified, additional and aligned with the climate and development outcomes they are intended to support. From 2026, where Paris Agreement-aligned credits are available, organisations should prioritise them alongside other markers of quality. While credits issued before 2026 will not be Paris Agreement-aligned, earlier vintages can still represent a credible and valuable investment where they meet robust integrity requirements and deliver genuine climate and sustainable development outcomes.
Step 3 – Communicate impact credibly
Once an OER strategy is in place, a company should communicate it transparently. Communications should reflect both the company’s overall OER strategy and how it has allocated its funding, as well as the real-world outcomes its funding has achieved, including carbon and beyond-climate benefits for people and nature.
For non-mitigation investments, particularly those that are more speculative, organisations should consider how they can illustrate the intent of their funding and the methods in place to ensure they achieve the right outcome.
The most compelling claims combine both approaches. A company might disclose how its OER budget has been allocated, whilst highlighting a specific project that connects to its sourcing regions or communities of strategic relevance. Grounding the claim in something concrete and meaningful illustrates the impact those investments are helping to deliver.
In any case, the claim should be framed as a contribution to climate action, rather than a claim that the companies' own emissions have been eliminated.
Keep it simple
The principle behind OER is simple. A company doesn’t need to wait for a perfect transition plan, or to have reduced emissions by a set amount before taking responsibility for today’s emissions. Invest in activities that accelerate your own transition or contribute meaningfully to broader climate goals. Frameworks and accounting mechanics matter, but they should support action rather than distract from it.
Many of the solutions needed to cut emissions, strengthen resilience and deliver benefits for people and nature already exist. What they need is large-scale, sustained, well-directed investment. OER gives companies a practical way to begin making those investments, while continuing to reduce emissions across their own operations and value chains.
