The development of the ISO 14060 Net Zero Aligned Organizations Standard represents one of the most significant opportunities to establish a globally consistent benchmark for credible organisational net zero claims. As part of the current consultation on the draft standard, we recommend a number of targeted improvements to strengthen environmental integrity and ensure the standard delivers durable, science-aligned net zero.
This standard could become an influential reference point for corporate climate strategies, procurement requirements, assurance processes and, potentially, future regulation. It therefore matters not only how the standard defines net zero, but also how it treats the transition to it in terms of both reducing emissions to only those residual and fully counterbalancing them with greenhouse gas removals.
The Net Zero Lab welcomes the draft’s emphasis on the prioritisation of emissions reductions over offsetting and the steps it puts in place to emphasise that concepts such as residual emissions are indeed dynamic over time, and need to be both fully neutralised and reduced over time. At the same time, we identify several areas where the draft should be strengthened to ensure that organisational net zero represents a contribution to a durable net zero, rather than a temporary one globally.
The International Organization for Standardization, or ISO, is an independent international standard setting organisation composed of national standards bodies from over 160 countries.
ISO standards are generally voluntary. However, they can have substantial real-world influence because they are frequently incorporated into certification systems, procurement requirements, financial frameworks and national regulation. ISO Standards can therefore shape how concepts such as “net zero” are interpreted and implemented across jurisdictions and sectors.
Building off of the earlier ISO Net Zero Guidelines, ISO/DIS 14060 is intended to establish requirements for organizations to develop and implement a net zero-aligned pathway. It addresses topics such as organizational emissions boundaries, greenhouse gas inventories, transition planning, mitigation target-setting, residual emissions, carbon dioxide removals (CDR), reporting, assurance and claims. It also distinguishes between four stages of organizational claims: a net zero aspiration, a net zero-aligned transition plan, net zero-aligned progress and achievement of organizational net zero. The draft consultation opened on 17 June 2026 and is scheduled to close on 9 September 2026.
At the centre of the draft is the concept of organizational net zero, defined in Clause 3.1.1 as a condition in which emissions within an organization’s greenhouse gas inventory have been reduced to residual emissions, with those residual emissions counterbalanced by anthropogenic carbon dioxide removals. This is broadly the right calibration for net zero to be reached but still leaves three key questions unanswered:
Weakness in any of these areas could allow organizations to claim net zero while continuing avoidable emissions or relying on temporary removals that do not address the long-lived warming effect of fossil carbon in the atmosphere. Our submission therefore groups its recommendations around a series of connected themes.
Greenhouse gas removal should include durable storage. The draft defines a greenhouse gas removal in Clause 3.2.6 simply as the withdrawal of a greenhouse gas from the atmosphere. This is incomplete for the purposes of net zero because withdrawal alone does not guarantee a durable climate benefit. Carbon may be removed from the atmosphere and then rapidly released again. We recommend revising Clause 3.2.6 to align more closely with the IPCC definition of removals as anthropogenic activities that remove greenhouse gases from the atmosphere and durably store them in geological, terrestrial or ocean reservoirs, or in products. This would ensure that removal is not treated as complete without storage and would provide a stronger conceptual foundation for the necessary durability requirements concerning CDR in Clause 12.4.2.
Residual emissions must be genuinely unavoidable. The draft defines residual emissions in Clause 3.2.11 as those remaining after all “technically and economically feasible” reductions have been implemented. The concern is that economic feasibility is assessed primarily from the perspective of the individual organization. Without objective benchmarks, one organization could classify an emissions source as economically infeasible because it has not allocated sufficient capital to mitigation, while another organization in the same sector might implement the available measure. A company’s willingness to pay or preference to offset should not determine what counts as residual. We recommend revising Clause 3.2.11 so that residual emissions are limited to those that cannot reasonably be eliminated after the application of best available and emerging mitigation options.
The standard should clarify in Clause 3.2.11 and the associated feasibility test in Clause 10.3 that an organization’s current financial position, capital-allocation choices or preference for purchasing removals does not in and of itself mean an emissions source is categorically unavoidable and thus residual.
Removal prices should not determine whether abatement is feasible. Under Clause 10.3, paragraph b)(1), the technical feasibility test appears to permit organizations to compare the cost of emissions reductions with the cost of durable removals. This creates a structural problem. If removal credits are cheaper than eliminating an emissions source, an organization may have an incentive to classify the emissions as residual even where abatement is technically possible. Removal cost is not a valid test of whether emissions are unavoidable. The price of compensating for pollution should not become the benchmark for deciding whether the pollution must continue. Given the finite global carbon budget which the draft itself recognises, all feasible emission reductions should be actioned.
We therefore recommend deleting the comparison with removal costs from Clause 10.3, paragraph b)(1) and instead requiring assessment against the best available technology; a credible sectoral transition pathway; expected availability of abatement technology by the target year; and a transparent abatement-cost threshold or internal carbon price consistent with net zero. Similarly, the organization-specific affordability test in Clause 10.3, paragraph b)(2) should be replaced with objective sectoral benchmarks. Where an organization claims financial incapacity, it should disclose relevant capital-allocation decisions, available finance, dividends and material climate-related lobbying.
The draft generally establishes a clear distinction between emissions reductions and carbon credits. We strongly support Clause 5.4 which states that carbon credits cannot be used to claim progress against interim or net zero emissions-reduction targets. However, the remedial action provisions in Clause 16.6, including the provisions concerning missed interim targets and excess emissions, allow credits to be used after an organization has fallen short of its pathway. This creates the live risk of corporates utilising carbon credits to compensate for emissions reductions that otherwise should have occurred within the organization or its value chain. The fact that credits are described as “remedial” does not change their practical function. If credits allow an organization to retain a progress claim despite missing its target (even just for a limited timeframe), they may weaken the incentive to make deep, near-term reductions. By contrast the IMO’s Net Zero Framework has remedial units at $380 USD per ton, a rate which significantly incentivises delivering the target in the first place.
We recommend that carbon credits should be removed from the permissible remedial actions under Clauses 5.4 and 16.6. In the case that some limited remedial use is retained, Clauses 5.4 and 16.6 should require that their use be restricted to cases where all feasible reduction measures have been exhausted, and require explicit disclosure of the reliance on credits in any accompanying claim.
The treatment of excess emissions in Clause 16.6.4 should also be revised. Financing mitigation elsewhere does not erase an overshoot of the organization’s emissions budget. Excess cumulative emissions should instead be quantified, disclosed and carried forward, with remediation focused first on accelerated reductions within the organization’s inventory boundary. We recognise that separate climate-finance contributions can still be valuable under Clause 11.3, but they should be reported as contributions to global climate action, rather than as substitutes for reducing or counterbalancing the organization’s own emissions in order to prevent greenwashing.
The draft contains mandatory quality criteria for removals used to counterbalance residual emissions in Clause 12.4. However, carbon credits used for other purposes under Clause 5.4 are not subject to an equivalent mandatory quality framework. This puts it at odds with resources like the Oxford Principles for Net Zero Aligned Carbon Offsetting. Indeed, the only relevant cross reference appears in Clause 5.4, Note 5, which points towards criteria for environmental commodity certificates. Yet Clause 3.3.9, Note 3 expressly states that carbon credits are not environmental commodity certificates. This creates both a drafting contradiction and a substantive integrity gap.
There is no principled reason why carbon credits used as remedial action or as part of an organization’s contribution to global net zero should face a lower quality threshold than removal credits used at net zero. Literature has demonstrated that a wide range of carbon crediting pathways face environmental integrity challenges (see Probst et al. 2024). Low-quality credits can consume organisational climate budgets without generating real additional mitigation and crucially divert revenue that otherwise could have gone towards meaningful mitigation.
The inappropriate cross-reference in Clause 5.4, Note 5 should be removed or corrected. A new normative requirement should then be added to Clause 5.4 requiring all carbon credits used under the standard to satisfy minimum quality criteria, including aspects such as robust additionality; regulatory surplus; conservative baselines; comprehensive leakage assessment; conservative treatment of uncertainty; no double issuance, double use or double claiming; independent validation and verification; transparent public registry information; environmental and social safeguards; ongoing monitoring; and reversal management and remediation arrangements.
Recognition by a carbon-crediting programme may provide evidence of quality, but Clause 5.4 should make clear that programme certification does not automatically establish compliance. For removals used to support a net zero achievement claim, Clause 12.4.1 should require that credits be issued under a programme whose requirements for removal activities are at least as stringent as those established by the Article 6.4 Supervisory Body for the Paris Agreement Crediting Mechanism. The existing criteria in Clauses 12.4.2–12.4.7 should remain as minimum characteristics that any eligible programme must address.
The additionality requirement in Clause 12.4.3 is currently expressed at a very high level. It does not specify how additionality should be assessed or what evidence is required. A one-sentence counterfactual test is insufficient to establish that credited removals would not have occurred without the intervention or the associated carbon finance.
Clause 12.4.3 should require an activity-specific additionality assessment covering: legal and regulatory requirements; common practice; financial additionality or material investment barriers; the causal role of carbon finance; conservative treatment where evidence is uncertain; and periodic reassessment at renewal or re-crediting. This would make additionality independently auditable rather than leaving it as a general principle.
The most significant environmental-integrity issue in the draft concerns the durability of carbon storage. Fossil carbon dioxide emissions add carbon to the active carbon cycle that would otherwise have remained stored underground. A portion of that CO₂ remains in the atmosphere for centuries to millennia. Counterbalancing those emissions with carbon stored temporarily in forests, soils or products does not necessarily provide an equivalent mitigation outcome.
Risk-management mechanisms cannot create physical durability. Clause 12.4.2, list item 2, permits removals expected to store carbon for less than 100 years, suggesting that risk-management mechanisms such as buffer pools or insurance may be used. These instruments can help manage project or financial risk. They do not, however, transform temporary storage into permanent storage. The further description that even this might not be mandatory is further cause for concern, indicating that this should at least be a “shall” provision.
We recommend the second bullet in Clause 12.4.2 should be deleted and replaced with a clear like-for-like rule:
The current 100-year threshold should not operate merely as a nominal requirement that can be satisfied through financial risk-management arrangements.
The transition to durable removals should have a clear end-state. Clause 12.2 requires organizations to increase the share of higher-durability removals over time and contemplates portfolios containing both nature-based and technological removals. Early investment across a broad portfolio can support innovation and market development as per the Oxford Principles for Net Zero Aligned Carbon Offsetting. But purchases intended to develop future removal capacity should be distinguished from removals eligible to support a net zero achievement claim.
We recommend revising Clause 12.2 to require dated milestones for transitioning from lower- to higher-durability storage; a clear end-state by the net zero target year; demonstration that the full counterbalancing portfolio complies with the like-for-like requirements in Clause 12.4.2; and separate reporting of early market-development purchases that are not eligible to support a net zero achievement claim.
Forward contracts and offtake agreements are emerging features of the voluntary carbon market today, particularly for novel CDR. They are important tools for financing emerging carbon-removal technologies. However, a commitment to deliver a removal in the future does not counterbalance emissions occurring today. The temporal relationship between emissions and removals is not sufficiently explicit in Clause 12.3.
We recommend Clause 12.3 should require net zero status for a reporting period to be supported only by removals that have been physically delivered; independently verified; issued in a registry; and retired for the organization’s claim. Forward purchases and future delivery agreements should be reported separately and should not count towards current net zero status until the removals have occurred and been verified. This distinction should also be mirrored in the reporting requirements in Clause 14.8, item b).
The draft requires consideration of durability and reversal risk in Clause 12.4.2, but it does not clearly establish who remains responsible if stored carbon is later released. This is particularly important where a project closes, a crediting programme ceases operating, a buffer pool becomes depleted or contractual responsibility expires before the end of the claimed storage duration.
We recommend Clause 12.4.2 should require an enforceable chain of responsibility from monitoring and reporting through to remediation and replacement. Any reversal should trigger prompt replacement with removals of at least equivalent quantity, quality and durability. The organization making the net zero claim should retain ultimate responsibility where the project developer, insurer, registry or crediting programme fails to provide an effective remedy. Outsourcing the removal activity should not allow the organization to outsource responsibility for the integrity of its claim: especially if other preventative tools were not used to minimise durability risks.
The prohibition in Clause 12.4.6 on more than one organization counting, using or claiming the same removal does not fully address the risk of double counting. One of the key areas this is true is the implications of Article 6 authorization and corresponding adjustments.
We recommend Clause 12.4.6 should be expanded to prohibit double issuance and double use and to require disclosure whether a corresponding adjustment applies or whether the mitigation also contributes to the host country’s nationally determined contribution. Where no corresponding adjustment applies, the claim language should accurately describe the activity as a contribution to host-country mitigation and should not imply exclusive compensation of the organization’s own emissions.
A durable organizational net zero claim must address the full value chain. The approach in Clause 10.6.2 allows organizations discretion in determining which Scope 3 categories are “significant”. This risks excluding categories that are difficult to quantify or influence, even where they represent a material share of the organization’s climate impact.
We recommend that Clause 10.6.2 should require inclusion of all material Scope 3 categories, including by establishing a minimum quantitative coverage threshold. Exclusion due to lack of data should also require time-bound plans to improve data and expand coverage. An organization should not be able to define the boundary of its net zero claim around the parts of its value chain that are easiest to manage.
The draft already contains important reporting requirements. However, aggregate disclosures may not allow stakeholders to assess whether residual emissions and removals are genuinely matched. For example, reporting a single total quantity of removals does not show whether the portfolio consists of direct air capture with geological storage, afforestation, soil carbon, biochar, carbon stored in products or a mixture of methods with very different durability characteristics.
Residual emissions should be disclosed in detail. Clause 14.8 should require annual disclosure of residual emissions by factors such as: Scope; source category; greenhouse gas; fossil or biogenic origin; quantity; expected atmospheric persistence; and the rationale and evidence used to classify each material source as residual. This information is necessary to assess whether or not adequate counterbalancing under Clause 12.4.2 has occurred.
Credits and removals should be disaggregated. The disclosure requirements for credits in Clause 11.3, item 4, should require the amount of credits purchased or retired to be reported by project type. Clause 14.8, item b) should likewise require the quantity of removals retired to be disaggregated robustly and to mandate a table matching residual emissions by gas and source to the removals used to counterbalance them, with an explanation of how durability and timing are equivalent.
Clause 15 permits first, second or third-party validation and verification. Internal review can be appropriate during the early stages of a net zero journey. However, a public claim that an organization has achieved or maintained net zero involves complex and potentially conflicted judgment calls. Therefore we recommend that Clause 15 require independent third-party validation of the organizational pathway and any residual emissions feasibility assessment as well as independent third-party verification of net zero achievement and annual maintenance claims. First- and second-party review may support net zero aspiration and transition-planning claims, but should not be sufficient for claims made under Clause 16.5.
A generic statement that an organization is “net zero” can conceal important limitations. It may not reveal the reporting year, organizational boundary, Scope 3 coverage, quantity of residual emissions or type of removals used. We recommend that Clause 16.5.2 should require every net zero achievement claim to be accompanied by or provide an immediately accessible link with a detailed description of the exact claim with reference to details on the period, organisational boundaries, residual emissions and any counterbalancing effort. Clause 16.5.2 should prohibit misleading claims that imply the organization has no emissions or that net zero is a permanent characteristic independent of a specific reporting period.
The remedial framework in Clauses 16.6.1–16.6.8 appears to allow an organization to continue referring to a net zero claim while outside its pathway, with a period of up to three years to restore net zero status. This is problematic because net zero is a condition that either exists for the relevant period or does not. Where emissions exceed the residual level, eligible removals are not delivered or stored carbon is reversed without replacement, the organization should immediately suspend its current net zero achievement claim.
Clauses 16.6.1 and 16.6.8 should require immediate suspension of the net zero achievement claim when the balance is no longer maintained. The organization may accurately state that it previously achieved net zero and is implementing a verified restoration plan. But it should not continue to describe itself as currently net zero. A new achievement claim should be permitted only once:
The draft appropriately encourages organizations to contribute to global net zero beyond their own value chains through Clause 11.3, including through climate finance, policy engagement, climate solutions and support for affected workers and communities. These actions are important and should be encouraged. But they should remain distinct from the accounting used to demonstrate progress against an emissions-reduction target or achievement of organizational net zero under Clauses 12 and 16.5. Organizations can and should finance mitigation, removals, adaptation and innovation beyond their value chains. The most credible approach is to report such activities under Clause 11.3 as additional contributions to global climate action, rather than presenting them as substitutes for reducing or counterbalancing the organization’s own emissions.
In sum, ISO/DIS 14060 is a strong foundation that can still be improved. The consultation now provides an opportunity to make the standard more robust in the areas that will ultimately determine whether its claims are environmentally credible.