On 6 November 2025, the SBTi released their second draft of the Corporate Net-Zero Standard (CNZS) V2 for public consultation, looking to update the current V1.3 standard. The draft provides clarity for those wishing to claim biomethane for scope reporting, and could stimulate further gGO demand.
The contents of the current draft incorporate feedback from the first public consultation in April 2025 , providing more detail on initiatives introduced previously but also containing new elements. The feedback period closes on 12 December 2025.
Sustainable bioenergy (including biomethane) has biogenic emissions; according to the related GHG Protocol these are recorded but not included in Scope 1 or 3 emissions totals. Thus, substituting fossil fuels for bioenergy alternatives can reduce scope emissions.
Overall, the draft is bullish for biomethane and biofuels, with strong recognition of the role of biogenic carbon sources. However, there are some niche use cases which may be negatively affected. The following provides an overview of some of the aspects of the draft affecting biomethane, grouped by the section they appear under in the draft.
This section of the draft deals with setting organisational boundaries and selecting the appropriate reference year.
Criteria C6.3 requires that bioenergy usage (and associated claims) document biomass feedstock characteristics, with the feedstock to be certified as sustainable. The certification will likely be similar to EC voluntary schemes where the Proof of Sustainability (PoS) document serves this purpose. However, the SBTi are developing their own third-party framework for certification – ideally this will align with EU norms.
The sustainability requirements could potentially put a damper on uncertified biomethane GO markets . In the current absence of clear guidelines for Scope 1 usage, some jurisdictions have allowed uncertified biomethane GOs to be used for emissions reporting, UK RGGOs being one example. Established SBTi guidelines requiring certified biomethane could remove legal ambiguity and leave uncertified GOs stranded. Nevertheless, there is a move towards having all production be certified, particularly for newer biomethane operations.
The SBTi now calls for “asset decarbonisation plans” (Criteria C11.2c) to be developed detailing how Scope 1 emissions are to be reduced, establishing a carbon budget to 2050 and establishing five-year milestones with respect to emission reductions.
In comparison to electrification, or green hydrogen, biomethane is in an ideal position to aid in short-term decarbonisation, if not long-term where the other two energy vectors are expected to be more prominent. Implementation of such asset decarbonisation plans should encourage forward demand for biomethane GOs over the next five years.
Establishing credible indicators aligned with net-zero by 2050.
Criteria C13 calls for the use of “credible measures” for Scope 1 targets. Much of this is predicated by the new Annex E in the draft proposal, which underpins the use of Environmental Attribute Certificates (EACs), which opens the door to biomethane gGOs for Scope 1 claims, the main proviso to usage being accurate representation of emission factors for associated feedstocks and fuels.
Criteria C18 sets thresholds for reporting (commodities which represent at least 5% of total Scope 3), with at least 95% of purchased volumes meeting reference intensity benchmarks. Table A.3 of the draft gives details of metrics, reference pathways, benchmarks, and methods.
Target setting for Scope 3 emissions will increase demand for related EACs representing reductions. Scope 3 represents the majority of reportable emissions; whereas smaller companies in a supply chain may not have to report on their Scope 1 emissions, their larger clients may be obligated to report on these same emissions as Scope 3.
However, Scope 3 demand is less immediate than Scope 1, as benchmarking is expected to commence only in 2030. There are criteria which clarify two use cases for EACs:
Criteria C19 enables Scope 3 reporting at the ‘activity pool’ level where traceability to an individual emission source is not feasible. Grid biomethane is not individually traceable, but entities connected (either withdrawing or injecting) to the EU gas grid can be considered part of the same activity pool. In this case unbundled EACs can be used to represent a Scope 3 emissions reduction.
Alternatively, C20 allows sector-level sourcing, where sufficient green commodities to decarbonise cannot be sourced (via grid or physical delivery). This may be the case for a natural gas consumer with no feasible biomethane supply in their procurement chain. They may be able to reduce their Scope 3 inventory via EACs, which would be considered support for low-carbon sources at the sector level. However, this is an interim solution, with a move towards direct physical connectivity (which includes activity pool arrangements) required.
C19 appears synonymous with the general use of GOs for grid-injected biomethane in the EU.
C20 could apply to GO transfers between EU and non-EU countries (for example, a UK RGGO ex-domain cancellation for an organisation in the Netherlands). on the other hand, FuelEU Maritime pooling arrangements, where no GOs are involved, would be considered sector-level sourcing (no physical connectivity). A widespread use of pooling under FuelEU maritime, could mean that C20 in isolation is a bearish signal for gGOs used for Scope 3 reporting,
Under the SBTi general integrity principles, avoided emissions are not eligible for scope reductions (Principle 1.2), and may only count as a mitigation outcome. This has implications for manure biomethane.
Under the Renewable Energy Directive (RED), the avoided emissions associated with processing manure for biogas are recognised as a “manure credit”, further reducing Carbon Intensity (CI) of the manure biomethane beyond what is associated with biogenic CO2. This often leads to negative CI scores, and additional value in schemes which adopt RED lifecycle accounting, namely FuelEU and RED transport mandates.
Under the SBTi draft, an organisation using manure biomethane may only reflect the biogenic emissions from use, effectively reducing Scope 1 or Scope 3 emissions equivalent to the emissions associated with the fossil gas displaced. The avoided emissions, which generate negative CI scores under RED-schemes, would not reduce Scope emissions and only be treated as a mitigation outcome, similar to a carbon credit with associated low value. As a result, manure biomethane delivers less scope-related value under SBTi compared to schemes that reward negative CI values.
While this is bearish for those who expected negative CI biomethane to fully benefit under SBTi, the treatment mirrors current EU ETS practice. In the ETS when using renewable fuels to reduce obligations, there is no benefit to having a GHG intensity which results in emission savings beyond meeting the required sustainability threshold.
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