Recommendations from UN’s High-Level Expert Group on the Net Zero Emissions Commitments of Non-State Entities

Anna Triponel

November 11, 2022
Our key takeaway: Non-state actors, including businesses and financial institutions, are essential to get the world to net zero before 2050. To peak global emissions by 2025 and cut them in half by 2030, non-state actors need to align actions and investments with current commitments. A UN-commissioned group of experts chosen by the UN Secretary General has assessed how to get these actors to implement high‑quality net zero pledges and plans. They have ten recommendations for us. Their recommendations combine a “focus on equity and the urgency of the science” because, in their words, “the planet cannot afford delays, excuses, or more greenwashing.”

The UN’s High-Level Expert Group on the Net Zero Emissions Commitments of Non-State Entities published ‘Integrity Matters: Net Zero Commitments by Businesses, Financial Institutions, Cities and Regions’ (November 2022), an assessment of businesses’, financial institutions’ and local governments’ net zero pledges. The Expert Group formulates ten recommendations to non-state entities, which can be grouped into three key themes:

  • Aligning commitments with actions to reduce emissions and deforestation and reduce investments in fossil fuels (1. Announcing a Net Zero Pledge; 2. Setting Net Zero Targets;  3. Using Voluntary Credits; and 5. Phasing out of Fossil Fuels and Scaling Up Renewable Energy): In four of its recommendations, the Expert Group suggests that non-state actors make their net zero pledges “a commitment by the entire entity, made in public by the leadership”, and aligned with immediate emissions reductions and its capital expenditures. The group clarifies that net zero commitments should focus on reducing absolute emissions across the full value chain (scopes 1, 2 and 3), while carbon credits are used to complement these efforts to go “above and beyond efforts to achieve 1.5ºC aligned targets.” “Non-state actors cannot buy cheap credits that often lack integrity instead of immediately cutting their own emissions across their value chain.” Additionally, the commitments should not be undermined with investments in fossil fuels or contributions to deforestation, peatland loss and the destruction of remaining natural ecosystems. “Non‑state actors cannot claim to be net zero while continuing to build or invest in new fossil fuel supply. Coal, oil and gas account for over 75% of global greenhouse gas emissions.”
  • Committing to a Just Transition Plan. (4. Creating a Transition Plan; 7. People and Nature in the Just Transition; and 9. Investing in Just Transitions): Non-state actors are urged to “share their comprehensive net zero transition plans detailing what they will do to meet all targets, align governance and incentivise structures, capital expenditures, research and development, skills and human resource development, and public advocacy, while also supporting a just transition.” Businesses, in particular, should demonstrate how they are contributing to the "delivery of a net zero and climate‑resilient economy in a way that delivers fairness and tackles inequality and injustice” and “participate in developing country-led initiatives to decarbonise and provide renewable energy access, such as Just Energy Transition Partnerships (JETPs) or other country-level just transition frameworks.” Net-zero transition plans are expected to demonstrate contributions to economic development in operating regions, including skills development for the just transition, resilience, inequality, gender and energy access issues.
  • More transparency, reporting, governance & regulation to counteract greenwashing (6. Aligning Lobbying and Advocacy; 8. Increasing Transparency and Accountability; and 10. Accelerating the Road to Regulation): Transparency and regular disclosure of net-zero commitments and progress on these targets are recommended to increase the accountability of non-state entities and “to prevent dishonest climate accounting and other actions designed to circumvent the need for deep decarbonisation.” Standardised reporting, in accordance with open formats and platforms that can feed into the UNFCCC Global Climate Action Portal, is recommended. Additionally, non-state actors and businesses, especially, are expected to align their advocacy strategies and governance structures to climate commitments. “Non-state actors cannot lobby to undermine ambitious government climate policies either directly or through trade associations or other bodies.” They should also align capital expenditures and executive compensation and targets with climate commitments. Finally, the Expert Group calls “for regulation starting with large corporate emitters including assurance on their net zero pledges and mandatory annual progress reporting.” Non-state actors’ emissions and net-zero commitments are to be regulated to “avoid fragmentation that can slow the transition and ensure a level playing field.”

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