SBTi opens consultation on urgent updates to FLAG criteria

SBTi updates FLAG criteria to align deforestation rules with EU regulation

The Science Based Targets initiative has launched a public consultation to revise its Forest, Land and Agriculture guidance. The changes focus on implementation timelines and no-deforestation commitments. Companies in land-intensive sectors now face clearer deadlines and stricter documentation requirements.

SBTi describes the review as targeting two criteria that need urgent updates. The consultation ran for 30 days and sought stakeholder feedback on five proposed changes. The organization states the revisions will keep the guidance scientifically sound while making it more practical for businesses.

This consultation marks a significant shift in how land-sector emissions are managed within science-based targets. For UK businesses in agriculture, food production, forestry, and related supply chains, the updated criteria will affect compliance timelines and reporting obligations. The changes also bring FLAG guidance closer to EU regulatory standards, which matters for companies trading with European markets.

Five proposed changes to FLAG target-setting requirements

The consultation addressed five specific updates to the FLAG criteria. Each change aims to clarify expectations and align the framework with evolving regulations.

First, companies that already have non-FLAG targets must now set a FLAG target before their mandatory five-year review period ends. This replaces the previous requirement to set targets within six months of the GHG Protocol Land Sector and Removals Guidance publication. The change gives businesses more time to integrate land-sector accounting into their existing frameworks.

Second, first-time FLAG target setters face a new deadline. They must eliminate deforestation within two years after submitting FLAG targets for validation. However, there is an absolute cutoff of 31 December 2030. This creates a clear endpoint regardless of when companies begin the process.

Third, companies must use a deforestation cutoff date earlier than their first FLAG target submission. Previously, SBTi only recommended using a 2020-or-earlier date. The new requirement makes this mandatory, which means businesses can no longer count recent deforestation-free periods toward their commitments.

Fourth, the list of covered commodities now aligns with the EU Deforestation Regulation. This harmonization matters for companies operating across UK and European supply chains. It reduces the complexity of managing different commodity lists for different frameworks.

Fifth, SBTi has clarified what documentation companies must publish. Businesses need to show how they will meet no-deforestation commitments. The updated guidance specifies the evidence required, which should reduce ambiguity during the validation process.

Timeline for implementation and approval process

SBTi expects to publish the final updated criteria no earlier than Q1 2026. The organization will release a Basis for Conclusions report alongside the revised criteria. This report will explain the rationale behind each change and how stakeholder feedback influenced the final decisions.

Once published, the updated guidance takes effect immediately for new FLAG target submissions. Companies that have already submitted targets under the previous criteria will not need to resubmit. However, they will need to align with the new requirements during their five-year review period.

The timeline reflects SBTi’s approach to balancing urgency with thorough consultation. The Technical Council approved revised Criteria 1 and 4 on 18 December 2025 after a public consultation that ran from 7 October to 6 November 2025. This process mirrors the substantial stakeholder engagement seen in the original FLAG development, which received 1,582 comments from 165 organizations in 2022.

What the changes mean for land-intensive UK businesses

The revised FLAG criteria create more structured compliance pathways for businesses in agriculture, food production, forestry, and related sectors. These industries face significant emissions and reputational risks from land-use change and deforestation. The updated guidance addresses both.

For manufacturers and food producers, the alignment with EU Deforestation Regulation simplifies cross-border compliance. Companies trading with European markets no longer need to maintain separate commodity tracking systems for SBTi and EU requirements. This reduces administrative burden and potential for errors.

The mandatory deforestation cutoff date affects supply chain verification. Businesses must now demonstrate that their sourcing practices exclude deforestation from a date earlier than their target submission. This requires robust traceability systems and supplier engagement. Companies without strong supply chain visibility may need to invest in tracking infrastructure or change sourcing relationships.

The two-year deadline for eliminating deforestation presents an operational challenge. Many businesses rely on complex, multi-tier supply chains where land-use practices are difficult to verify. Achieving deforestation-free sourcing within 24 months requires rapid supplier audits, contract renegotiations, and potentially switching to certified sources. Smaller businesses with limited procurement resources may find this timeline particularly demanding.

The 31 December 2030 absolute cutoff creates a fixed endpoint. Companies that delay FLAG target-setting do not gain additional time to eliminate deforestation. This removes any incentive to postpone action. Businesses planning to set FLAG targets should therefore start supply chain assessments and deforestation elimination work immediately, regardless of their intended submission date.

For businesses already holding non-FLAG targets, the five-year review deadline provides a structured transition. However, it also means that land-sector emissions can no longer be deferred indefinitely. Companies in sectors like food retail, hospitality, or manufacturing with agricultural inputs will need to account for FLAG emissions during their next target review. This expands the scope of climate action for many UK SMEs.

The documentation requirements affect transparency expectations. Companies must publish clear evidence of their deforestation elimination plans and progress. This information becomes part of the public record and may be scrutinized by investors, customers, and advocacy groups. Businesses should therefore ensure their commitments are credible and backed by verifiable data.

Essential facts about the FLAG criteria revision

• SBTi’s public consultation on FLAG criteria ran for 30 days and addressed five proposed changes to implementation timelines and deforestation commitments.
• Companies with existing non-FLAG targets must set a FLAG target before their five-year review period ends, rather than within six months of the GHG Protocol Land Sector and Removals Guidance publication.
• First-time FLAG target setters must eliminate deforestation within two years of submitting targets for validation, with an absolute deadline of 31 December 2030.
• The list of covered commodities now aligns with the EU Deforestation Regulation, simplifying compliance for businesses operating in UK and European markets.
• Updated criteria are expected no earlier than Q1 2026 and will take effect immediately for new FLAG target submissions once published.
• The revised guidance requires companies to use a deforestation cutoff date earlier than their first FLAG target submission, making the previously recommended 2020 date mandatory.
• SBTi received 1,582 comments from 165 organizations during the original FLAG development in 2022, indicating substantial stakeholder interest in land-sector guidance.

How UK businesses should approach FLAG target-setting

The updated FLAG criteria require businesses to take a more proactive approach to land-sector emissions. Waiting until the last moment to set targets will compress timelines and increase compliance pressure. Companies should therefore begin supply chain assessments now, even if they do not plan to submit FLAG targets immediately.

Supply chain traceability is central to meeting the new requirements. Businesses need to know where their agricultural commodities originate and whether those sources involve deforestation. This means mapping supplier relationships beyond the first tier. For companies with limited visibility into their supply chains, working with procurement specialists or sustainable procurement advisors can help establish the necessary tracking systems.

The two-year deforestation elimination window demands early supplier engagement. Companies should communicate the new requirements to suppliers as soon as possible. Many agricultural suppliers may need time to adjust their practices or obtain certification. Starting these conversations early increases the likelihood of maintaining existing relationships while meeting compliance deadlines.

Documentation standards will be scrutinized during validation. Businesses should establish clear internal processes for recording deforestation elimination activities. This includes supplier audits, certification records, contract terms, and progress reports. Maintaining comprehensive documentation from the outset reduces the risk of validation delays or rejections.

For businesses already holding science-based targets, the five-year review presents an opportunity to integrate FLAG systematically. Rather than treating land-sector emissions as an isolated add-on, companies can use the review process to assess their full value chain impact. This comprehensive approach often reveals additional reduction opportunities and strengthens overall climate strategy.

Smaller businesses may benefit from sector-specific guidance and peer learning. Industry associations and trade bodies often develop shared approaches to complex compliance requirements. Participating in sector initiatives can reduce individual burden while building collective capability. Additionally, training programs focused on emissions accounting and target-setting can help internal teams understand the technical requirements without needing to hire specialized consultants immediately.

The alignment with EU Deforestation Regulation also creates an opportunity for regulatory efficiency. Businesses that invest in systems to meet SBTi FLAG requirements may find they simultaneously satisfy EU compliance obligations. This makes the investment more cost-effective and justifiable to senior leadership. Companies should therefore assess both frameworks together when planning their compliance approach.

Finally, businesses should monitor SBTi communications closely between now and Q1 2026. The final criteria may include additional clarifications or adjustments based on consultation feedback. Staying informed ensures that internal planning reflects the most current requirements. Subscribing to SBTi updates and participating in industry forums can help businesses stay ahead of changes.

Where to find official guidance and regulatory information

SBTi provides comprehensive resources on its website for businesses developing FLAG targets. The FLAG sector page includes the current criteria, technical guidance, and updates on the consultation process. Businesses should refer to this page for the most current version of the requirements.

The GHG Protocol Land Sector and Removals Guidance provides the accounting framework that underpins FLAG targets. Understanding this protocol is essential for companies developing their inventory of land-sector emissions. The guidance explains how to account for emissions and removals from agriculture, forestry, and other land uses.

For businesses trading with European markets, the EU Deforestation Regulation sets out the legal requirements for deforestation-free commodities. Reviewing this regulation alongside the FLAG criteria helps companies understand how the two frameworks interact and where compliance efforts can be coordinated.

UK businesses may also benefit from sectoral guidance provided by industry bodies. Organizations like the Food and Drink Federation, the Agriculture and Horticulture Development Board, and the Forestry Commission offer sector-specific resources on sustainable sourcing and emissions reduction. These resources often translate regulatory requirements into practical actions for specific industries.

Companies seeking support with carbon reporting and science-based target development should assess their internal capability before starting the FLAG process. The complexity of land-sector accounting often requires specialized knowledge, particularly for businesses without existing environmental management systems. Working with advisors who understand both the technical requirements and the commercial realities facing UK SMEs can make the process more manageable.