SBTi calls for input on updated Forest, Land and Agriculture Standard

SBTi launches consultation on FLAG deforestation deadlines and target timings

The Science Based Targets initiative has opened a 30-day public consultation on urgent changes to its Forest, Land and Agriculture criteria. The proposal focuses on two specific areas: when companies must set FLAG targets, and how they prove progress on deforestation-free supply chains. Businesses with land-related emissions need to understand what is changing and why it matters for their target-setting obligations.

The consultation closes on 6 November 2025 at 11:59 PM Pacific Time. Updated criteria are expected no earlier than the first quarter of 2026. This represents a rapid revision cycle for a standard that became mandatory only in April 2023.

SBTi says the changes are necessary because previous deforestation deadlines have passed. Consequently, parts of the existing framework have become difficult to apply without reducing scientific ambition. The proposal attempts to preserve credibility while reflecting current policy and the realities facing businesses with complex commodity supply chains.

Five specific changes under consultation

SBTi identified two FLAG criteria requiring urgent revision. Criterion 1 governs when companies must set a FLAG target. Criterion 4 covers no-deforestation commitments. The consultation asks for feedback on five proposed changes across these two areas.

First, companies that already hold non-FLAG targets would need to set a FLAG target by the end of their mandatory five-year review period. This replaces the previous requirement to submit within six months of the GHG Protocol Land Sector and Removals Guidance being published. The change extends the deadline significantly for many businesses.

Second, companies setting FLAG targets for the first time would have up to two years after submission for validation to eliminate deforestation. However, the proposal includes an absolute backstop deadline of 31 December 2030. This creates a dual timeline structure with both relative and fixed dates.

Third, companies would be required to use a deforestation cutoff date that predates submission of their first FLAG target for validation. The current framework merely recommends a cutoff date of 2020 or earlier. The proposed change makes this mandatory rather than advisory.

Fourth, the list of commodities covered under no-deforestation commitments would be updated to align with the EU Deforestation Regulation. This responds to regulatory developments in Europe that have created new compliance obligations for businesses trading in forest-risk commodities.

Finally, SBTi proposes to clarify the documentation companies must publish to demonstrate how they will deliver their no-deforestation commitments. This addresses practical questions about evidence and transparency that have emerged during implementation.

How FLAG targets work and why they became mandatory

FLAG is the Science Based Targets initiative framework for companies with land-related emissions. It applies especially to sectors such as agriculture, forestry, and food production. These industries face unique challenges because their emissions profiles differ substantially from energy or manufacturing businesses.

The original FLAG guidance emerged from extensive consultation in 2022. That process generated 1,582 comments from 165 organizations. SBTi published the first version of the framework following this input. FLAG targets became mandatory on 30 April 2023 for companies setting or updating science-based targets.

Since then, SBTi has been refining the framework based on implementation experience. The organization published FLAG Guidance Version 1.2 as a major revision. The SBTi Technical Council approved these changes on 18 December 2025, with an effective date of 19 March 2026.

Version 1.2 includes the five targeted updates to Criteria 1 and 4 now under consultation. It also temporarily suspends use of the timber and wood fiber pathway in the FLAG Target-Setting Tool. A revised version of this pathway will be released later. Therefore, companies in forestry sectors face additional uncertainty about methodology.

Why the deforestation deadline became unworkable

The current consultation responds to a practical problem that has made parts of the FLAG criteria difficult to enforce. Previous deforestation deadlines have already passed for many companies. This created a situation where businesses could not comply retrospectively, even if they wanted to demonstrate ambition.

SBTi needs to maintain scientific credibility while acknowledging implementation realities. The organization cannot simply ignore missed deadlines without appearing to weaken its standards. Similarly, it cannot impose impossible retrospective requirements without losing the participation of businesses that are otherwise committed to science-based targets.

The proposed changes attempt to resolve this tension by creating forward-looking deadlines that preserve ambition. The absolute backstop of 31 December 2030 ensures that no company can delay indefinitely. Meanwhile, the two-year implementation window for new FLAG targets recognizes the complexity of commodity supply chains.

External regulatory developments have added pressure for alignment. The EU Deforestation Regulation creates legal obligations for businesses trading in cattle, cocoa, coffee, palm oil, rubber, soy, and wood. Companies now face parallel compliance frameworks that do not always use identical definitions or timelines. Therefore, SBTi is attempting to reduce friction between voluntary target-setting and mandatory regulation.

What this means for companies with land-intensive operations

Businesses with significant land-related emissions need to assess whether these proposed changes affect their target-setting obligations. If you already hold non-FLAG targets, the revised timeline for adding a FLAG target could provide additional breathing room. However, you will still need to act within your five-year review period.

For companies setting FLAG targets for the first time, the two-year implementation window for deforestation elimination creates a clear planning horizon. Nevertheless, the 31 December 2030 absolute deadline means you cannot delay indefinitely. Businesses submitting targets in late 2028 or 2029 would face very tight implementation timelines.

The requirement for a mandatory deforestation cutoff date changes the compliance landscape. Previously, you could treat the 2020 cutoff as guidance rather than obligation. Under the proposed changes, you would need to demonstrate that your cutoff date predates your first FLAG target submission. This affects how you document your supply chain baseline.

The alignment with EUDR commodity lists matters for businesses trading into European markets. If your commodities fall under both frameworks, you face parallel obligations with potentially different requirements. Understanding where these frameworks overlap and where they diverge becomes important for efficient compliance.

Documentation requirements will become more explicit under the proposed changes. You will need to publish clearer evidence of how you plan to deliver your no-deforestation commitments. This goes beyond simply stating an intention. It requires demonstrable plans, supplier engagement strategies, and monitoring systems.

Key details for target-setting and compliance planning

The consultation period runs for 30 days and closes on 6 November 2025 at 11:59 PM Pacific Time. Businesses affected by FLAG criteria should consider responding, especially if implementation challenges are not fully addressed by the proposed changes. SBTi has historically been responsive to substantive feedback from the business community.

Updated criteria are expected no earlier than the first quarter of 2026. Therefore, companies planning target submissions in late 2025 or early 2026 face uncertainty about which version of the criteria will apply. This creates a practical challenge for businesses with board approval cycles or investor reporting deadlines tied to specific dates.

FLAG targets have been mandatory since 30 April 2023 for companies setting or updating science-based targets. If you are approaching a target review or setting targets for the first time, you need to include FLAG emissions if they exceed certain thresholds. The current thresholds and sector definitions remain unchanged by this consultation.

Version 1.2 of the FLAG Guidance becomes effective on 19 March 2026. This version includes the five targeted updates under consultation, assuming they are approved following the feedback period. The Technical Council approved this version on 18 December 2025, giving businesses roughly three months’ notice before implementation.

The timber and wood fiber pathway remains suspended until SBTi releases a revised methodology. Companies in forestry sectors cannot currently use this pathway in the FLAG Target-Setting Tool. No timeline has been published for when the revised pathway will become available. Consequently, forestry businesses face extended uncertainty about how to set valid FLAG targets.

SBTi has confirmed that development of FLAG Standard Version 2 will follow a structured process. This will include implementation experience, evidence gathering, public consultation, pilot testing, and expert working groups. The timeline will be shaped by the organization’s 2026 to 2030 strategy and its standard-development procedures. Therefore, businesses should expect ongoing refinement rather than a stable rule set.

Balancing scientific credibility with operational reality

This consultation reveals three competing pressures that SBTi is attempting to reconcile. First, the organization must maintain scientific credibility. Targets need to align with climate science and contribute to limiting global warming to 1.5 degrees Celsius. Weakening standards to accommodate business challenges would undermine the entire framework.

Second, SBTi must respond to evolving regulation. The EU Deforestation Regulation represents a significant shift in how governments are addressing forest-risk commodities. Voluntary target-setting frameworks that ignore mandatory regulation risk becoming irrelevant. Businesses need coherent guidance that helps them meet both voluntary and regulatory obligations efficiently.

Third, the organization must acknowledge operational realities in global commodity supply chains. Agricultural supply chains often involve thousands of smallholder farmers across multiple countries. Achieving full traceability and implementing deforestation-free practices requires time, investment, and collaboration with suppliers who may have limited resources. Ignoring these realities creates targets that businesses cannot meet, even with genuine commitment.

The proposed changes represent SBTi’s attempt to navigate these tensions. Extended timelines and clearer cutoff dates provide businesses with workable compliance pathways. The absolute 2030 deadline preserves scientific ambition and prevents indefinite delay. Alignment with EUDR reduces duplication for businesses operating in European markets.

However, the rapid revision cycle also signals that land-sector accounting remains a fast-evolving area. Businesses should not treat the current FLAG criteria as fixed. Instead, you need to build flexibility into your target-setting and supply chain strategies. What works for compliance today may require adjustment as methodologies and regulations continue to develop.

Where to find detailed guidance and respond to the consultation

The full consultation document is available on the Science Based Targets initiative website. This includes detailed explanations of each proposed change, the rationale behind the revisions, and specific questions on which SBTi is seeking feedback. Businesses should review the full document before responding, especially if you have implementation concerns not covered by the summary materials.

The FLAG sector guidance page provides background on how FLAG targets work and which sectors are affected. This includes threshold calculations, sector definitions, and links to the FLAG Target-Setting Tool. Companies new to FLAG requirements should start here to understand the broader framework.

For broader context on UK net-zero compliance obligations, our net-zero program supports businesses with carbon reporting and science-based target development. We help companies navigate the intersection between voluntary frameworks like SBTi and mandatory reporting requirements such as SECR and TCFD.

The GHG Protocol Land Sector and Removals Guidance provides the accounting foundation on which FLAG targets are built. Understanding this guidance helps businesses grasp why certain methodological choices are made in the SBTi framework. It also clarifies how land emissions differ from other Scope 1, 2, and 3 categories.

Information on the EU Deforestation Regulation is available from the European Commission environment directorate. This regulation creates legal obligations for businesses trading in forest-risk commodities. Understanding EUDR requirements helps you assess where alignment with SBTi FLAG criteria creates efficiency and where differences require separate compliance processes.