Mechanisms to Prevent Carbon Lock-in in Transition Finance

1. Overview

Abstract

Transition finance has grown in importance over recent years to enable decarbonation of high-emitting industries, complementing more narrow green finance approaches that focus on activities that are already considered as low-emission. This Chapter explains why carbon lock-in is a key risk in transition finance and summarises the key findings and good practices to strengthen mechanisms to prevent carbon lock-in in transition finance policy frameworks. The chapter also presents the background, scope and aim of this report.

1.1. Background and context

In April 2022, the Intergovernmental Panel on Climate Change (IPCC) concluded that the continued installation of unabated fossil fuel infrastructure will “lock in” GHG emissions.1 According to the IPCC, projected cumulative future CO₂ emissions over the lifetime of existing and currently planned fossil fuel infrastructure without additional abatement will exceed remaining cumulative net CO₂ emissions in pathways that limit warming to 1.5°C (>50%) with no or limited overshoot. They are approximately equal to total cumulative net CO₂ emissions in pathways that limit warming to 2°C (IPCC, 2022[1]). This means that already today, existing and planned fossil fuel assets are largely inconsistent with the temperature goal of the Paris Agreement of “holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels” (UNFCCC, 2015[2]).

In a “net zero emissions by 2050” (NZE) scenario, updated IEA modelling indicates that between 2021 and 2050 coal demand declines by 90%, oil declines by around 80%, and natural gas declines by more than 70% (IEA, 2022[3]). In this scenario, the remaining fossil fuels are used exclusively for the following purposes:

• In the production of non‐energy goods where carbon is embodied in the product (e.g., fertilisers),

• in plants with carbon capture, utilisation and storage (CCUS), and

• in sectors where low‐emissions technology options are scarce (e.g., aviation) (IEA, 2021[4]).

However, the IEA shows that annual investment in assets that produce and use fossil fuels continues to be on a rising trend. Global net income from oil and gas production reached a record high of USD 4 trillion in 2022, double 2021 levels (IEA, 2023[5]). Global coal investment increased to USD 135 billion in 2022, a 20% increase with respect to 2021 levels, and is expected to further increase in 2023. According to the IEA, the risks of locking in fossil fuel use are increasingly clear, as fossil fuel investment in 2023 is more than double the levels required to meet much lower demand in IEA’s NZE scenario (IEA, 2023[5]). According to Wood Mackenzie, new global oil and gas discoveries in 2022 drove exploration to the highest value creation in over a decade (Wood Mackenzie, 2023[6]). It is estimated that fossil fuel financing2 from the world’s 60 largest banks reached USD 5.5 trillion over the period of 2015 to 2022, with average annual financing amounting to USD 781 billion (Rainforest Action Network (RAN) et al, 2023[7]).

These levels of fossil fuel finance and investment run contrary to the IEA’s 2021 Net Zero by 2050 Roadmap, which concluded that no fossil fuel exploration and no new oil and gas fields are required beyond those that have already bee8n approved for development in 2021. Similarly, under this scenario, no new coal mines or mine extensions are required beyond what currently exists, and no new unabated coal plants should be approved for development (IEA, 2021[4]). Since the 2021 Roadmap was published, oil and gas demand rose and additional oil, gas and coal projects have reached final investment decisions, which would result in 25 Gt of emissions if operated to the end of their lifetime (around 5% of the remaining carbon budget for 1.5 °C) (IEA, 2022[3]).

Despite the clear evidence that investment to scale up low- and zero-emission technologies is urgently needed to achieve the Paris Agreement temperature goal, net-zero pathways of countries around the world continue to rely on the use of fossil assets in the short term. Moreover, the risk for fossil fuel producer countries (especially EMDEs) of being locked into carbon-intensive development trajectories has increased with Russia's war of aggression against Ukraine. As crude oil and natural gas prices have risen significantly, while demand for fossil fuels and related consumption subsidies have remained high (IEA, 2023[8]), there are few incentives for producer countries to reduce fossil production and exports (OECD, 2022[9]).

According to IEA’s updated NZE scenario, declining fossil fuel demand can be met through continued investment in existing production assets without the need for any new long lead time upstream conventional projects, provided that reducing fossil fuel investments is accompanied by clean energy investments and policy action to reduce energy demand (IEA, 2022[3]). New fossil fuel infrastructure projects will need to be compensated by even deeper emission reductions, making the later stages of the net-zero transition more challenging and creating a risk that targets move out of reach.

The IEA recognises that some natural gas infrastructure investments may be necessary in the transition to net zero, such as to support intermittent energy generation and to replace more emitting energy sources in industry until low-emission solutions are fully feasible and scalable. However, investments in energy generation likely need to be limited to supporting the objective of balancing electricity grids, rather than investing into natural gas as a baseload source of power (IEA, 2022[3]; FrontierEconomics, 2021[10]). In addition, the role of natural gas will change rapidly in the next decades and will vary significantly across regions, countries, and sectors. According to IEA’s 2022 Sustainable Africa Scenario, natural gas will continue to play an important role for the fertiliser, steel and cement industries and water desalination in Africa (IEA, 2022[11]). In Southeast Asia, natural gas plays an important role in enabling the move away from coal in power generation and to replace oil and biomass as a source of heat in industry. But in the IEA’s Sustainable Development scenario, natural gas use in Southeast Asia will decrease over time and after 2030 will switch from bulk generation to supporting the integration of variable renewables through the provision of different system services (IEA, 2022[12]).

Moreover, to be in line with a 1.5°C goal, global GHG emissions need to peak before 2025, with rapid and wide-reaching emissions reductions across all sectors needed during the subsequent decades until 2050 (IPCC, 2022[13]). This implies that unabated natural gas use must remain short-term. Natural gas infrastructure should be retired, repurposed, or retrofitted to utilise exclusively renewable and zero-emission fuels or be otherwise brought in line with a Paris-aligned net-zero trajectory through the use of low- or zero-emission technologies across the full value chain. Given that the lifetime emissions of existing and planned investments in fossil fuel infrastructure are today consistent with 2°C pathways (IPCC, 2022[1]), any additional natural gas investments, even if they remain short-term, have to be coupled with additional abatement and possibly the early retirement of other high-emitting assets. This is particularly important if 1.5°C is to remain within reach.

Against this background, any investment involving fossil fuels and any lending to companies with fossil fuel assets have a high risk of carbon lock-in3 and must therefore be carried out with the appropriate safeguards in place (Box 1.1 below presents a definition and examples of carbon lock-in and how it differs from the concept of stranded assets). Carbon lock-in can come about as a result of technical, economic, political, or institutional factors. Whenever government or market actors have stakes in fossil fuel assets, there is an incentive to continue operating the asset until the end of its useful life, given that the construction is by then a sunk cost (OECD, 2022[14]; FrontierEconomics, 2021[10]).

Considering the tension between the financial interests of fossil fuel asset owners and the need to avoid carbon lock-in, intense debate continues among policymakers, industry, and civil society on whether certain investments in fossil fuel assets and infrastructure can be considered as necessary for the net-zero transition and sustainable development, and therefore eligible for transition finance. Such investments include, for example, those that deploy emissions abatement technologies, refurbishments, and retrofits across existing (and potentially new) fossil assets and infrastructure.

1.2. Carbon lock-in is a key risk in transition finance

In setting out elements of credible corporate transition plans, the OECD Guidance on Transition Finance: Ensuring Credibility of Corporate Climate Transition Plans aims to unlock the capital flows required to reach net zero and reduce the risk of greenwashing in transition finance. The Guidance proposes to anchor transition finance transactions (use-of-proceeds and general-purpose instruments, such as sustainability-linked bonds (SLBs)), including their Key Performance Indicators (KPIs) and Sustainability Performance Targets (SPTs), in entity-wide corporate climate transition plans. Annex B recaps the ten key elements of credible corporate climate transition plans set out in the Guidance.

The Guidance identifies carbon lock-in as one of the main factors contributing to risks of greenwashing in transition finance, which in turn can hamper the development of this market (OECD, 2022[14]). Investments that increase the risk of lock-in will ultimately undermine net-zero transition efforts, even if they may result in short-term emissions reductions (OECD, 2022[14]; Tandon, 2021[15]). To be credible, transition finance needs to tackle the risk of carbon lock-in.

This report reviews and compares mechanisms to prevent carbon lock-in that are currently being used in transition finance policy frameworks and approaches and relevant financial instruments. Recognising that the risk of carbon lock-in is not limited to private sector investment and transition finance but has also been a recurrent theme in public sector climate mitigation policy and related financing and investment for some time, the report draws lessons from Paris-alignment methodologies of Multilateral Development Banks (MDBs), and public investment frameworks, notably state aid.

Box 1.1. Carbon lock-in and stranded assets: two sides of the same coin

What is carbon lock-in?

Carbon lock-in occurs when fossil fuel infrastructure or assets (existing or new) continue to be used, despite the possibility of substituting them with low-emission alternatives, delaying or preventing the transition to near-zero or zero-emission alternatives.

There are several types of investments that can increase the risk of carbon lock-in, and there are ongoing debates regarding their degree of environmental integrity, such as:

• Efficiency improvements and carbon capture, utilisation and storage (CCUS) investments in coal assets;

• Gas assets and infrastructure like transmission and distribution networks; domestic gas boilers; power generation plants like combined cycle power plants (CCGTs); and power, heating and cooling generation plants like combined heat and power plants (CHPs);

• Industrial plants that currently mainly rely on fossil fuels, such as blast furnaces that are used to generate high-temperature heat required for heavy industry production processes.

How does carbon lock-in relate to asset stranding?

Carbon lock-in is linked with but distinct from asset stranding. There are various recognised definitions of asset stranding, but no universally agreed view. Existing definitions have in common that stranded assets involve economic loss, asset devaluations, or write-downs prior to the end of an asset’s anticipated useful economic life. Definitions differ with regards to the reasons for the loss, with some, for example, emphasising climate policy (IEA, 2013[16]), while others take a broader view and highlight “changes in the market and regulatory environment” (Carbon Tracker, 2017[17]), or “changes in legislation, regulation, market forces, disruptive innovation, societal norms, or environmental shocks” (Generation Foundation, 2013[18]) more broadly (see (OECD/IEA, 2017[19]) for a detailed overview of existing definitions).

For the purposes of this report, the definition of stranded assets put forward by the Smith School of Enterprise and the Environment at the University of Oxford, which can be considered the common denominator across existing definitions, is used. Under this definition, stranded assets are assets that “have suffered from unanticipated or premature write-downs, devaluations, or conversion to liabilities” (Caldecott, Howarth and McSharry, 2013[20]).

Asset stranding and carbon lock-in are two risk factors attached to fossil fuel investments. Asset stranding is predominantly an economic and financial risk for the asset owner, rather than a factor undermining the net-zero transition. Lock-in risk, on the other hand, makes investments susceptible to criticisms of greenwashing, as they could ultimately undermine net-zero transition efforts. Asset stranding and lock-in risk can work in opposing ways whereby investments are structured in a way as to protect from asset stranding risk, while increasing lock-in risk (such as, when providing contractual certainty around revenues).

Source: Authors.

Key elements of the OECD Guidance relate to target-setting and implementation steps, as well as using relevant supporting tools, such as taxonomies, technology roadmaps, and sectoral emissions pathways. The latter are being developed (e.g. by the IEA and the Network of Central Banks and Supervisors for Greening the Financial System (NGFS)) and applied (e.g., by the Transition Pathway Initiative and the Science Based Targets initiative (SBTi), amongst others) to assess whether an asset or company is in line with a selected decarbonisation or net-zero trajectory. However, such emissions pathways have mainly been developed at macro level (e.g., at global or regional level) and accounting for country-specific considerations remains challenging (Noels and Jachnik, 2022[21]; OECD, forthcoming[22]). Technology roadmaps (also sometimes referred to as “technology pathways” or “investment pathways”), build on emissions scenarios by providing a forward-looking perspective on technologies that are needed to decarbonise a given sector, including the relevant timelines. Their use also remains limited for the moment, with the most prominent example being the sectoral roadmaps developed by Japan’s Ministry of Economy, Trade and Industry and Ministry of Land, Infrastructure, Transport and Tourism. The roadmaps today cover ten high-emitting sectors in Japan (METI, 2023[23]).4 Lastly, transition taxonomies aim to account for transition considerations through eligibility criteria such as: sunset clauses, limiting eligibility of economic activities to a specific timeframe; and future-proofing requirements, to ensure that assets and infrastructures use technologies which enable them for the use of low-carbon and renewable alternative energy sources in the future. This remains insufficient as it does not guarantee that fossil assets will ultimately be transitioned to near-zero or zero-emission alternatives.

To further help mitigate carbon lock-in risk, the OECD Guidance concludes that companies should in addition identify in their transition plans existing assets and infrastructure, as well as planned investments, that are at risk of carbon lock-in and put in place mechanisms to prevent this risk from materialising. To this end, the Guidance analyses existing mechanisms to prevent carbon lock-in in transition finance and concludes that further work is needed to strengthen such mechanisms and broaden the suite of solutions that market actors have at their disposal to prevent lock-in.

1.3. Aim and scope of the report

This report proposes ways to strengthen mechanisms to prevent carbon lock-in in transition finance. The proposed mechanisms can be applied at economic activity or project level (e.g., as part of taxonomies), at the level of a corporate’s climate transition plan (e.g., as part of climate-related disclosure or transition planning requirements), and as part of KPIs and SPTs of relevant financial instruments (e.g., standards or labels for SLBs). The aim of the report is to support the scaling up of the transition finance market by helping market actors and policymakers identify ways to increase the environmental integrity and credibility of transition finance, given its importance in supporting the net-zero transition, especially in EMDEs.

The report is relevant to policymakers and regulators that have developed or are considering developing transition finance policies (for example, taxonomies, roadmaps, or guidance), standards for green, transition and sustainability-linked debt, frameworks for corporate transition plans, or broader climate-related disclosure frameworks.

The report is structured as follows:

• Chapter 2 looks at transition finance definitions and the role that feasibility assessments play in setting eligibility criteria, which subsequently impact the degree of carbon lock-in risk and environmental integrity of those definitions. The chapter concludes that the risk of lock-in in transition finance approaches can be reduced by providing clarity on how to assess feasibility as part of eligibility criteria, and by explicitly taking a long-term approach in the assessment.

• Chapter 3 analyses existing mechanisms to prevent carbon lock-in across relevant private and public sector financing and investment frameworks, and summarises good practices. It proposes ways to strengthen mechanisms deployed in transition finance frameworks, such as in taxonomies, pathways, technology roadmaps, and transition plans.

• Chapter 4 focuses on relevant debt instruments, notably green, transition and sustainability-linked bonds, and analyses the extent to which the structure and requirements of these instruments can contribute to increasing the lock-in risk of the projects and entities that they finance. It provides key findings and good practices on reducing carbon lock-in using transition financial instruments.

1.4. Overview of key findings of the report

Transition finance approaches emphasise the need to avoid carbon lock-in, but largely do not set clear criteria on how to do so. Consequently, questions relating to carbon lock-in are an important reason why market actors are hesitant to engage in transition financing. In the absence of consensus on how to avoid lock-in, corporates seeking transition financing may fear accusations of greenwashing - i.e., claims that they might use green, transition or net-zero labels for their offer of products and services while directing capital to high-emitting activities that delay rather than advance the net-zero transition. While several of the existing transition finance approaches highlight the need to avoid locking activities in high-emission pathways, limited guidance exists on ways in which financiers and corporates can practically prevent this risk.

The following section summarises this report’s key findings and good practices on how addressing carbon lock-in risk can enhance credibility of transition finance frameworks.

Carbon lock-in considerations in transition finance definitions: the role of feasibility assessments

Transition finance focuses on providing funds to decarbonise economic activities and industries that currently do not have a fully feasible zero- or near-zero emission alternative. Therefore, for policymakers to define which activities and industries should be eligible for transition finance in their jurisdiction, it is necessary to assess the feasibility of zero- and low-emission substitutes.

How feasibility is assessed, such as whether a long-term approach is taken in the assessment and how much weight is given to institutional and political factors, fundamentally affects technology selection:

• Institutional and political factors can effectively outweigh technological or environmental factors in determining feasibility, and therefore eligibility. This can allow for technologies that are incompatible with the temperature goal of the Paris Agreement to be selected as being eligible for transition finance, even in cases where lower-emission alternatives are technologically feasible.

• Similarly, economic feasibility assessments may only assess short-term costs, rather than considering future transition risk and projecting costs over the lifetime of the asset. In such cases, a technologically feasible low-emission option may be assessed to be economically infeasible and potentially lower cost over the longer term. See Box 1.2 below for a summary of key findings and good practices related to the role of feasibility assessments.

Box 1.2. The role of feasibility assessments in transition finance: Key findings and good practices

Transition finance definitions can be strengthened and made more transparent by providing clarity on how to assess feasibility as part of eligibility criteria, and by explicitly taking a long-term approach in the assessment.

Transition finance approaches that credibly prevent carbon lock-in will provide a more detailed definition of what feasibility entails, notably by specifying the need to:

• Take into account project costs in 2030 and beyond, using an appropriate net-zero scenario;

• Take into account future costs of reinvestment in order to achieve net zero;

• Appropriately assess and monetise transition risk, including by projecting it over a longer time horizon (2030 and beyond), as it may not immediately materialise; and

• Explicitly acknowledge and address potential challenges related to institutional and social feasibility, which may affect economic feasibility, for example by providing adequate support, social protection, training, and reskilling to impacted workers, households, and communities.

Carbon lock-in considerations in financing and investment frameworks

The concept of carbon lock-in is not exclusive to transition finance and is a recurring theme in discussions around policy and financing for climate change mitigation. It is particularly important to consider the concept of carbon lock-in when designing public or private investments in energy production and use. Existing frameworks and tools guiding such investments reflect to varying degrees the growing importance of carbon lock-in risk. However, as the window of opportunity to stay within the Paris temperature goal is closing, the issue of lock-in risk and questions on how best to mitigate it will take centre stage as stakeholders develop relevant financing frameworks and tools.

To date, some mechanisms to prevent carbon lock-in have been developed and applied in some public and MDB finance and investment frameworks, as well as in transition finance frameworks for private finance and investment. Integrating the following existing good practices in transition finance policies (see Box 1.3) has the potential to significantly strengthen the environmental credibility of transition finance.

Box 1.3. How financing and investment frameworks address carbon lock-in: Key findings and good practices

Standards and frameworks for credible corporate climate transition plans, with net-zero targets based on the Paris temperature goal, are key tools to preventing carbon lock-in in transition finance.

In the absence of frameworks for credible corporate climate transition plans, there will continue to be uncertainties in transition finance with respect to greenwashing and carbon lock-in. This uncertainty can be addressed if jurisdictions and market actors step up efforts to put in place standards and frameworks for developing and disclosing credible corporate climate transition plans, identifying sources of carbon lock-in risk, and ways to address it.

National sectoral emissions pathways can guide technology roadmaps, robust transition taxonomy criteria, and similar tools, as well as allowing companies to develop credible net-zero plans and targets.

When emission pathways are based on a country’s net-zero target and developed for each sector, they can provide a robust basis for companies to set their own net-zero targets and develop transition plans, as well as for policymakers to develop taxonomy criteria, technology roadmaps, and similar tools.

Excluding the most emission-intensive energy sources from eligibility for transition finance enhances the credibility of transition finance frameworks.

Providing clear guidance on which investments are not eligible for transition finance, due to them not being in line with the Paris temperature target, can enhance the credibility of transition finance frameworks and will avoid uncertainty for companies and investors.

Actions to future-proof transition investments can include setting requirements with technical specifications that enable infrastructure for the use of low-emission and renewable fuels.

To strengthen their credibility, transition finance frameworks will benefit from including requirements for supported assets to be future-proof and comply with technical specifications to enable the transport and use of low-emission fuels in the future.

Sunset clauses for use of fossil fuels can reduce lock-in risk for assets where a fuel switch is planned to ensure alignment of the asset with the Paris temperature goal (e.g., a switch from natural gas to low-emission hydrogen).

To ensure that natural gas assets containing requirements to be future-proof actually carry out the switch to low-emission fuels, it is paramount to set a sunset clause that will limit the eligibility for support and allow the eventual phase out of the fossil fuels.

For assets where a fuel switch is needed to achieve alignment with the Paris temperature goal, flanking measures to ensure the switch can happen in a timely manner can contribute to preventing carbon lock-in.

Flanking measures, that give credibility to future-proofing requirements and sunset clauses in transition finance frameworks, include:

• Accompanying research, development, and innovation investments, as well as investments to support the supply of the future low-emission fuel that is expected to be used after the sunset date;

• Contracts of supply for the low-emission replacement fuel to be agreed within a specified timeframe, ideally within three years of the initial investment;

• Detailed plans and binding timeframes setting out a strategy of how the low-emission fuel will be used by the company benefitting from transition finance.

It is important to establish a date for early retirement of assets that cannot be retrofitted or refurbished to be consistent with net zero, accompanied by a strategy to finance the retirement.

To be credible, transition finance frameworks can specify additional requirements for the managed phaseout of high-emitting assets. This could include specific phase-out plans as part of transition plan frameworks, outlining how the phase-out is aligned with any net-zero or climate-related strategy, how just transition considerations are integrated, key milestones such as phase-out timing, key metrics and targets, disclosure of progress, governance mechanisms, related capital expenditure (CapEx) plans and key assumptions and uncertainties as part of the plan.

Carbon lock-in considerations in transition financial instruments

A wide range of financial instruments are relevant to transition finance, namely green, transition and sustainability-linked bonds and loans. Box 1.4 below summarises key findings and good practices on how carbon lock-in risk can be addressed when designing frameworks for transition financial instruments. Relevant transition financial instruments include green bonds that finance transition activities, transition bonds and sustainability-linked bonds (SLBs).

Green and transition bonds are generally used to raise finance for specific green or transition projects. Therefore, individual issuances do not necessarily signal that issuers have a credible and whole-of-entity transition strategy in place to transform their business models and operations and drastically reduce their emissions. This is a source of greenwashing risk in particular where bonds finance projects that reduce but overall still have high emissions. In addition, individual issuances that are not directly anchored in an overarching transition plan or strategy and not aligned with existing taxonomies or other relevant classification systems cannot be considered a proxy for an entity’s transition efforts. To avoid lock-in, it is necessary to situate such projects within a wider transition plan and show how they are, over the long-term, in line with a Paris-aligned pathway.

While green bond standards and green taxonomies broadly converge on the definition of green eligible activities, some differences persist, which can create greenwashing and carbon lock-in risks. In the transition bond space, currently still very limited in size, lock-in risks are highly present, given the lack of definitions and eligibility criteria for what constitutes a transition bond.

The uptake of SLBs by a wide variety of issuers across sectors indicates that the instrument has potential to be used for a whole-of-economy, cross-sectoral transition. At the same time, evidence suggests that there are emerging loopholes and potential penalty-minimising behaviour in SLB structures. Moreover, KPIs and metrics used in SLB issuances in high-emitting sectors are not always consistent with an ambition to transition a company towards credible low-emission pathways.

Box 1.4. Addressing carbon lock-in risks in transition financial instruments: Key findings and good practices

Clearly distinguishing between green and transition eligible activities will make frameworks for transition financial instruments more credible. Credibility can also be enhanced by linking frameworks with corporate transition plans, and by using ambitious KPIs and SPTs that are linked with key milestones designed to prevent carbon lock-in.

The credibility of SLB frameworks can be enhanced by anchoring them in and providing details about the corporate climate transition plan, as well as by using meaningful Paris-aligned emission reduction-related KPIs and SPTs. In line with the OECD Guidance on Transition Finance, it is important that such KPIs and SPTs include all emission scopes, both absolute and intensity targets and not overly rely on offsets. In cases where offsets are used as a last resort option, sufficient details on their reliability and use will be provided.

To reduce the risk of lock-in, it is important that green and transition bond frameworks and standards clearly distinguish between green and transition eligible activities, in line with applicable taxonomies or other relevant eligibility requirements disclosed by the issuer.

Where they finance transition activities or projects involving fossil fuels, such as natural gas-based energy production for a limited period (when blending with or before switching to 100% renewable or low-emission gases), credibility can be ensured through additional verification requirements and reporting on forward-looking indicators like sunset requirements and flanking measures. The same logic applies to investments in efficiency improvements of fossil fuel assets, or ammonia co-firing in coal-fired power plants, where explicit and detailed information on key milestones to achieve net zero should be reflected in KPI and SPT requirements.

The development of standards and frameworks for SLBs is necessary to strengthen the credibility of this instrument and address emerging loopholes which increase the risk of lock-in of related investments.

Standards and oversight are needed to ensure that verification and SPO providers follow the highest quality standards available and ensure the credibility, integrity, and ambition of SLB frameworks and related KPIs and SPTs. In a credible SLB framework, standalone ESG metrics and scores will not be used as KPIs and SPTs. It is important that penalties are set in a way that provides adequate incentives for the issuer to achieve its sustainability targets.

Eligibility criteria of standards and frameworks for transition financial instruments should be regularly updated and reassessed as factors affecting feasibility evolve.

Wherever green or transition eligible projects include activities that are emission-intensive because of feasibility hurdles, feasibility should be regularly reassessed in case technological, economic, regulatory, or political and social conditions change over time.

Wherever innovative and not fully tested and scalable net-zero technologies are used, details should be provided on the associated Capital Expenditure (CapEx) required, the feasibility of the technology used and any foreseen limitations, constraints, and uncertainties to their application.

References

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Notes

← 1.  In this context ‘abatement’ refers to interventions that can substantially reduce GHG emissions, e.g., by capturing 90% or more of emissions from power plants.

← 2.  The analysis includes the world’s 60 largest banks by assets according to Standard & Poor’s. The report assessed banks’ involvement in corporate lending and underwriting transactions (including project finance, where data was available). All deals marked as “green” were removed from the dataset, whereas those designated as “sustainability-linked” or “sustainability” were included (Rainforest Action Network (RAN) et al, 2023[7]).

← 3.  Other terms that are frequently employed, often interchangeably, are “emissions lock-in”, “emissions-intensive lock-in”, and “carbon-intensive lock-in”. The terms “emissions lock-in” and “emissions-intensive lock-in” differ from the others in that they refer to all greenhouse gases (GHGs), thus not only carbon dioxide, despite often being used in the context of describing carbon lock-in. This report will use the term “carbon lock-in” to align with existing literature and because it will not deep dive into different GHGs.

← 4.  Emissions pathways are distinct from scenarios and models, though the terms are sometimes used interchangeably: Climate mitigation scenarios are a “coherent set of quantitative projected pathways”, with each pathway providing a future trajectory (based on a set of assumption) for a specific variable, such as emissions, GDP, natural resource use, etc. Therefore, an emissions pathway forms part of a climate mitigation scenario. Climate change mitigation scenarios, on the other hand, “are the output of models”. For more details on climate scenarios and emissions pathways used in the financial sector, please refer to (OECD, forthcoming[22]).