Proposed SBTi FLAG updates support deforestation action
9 Oktober 2025
The SBTi’s public consultation provides an opportunity to advocate for ambitious and Accountability Framework-aligned no-deforestation commitments.
This week, the Science Based Targets initiative (SBTi) launched a targeted consultation to gather input on important updates to the SBTi Forest, Land and Agriculture (FLAG) Guidance, specifically to requirements related to the no-deforestation commitment. These updates support continued adoption and implementation of SBTi FLAG targets that provide high levels of ambition for land sector emissions reduction. They also maintain and further strengthen alignment between the SBTi and the AFi, as both initiatives provide a pathway to continued progress post-2025.
The AFi encourages interested stakeholders to participate in the consultation, which closes on 6 November. Read on for a short overview of SBTi FLAG’s no-deforestation commitment, as well as the components of the current proposal, and insights on how each component supports robust commitments and action on no-deforestation.
SBTi FLAG and its requirement for a no-deforestation commitment
The SBTi FLAG Guidance provides the only credible, globally-applicable framework for a company to set a target to reduce greenhouse gas (GHG) emissions from land sector activities in line with the Paris Agreement’s global goal of limiting climate warming to 1.5°C.
Deforestation is associated with as much as half of all land sector emissions. Based on SBTi models, all companies setting FLAG targets must eliminate deforestation and conversion from their supply chains to meet a near-term 1.5°C-aligned FLAG target, with most land use change being phased out well in advance of 2030.
To drive rapid action to address deforestation in supply chains, the SBTi FLAG Guidance includes a requirement for companies to set no-deforestation commitments for primary deforestation-linked commodities. To provide consistent guidance for companies on this topic, the SBTi and the AFi have worked together to ensure that the FLAG Guidance builds on and is aligned with common expectations for no-deforestation supply chains.
A look at the proposed updates
The SBTi proposes four primary updates to its requirements regarding the no-deforestation commitment. The following perspectives on each of these are based on the guidance of the Accountability Framework, as well as our AFi Explainer on no-deforestation commitments under SBTi FLAG, and the recent AFi statement on company target setting in 2025.
SBTi proposal:
The target date shall be within two years of the company’s submission of FLAG targets for SBTi validation, and no later than 31 December 2030.
This proposal represents an essential update to FLAG requirements, allowing companies to continue to set targets in 2025 and beyond, while maintaining high levels of ambition for addressing deforestation in alignment with 1.5°C pathways.
In line with emissions reduction models and AFi recommendations, the original FLAG Guidance requires that no-deforestation commitments have a target date of 2025 or earlier. That means companies should achieve deforestation-free supply chains for key commodities by the end of this year.
With the original 2025 deadline rapidly approaching, many companies have set ambitious no-deforestation commitments, and some have achieved them or are coming close. Others have not yet committed to time-bound action to address deforestation and associated emissions. To help set a clear direction for all companies, in May of this year, the AFi released a statement regarding no-deforestation commitments in 2025 and beyond. It urges companies to continue to set and implement no-deforestation and no-conversion policies with ambitious target dates that support achievement of global goals for climate and nature.
The proposed update fully aligns with AFi’s statement. By requiring an ambitious target date within a two-year window, the SBTi proposal enables new companies to set FLAG targets while ensuring that all participating companies rapidly address the largest sources of land sector emissions, in alignment with a 1.5°C goal.
SBTi proposal:
The cutoff date shall pre-date the company’s first FLAG no-deforestation commitment submitted for validation.
A cutoff date is the date after which deforestation renders a given area or production unit non-compliant with no-deforestation commitments. The proposed update adds an important criterion to the FLAG no-deforestation commitments: that cutoff dates must pre-date the establishment of FLAG targets. This increases alignment with the Accountability Framework and avoids incentivising new deforestation in advance of cutoff dates. Current FLAG Guidance recommends no-deforestation cutoff dates of no later than 2020, in line with the Accountability Framework, and this is retained under the SBTi proposal.
SBTi proposal:
SBTi requires that the seven commodities covered under the EUDR—cattle, cocoa, coffee, oil palm, rubber, soy, and timber—are as a minimum included within companies’ no-deforestation commitments in cases when any of these commodities are responsible for 5% or more of a company's total gross FLAG emissions.
This proposal provides significantly clearer requirements for commodity coverage and materiality thresholds, guiding companies to address the largest sources of deforestation. It also supports consistency in target setting across commodities.
SBTi FLAG Guidance requires companies to set commitments for “primary deforestation-linked commodities.” The objective of this wording was to prompt companies to set commitments associated with their largest deforestation impacts. However, it has led to uncertainty regarding which commodities should be covered by no-deforestation commitments. This proposal addresses that uncertainty by providing more specificity and a sufficiently low materiality threshold to ensure that products that present risk for deforestation and associated emissions are incorporated into commitments.
It should be noted that this commodity list is identified as a minimum. The SBTi adds that companies will still be expected to identify any further relevant deforestation-linked commodities within their supply chains, and to include these commodities in their no-deforestation commitments. This is also in line with the Accountability Framework.
SBTi proposal:
Within 12 months of validating their FLAG target, companies shall publish the commitment language on their own website or in relevant self-published policy documents. Companies shall also publish key details on how they plan to deliver their no-deforestation commitment either as a standalone document or within relevant documentation.
This proposal is aligned with the AFi position that companies should publish policies on public platforms, including their websites. Doing so increases the value of no-deforestation commitments by ensuring that companies signal their sustainability ambition in clear and transparent ways. This creates a strong basis for embedding commitments throughout the company’s operations and supply chains. It also creates stronger accountability for progress and enables stakeholders to assess whether companies are taking sufficient action to address deforestation.
The proposed updates are also in line with the AFi’s recent statement on 2025 targets, which guides companies to set and publish annual quantitative milestones and implementation plans indicating how commitments will be fulfilled.
Consultation open until 6 November
The AFi encourages stakeholders to respond to the SBTi consultation to help ensure that SBTi FLAG continues to support ambitious action towards eliminating deforestation and associated GHG emissions. The updates proposed by SBTi are well-aligned with the Accountability Framework and provide a pathway for companies to set FLAG targets while rapidly addressing the largest deforestation drivers in their business as a key component of credible climate action.