Summary

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ClientEarth argues that the TPT framework must move from permissive language to mandatory, science-aligned standards to correct a market failure where corporate net zero commitments lack credible transition plans. Key recommendations include requiring alignment with 1.5°C pathways, mandatory disclosure of all Scope 1-3 emissions, and a prohibition on counting carbon credits toward reduction targets. The document also advocates for stronger links between transition plans and financial statements, more rigorous reporting on corporate lobbying, and the integration of 'just transition' and nature-positive objectives.

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  • ClientEarth asserts that current corporate net zero commitments represent a market failure characterized by a lack of credible transition plans and insufficient regulatory enforcement against misleading disclosures.
  • The TPT framework should mandate that transition plans are compatible with scenarios limiting global warming to 1.5°C with low or no overshoot, rather than using non-mandatory language like 'should reflect'.
  • Companies must be required to include all Scope 1, 2, and 3 greenhouse gas emissions in their inventories and targets, with exceptions only for non-material sources (defined as less than 1% of total emissions).
  • Carbon credits, greenhouse gas removals, and avoided emissions must be reported separately and cannot be counted toward a company's absolute emissions reduction targets to avoid 'mitigation deterrence'.
  • To ensure financial accountability, transition plans should include mandatory cross-references to financial statements, specifically reconciling planned capex and opex with the accounts.
  • The TPT framework is currently underdeveloped regarding the integration of nature-positive objectives and 'just transition' principles, such as impacts on workforce, indigenous peoples, and human rights.

Cite the original document

APA
ClientEarth (2023). TPT Consultation Survey. https://www.clientearth.org/media/vnsfxov2/clientearth-tpt-consultation-survey-response-28-february-2023.pdf
Chicago
ClientEarth. TPT Consultation Survey. 2023. https://www.clientearth.org/media/vnsfxov2/clientearth-tpt-consultation-survey-response-28-february-2023.pdf.
Wikipedia
{{cite press release |author=ClientEarth |title=TPT Consultation Survey |date=28 February 2023 |url=https://www.clientearth.org/media/vnsfxov2/clientearth-tpt-consultation-survey-response-28-february-2023.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{clientearth2023tpt, author = {{ClientEarth}}, title = {{TPT Consultation Survey}}, publisher = {ClientEarth}, year = {2023}, month = feb, url = {https://www.clientearth.org/media/vnsfxov2/clientearth-tpt-consultation-survey-response-28-february-2023.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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