In October 2025, Banco Santander became a founding signatory of Carbon Measures, a new emissions-accounting initiative launched by a group of major industrial players. While the initiative is marketed as a technical upgrade to carbon accounting, its implications are far more troubling. The model promoted by Carbon Measures threatens to weaken global climate accountability at the very moment governments and regulators are finally converging on unified standards.

Even more concerning is that Carbon Measures is backed by ExxonMobil, one of the world’s largest climate polluters and a company with a long history of resisting strong climate disclosure rules. Santander’s decision to stand alongside Exxon in advancing this alternative system raises serious questions about the bank’s commitment to genuine climate responsibility.

What Carbon Measures proposes, and why it undermines accountability

The initiative promotes an e-ledger or e-liability model that treats emissions as transferable along the supply chain. Under this framework:

• A company records its direct and upstream emissions;
• When it sells a product, it passes those emissions to the buyer;
• Downstream emissions vanish from corporate accounts as the liability moves to the end consumer.

This is not simply a new accounting method. It fundamentally alters who is responsible for emissions.

1. Downstream emissions disappear from corporate reporting

Under today’s GHG Protocol, companies must disclose Scope 3 emissions, which for many sectors – especially fossil fuels, chemicals, agriculture, steel and cement – represent the majority of their climate impact.

Instead, under Carbon Measures:

• downstream emissions from product use (Scope 3) are removed,
• high-emitting sectors appear significantly cleaner than they are,
• incentives to decarbonise products vanish.

This aligns with long-standing industry efforts, particularly from companies like Exxon, to downplay or avoid accountability for the emissions generated when their products are used.

2. Responsibility shifts onto consumers

Because emissions “land” with end users, the burden of tracking and managing carbon is pushed onto individuals who lack the tools, authority, and data to do so.

This is not climate leadership, it is the outsourcing of responsibility.

Consumers alone cannot decarbonise global supply chains; producers and financiers can.

3. A private governance structure with little transparency

Unlike the GHG Protocol or ISO 14064/14067, which are built through public, transparent, multi-stakeholder processes, Carbon Measures is:

• corporate-led,
• privately governed,
• lacking independent oversight.

This creates an accountability vacuum that benefits industries seeking flexibility rather than rigour.

A risky distraction at a crucial time

Carbon Measures launched just weeks after the landmark 2025 ISO - GHG Protocol partnership, which is unifying global carbon accounting into a single coherent system backed by governments, markets, and regulators.

This unified framework is already being digitised, expanded, and strengthened. Introducing a competing standard now risks:

• fragmenting global rules,
• delaying urgently needed improvements,
• confusing companies and investors,
• and undermining the consensus required for rapid implementation.

Whether intentional or not, the effect is the same: a slowdown in progress. Given Exxon’s history of favouring approaches that delay climate action, it is difficult to ignore how neatly Carbon Measures fits within that pattern.

Why Santander’s role matters

Santander’s endorsement of Carbon Measures gives the initiative financial-sector credibility it does not deserve. By signing on, the bank is:

• supporting a framework that weakens global standards,
• helping shift responsibility away from major emitters,
• and aligning with an initiative shaped by industries with the most to gain from softer rules.

For a bank that claims climate leadership, this is deeply irresponsible.

What Santander should do instead

The world does not need new private frameworks that bypass public governance. We already have a robust system - the GHG Protocol - which underpins national climate policy, investor disclosure, supply-chain rules, and corporate transition plans.

It took years for the GHG Protocol to be the reference framework in carbon accountability. Carbon Measures risks diverting attention from real progress. The experience of the Net-Zero Banking Alliance showed the risks of focusing purely on carbon emissions accountability and ignoring the urgent need to end finance for fossil fuel expansion; a prerequisite to achieve the goals of the Paris Agreement.

The GHG Protocol is being modernised now, with transparency and legitimacy. Strengthening, not replacing it, is the path to credible climate action.

BankTrack calls on Santander to:

• withdraw from Carbon Measures,
• support the GHG Protocol framework,
• develop policies to exclude financing for fossil fuel expansion,
• and commit to strengthening, not undermining, global climate accountability.

In a decisive decade for climate action, Santander must choose real responsibility over corporate-led shortcuts.