I would greatly appreciate if you could answer to following two questions.
Please refer to the question No.1 and 2 below.
No.1: Validation route for Equity REITs which are SMEs
In the case of Equity REITs which are SMEs, non-subsidiary, independent company with fewer than 500 employees, I am wondering if they should apply for the validation process as not a SME route but a regular route.
I understand that Equity REITs are not a target audience of financial sector SBT guidance according to the document below (, especially page19).
However, it seems that the application form for SMEs describes Equity REITs cannot validate targets using the SME streamlined route due to its uniqueness.
Please refer to the “Please also indicate if you are the following types of companies: ” on the 3 page of following link.
No2: Base year setting for SMEs
On the application form for SMEs ( link is the same as above), it seems that we can select one year from the most recent three years (2018, 2019 and 2020, currently) as a base year.
Even after 2022 starts (year of 2021 is over), could we still select 2018 as a base year?
We hope we can choose 2018 as a base year, however, we are afraid that we could not do that because of the time we send a form. I wonder if we can select 2018 as a base year whenever we apply for the SME route.
Equity REITs should set targets via the regular company route. And as you can see from the companies taking action table, if you filter on real estate, you have a number of REITs that have set targets this way.
Hi Donald. I’m helping a PE investing in real estate with setting targets for emissions reductions and I have two questions that follow from your discussion with Ryuhei.
It was very useful to see the reference to equity REITs that you point to in the guidance for FIs published in Feb 2022 ie that the FI guidance is not for equity REITs and they should use the regular company route. But I can’t help noticing that in the same document REITs are specifically mentioned in Appendix B which suggests the real estate SDA is relevant for REITs. This seems contradictory, but am I missing something?
Ryuhei raised above a question about the relevance of the SME SBTi route for equity REITs: he wrote that the SME route is not possible for equity REITs. Unfortunately the document that Ryuhei refers to is no longer at that link since the SME application form has been up-dated but I’m assuming he had read that the SME route is not suitable for Financial Institutions. So would you say that the option open to a small equity REIT (under 500 employees) is the SME route?
Apologies for the delayed response as we are still waiting for some updates.
As stated in Section 1.2 of the Near-Term Financial Sector SBT Guidance, the primary audience includes mortgage REITs (which are then not eligible for the SME target validation route since they are FIs), whereas equity REITs are not a target audience.
Equity REITs are then technically eligible for the streamlined target validation route if they meet the current SME definition (e.g., under 500 employees). However, this may be revisited such that they potentially must go through the regular company route.
