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Navigating ICAOs CORSIA in the first phase

Normec Verifavia
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Navigating ICAOs CORSIA in the first phase

Introduction

As CORSIA enters its first phase (2024-2026), significant changes in compliance requirements have been introduced starting in 2024, marking a shift in regulatory standards and expectations; the most notable one is the baseline being shifted to 85% of 2019 CO₂ emissions covered by offsetting requirements. With a likely positive Sectoral Growth Factor (SGF), aeroplane operators will need to cancel emission units for the upcoming years and submit an Emissions Unit Cancellation Report (EUCR) for the first phase (2024-2026). To meet these requirements operators can also use CORSIA eligible fuels and benefit from reductions. For more details on CORSIA, click here

2025 Activities

  • 1st January to 31st December 2025: Monitor emissions from international flights as per ICAO Annex 16 Volume IV Part II, Chapter 2, 2.2.
  • 1st January to 30th April 2025: Compile the 2024 CO₂ emissions data in an Emissions Report and engage with an independent verification body as per ICAO Annex 16 Volume IV Part II, Chapter 2, 2.4.
  • 30th April 2025: Submit the verified Emissions Report and Verification report to the State.

Developments in CORSIA

During the Pilot Phase (2021–2023), the Sectoral Growth Factor (SGF) for each year was 0.0, meaning aeroplane operators had no offsetting requirements for this period and thus do need not submit an Emissions Unit Cancellation Report (EUCR) in 2025.

The second compliance cycle and first phase (2024–2026) began in 2024, with a baseline set at 85% of 2019 CO₂ emissions, reflecting a 15% reduction. This baseline will remain until 2035, likely resulting in a positive SGF for 2024, 2025, and 2026. If confirmed, aeroplane operators must offset emissions for 2024–2026 by cancelling equivalent emissions units, requiring the submission of the first EUCR. Operators can download the template for the EUCR here. At the end of the compliance period (2024-2026) if the operator’s total offsetting requirement is less than 3000t CO₂ then the operator is exempt from offsetting for that compliance period.

To meet offsetting requirements, operators must buy and cancel CORSIA eligible emissions units supplied by Emissions Unit Programmes approved by the ICAO Council. For the compliance period 2024-2026, there are currently six approved programmes which follow the criteria and standards set.

Since offsetting is likely in the upcoming years, operators can consider uplifting CORSIA-eligible fuels to reduce their offsetting requirements, which are fuels which have been certified under the CORSIA Sustainability Certification Scheme. These fuels can be used to claim emissions reductions which will be reflected in the operator’s final offsetting requirement. If an operator wishes to claim CEFs, they must attach supplementary information to the emissions report using the template provided. Click here for more information on CORSIA Eligible Fuels (CEFs).

First phase (2024–2026) Offsetting Compliance

  • Cancel emissions units upon receiving the final offsetting requirements from the State for the 2024–2026 compliance period by 31 January 2028 (or within 60 days after notification from the State for the year 2026), as per ICAO Annex 16 Volume IV Part II, Chapter 4, 4.2.
  • By 07 February 2028, the aeroplane operator shall request that their cancellation of CORSIA Eligible Emissions Units for the 2024-2026 period are communicated on the respective CORSIA Eligible Emissions Unit Programme registry (or registries) public website(s) as per ICAO Annex 16 Volume IV Part II, Chapter 4, 4.2.2 b.
  • Compile, verify and submit the Emissions Unit Cancellation Report covering the 2024–2026 period by 30 April 2028, as per ICAO Annex 16 Volume IV Part II, Chapter 4, 4.4.

Conclusion

As the first phase of CORSIA implementation progresses, 129 states have confirmed their participation, as per the latest ICAO update. This development highlights international aviation’s commitment to achieving the emission targets set by the Council, further emphasising the importance of compliance with CORSIA. 2024 will likely be the first year that offsetting will be seen on such a large scale, and this raises a call for proper planning for aeroplane operators.

Contact Normec Verifavia for CORSIA Emissions Report and Emissions Unit Cancellation Report verification. Click here for more information about CORSIA on our website. Stay compliant, stay ahead.