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CORSIA 2024: Important updates and compliance guidelines for EEA and non-EEA aircraft operators

The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), developed by the International Civil Aviation Organization (ICAO), is the first global market-based initiative aimed at carbon-neutral aviation growth from 2020. The framework for CORSIA is outlined in Annex 16, Volume IV of the Convention on International Civil Aviation, and aims to offset carbon emissions beyond the 2019 level.

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CORSIA for EEA aircraft operators.

Updated baseline

In accordance with Commission Implementing Regulation (EU) 2024/1879, the ICAO General Assembly has revised the CORSIA baseline. For the period from 2021 to 2023, the baseline was changed from the average of 2019 and 2020 CO2 emissions to the 2019 CO2 emission level. For the period from 2024 to 2035, the baseline is set at 85% of 2019 CO2 emissions.

Offset calculations

To calculate the offset requirements under CORSIA, member states must consult the list of countries applying CORSIA as published by the Commission under Article 25a(3). This list differs from that of ICAO in that EEA countries, Switzerland and the United Kingdom are not included in the list and only countries applying CORSIA in accordance with Directive 2003/87/EC are listed. Moreover, routes exempted under Article 25a(7) of Directive 2003/87/EC should be excluded from the calculation to ensure equal treatment of operators within the Union.

CORSIA for operators outside the EEA.

Updated baselines and growth factors.

According to the second edition of SARP's Schedule 16, Volume IV, Part II, Chapter 3, several significant adjustments were made as a result of the COVID-19 crisis. These include:

  • The CORSIA baseline for the pilot phase was adjusted from the average of 2019 and 2020 emissions to 2019 emissions only.
  • After the pilot phase, the baseline will be set at 85% of 2019 emissions.
  • Adjustments to the growth factors used to calculate offset requirements:
    • For the 2030-2032 period, it will be 100% sectoral and 0% individual.
    • For the 2033-2035 period, il will be a maximum of 85% sectoral and a minimum of 15% individual.
  • The threshold for new entrants was revised, changing the base year for emissions from 2020 to 2019.

Baseline for operators with no carbon emissions in 2019:

In accordance with the second edition of SARP Annex 16, Volume IV, Part II, Chapter 3, Section 3.2.5, aircraft operators with no CO2 emissions recorded in 2019, who are not considered new entrants, will use a baseline of 10,000 metric tons of CO2 to calculate offsetting emissions for the "relevant year.