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Navigating ICAO's CORSIA in the first phase

As CORSIA enters its first phase (2024-2026), significant changes to compliance requirements have been introduced starting in 2024, marking a shift in regulatory standards and expectations; most notable is the shift from the baseline to 85% of CO₂ emissions in 2019 covered by offset requirements.

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Navigating ICAO's CORSIA in the first phase

Introduction

As CORSIA enters its first phase (2024-2026), significant changes to compliance requirements have been introduced starting in 2024, marking a shift in regulatory standards and expectations; most notable is the shift from the baseline to 85% of CO₂ emissions in 2019 covered by offset requirements. With a likely positive sectoral growth factor (SGF), aircraft operators will have to cancel emission units for the next few years and submit an emission unit cancellation report (EUCR) for the first phase (2024-2026). To meet these requirements, operators can also use CORSIA-eligible fuels and benefit from the reductions. For more information on CORSIA, click here

Activities 2025.

  • Jan. 1 to Dec. 31, 2025: Monitor emissions from international flights in accordance with ICAO Annex 16, Volume IV, Part II, Chapter 2, 2.2.
  • January 1 to April 30, 2025: Collect 2024 CO₂ emissions data in an emissions report and cooperate with an independent verification body in accordance with ICAO Annex 16 Volume IV Part II, Chapter 2, 2.4.
  • April 30, 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 that aircraft operators had no offset obligations for this period and thus did not have to submit an Emissions Unit Cancellation Report (EUCR) in 2025.

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

To meet the offset requirements, operators must purchase and cancel CORSIA-eligible emission units provided by emission unit programs approved by the ICAO Council. For the 2024-2026 compliance period, there are currently six approved programs that follow the established criteria and standards.

As offsets are likely to occur in the coming years, operators may consider using CORSIA-eligible fuels to reduce their offset requirements; these are fuels certified under the CORSIA Sustainability Certification Scheme. These fuels can be used to claim emission reductions reflected in the operator's final offset requirements. If an operator wants to claim CEFs, they must attach additional information to the emissions report using the template provided. Click here for more information on fuels eligible for CORSIA (CEFs).

Offset compliance in the first phase (2024-2026)

  • Cancel emission units upon receipt of the state's final offset requirements for the 2024-2026 compliance period by January 31, 2028 (or within 60 days of the state's notification for the 2026 year), as per ICAO Annex 16, Volume IV, Part II, Chapter 4, 4.2.
  • By February 07, 2028, the aircraft operator shall request that its cancellation of CORSIA eligible emission units for the period 2024-2026 be notified on the respective public website(s) of the CORSIA Registry (or registries) of eligible emission units, in accordance with ICAO Annex 16 Volume IV Part II, Chapter 4, 4.2.2 b.
  • Compile, verify and submit the emission unit cancellation report for the 2024-2026 period by April 30, 2028s in accordance with Annex 16, Volume IV Part II, Chapter 4, 4.4.

Conclusion

According to the latest ICAO update, 129 countries have confirmed their participation in the first phase of CORSIA implementation. This development highlights the commitment of international aviation to meet the emission targets set by the Council, further emphasizing the importance of CORSIA compliance. 2024 will likely be the first year that offsets will occur on such a large scale, and this calls for proper planning for aircraft operators.

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