The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) has entered its First Phase (2024-2026).
This means that airline operators must now monitor, report, and offset their CO₂ emissions from international flights.
Introduced in 2019, CORSIA is now in its active First Phase (2024-2026). This means airlines on covered routes have a live requirement to offset their emissions growth.
Where airlines exceed the stated emissions threshold - 10,000 metric-tonnes - international airlines must purchase CORSIA eligible emissions units (CEEUs).
Representing one metric tonne of CO₂ emissions reduced or removed, each EEU must be accessed on the voluntary carbon market, through ICAO-approved programmes.
CFP Energy can access CEEUs at the best price and help you meet each compliance phase, as well as regulatory changes, that are still under discussion.
The First Phase compliance deadline of January 2028 may seem distant, but market conditions can change from day to day.
Airlines that start planning now, with the right expertise supporting their decisions, will be better positioned to meet their CORSIA obligations and manage their exposure.
To discuss your CORSIA strategy, and start planning for the future, contact one of our carbon specialists, here.
When sourcing CEEUs airline operators face numerous hurdles, each with the potential to impact both compliance timelines and costs. The next three sections will outline the main hurdles and challenges in accessing CEEUs, and what you should do to start building a comprehensive compliance strategy.
The voluntary carbon market is fragmented. Many different project developers are operating in many different territories, each with their own regulatory requirements.
In addition, there are alternative pathways to compliance: as well as purchasing CEUUs, airlines can also purchase SAF and SAF credits (CORSIA Eligible Fuels) to reduce their carbon liability.
We have 19 years’ experience operating at the intersection of voluntary and compliance carbon markets, allowing us to synthesise complex information into as suitable solution for each airline.
CORSIA units differ fundamentally from EU ETS credits. Whilst an EUA is a digital certificate representing an emission allowance, CORSIA credits are an environmental certificate deriving from a physical decarbonisation activity. Without an official price floor, the cost of EEUs moves with typical commodity market factors..
As well as keeping up to date with changing regulations, airlines now grapple with forecasting compliance costs across multi-year periods, often turning to hedging instruments to manage exposure.
This adds another layer of financial complexity for affected airlines that, must proactively enter into forward agreements, in order to manage future compliance costs.
To issue EUUs, project developers must first secure host country sign-off through a Letter of Authorisation. Additionally, where EUUs are traded internationally, host governments must issue Corresponding Adjustments documents to prevent double counting (i.e., the potential overlap between country-level emission reductions and the airline’s compliance claim).
Requirements like these add significant bureaucratic complexity to an already complex compliance landscape. In practice, only a fraction sit in jurisdictions that are likely to be capable of handling these provisions, which may affect the number of projects approved in the future.
The quality of CORSIA's offset credits is assured by the ICAO’s technical advisory body, which measures the integrity of offset programmes against the Emissions Unit Eligibility Criteria (EUC). In accordance with the EUC, only programmes that can demonstrate actual, additional, and long-term carbon reductions can meet approval.
Seeking accreditation with a range of industry recognised standards has been another pathway to ensuring the integrity of CORSIA eligible emissions units.
As of October 2024, six carbon standards have received approval, including the Gold Standard, Verra, Climate Action Reserve, and the Global Carbon Council.
Previously, only ACR and ART held full approval rights, which significantly constrained market supply. The expansion of third parties permitted to approve carbon projects has improved availability, though each standard carries specific exclusions for certain methodologies and project types.
A central requirement for First Phase units is the corresponding adjustment mechanism. Credits generated from emissions reductions occurring from January 2021 onwards must include attestation from the host country confirming that these reductions won't also be counted toward national climate targets.
This prevents double-claiming, where the same emissions reduction is counted both by the host country toward its Nationally Determined Contribution (NDC) and by the airline.
However, approval standards have their drawbacks: the approval requirement has introduced procurement complexity as many host countries are still working on frameworks for issuing authorisation letters and implementing corresponding adjustments.
The responsibility for ensuring proper authorisation falls primarily on carbon standards and project developers, not airlines, but supply chain certainty remains a valid concern for procurement teams.
Additionally, understanding how CORSIA works alongside other carbon compliance programmes is essential to avoiding compliance conflicts.
While schemes such as the UK and EU Emissions Trading System cover domestic flights, and sometimes intra-regional international lines, CORSIA only covers international flights.
To prevent compliance overlaps, where the same route is assessed under these separate frameworks, airlines should adopt a policy of precise regulatory alignment.
As with any other commodity, the CORSIA eligible emissions units price is dictated by supply and demand. However, in carbon markets, regulatory decisions can also influence price.
These decisions, such as where offset projects are approved or rejected, can directly affect the supply of EEUs, which can influence their price in turn. By monitoring industry decisions like this, it’s possible to gain pricing advantages over competitors.
Forward procurement is another proven sourcing strategy. By securing CEEU credits ahead of compliance deadlines, it’s possible to access lower prices. However, to be eligible, CEEUs must come from emissions reductions that occurred during specific timeframes - for the First Phase, between January 2021 and December 2026.
Diversification across multiple standards and project types can also reduce risk. Instead of purchasing credits from a single registry or carried out according to a single method, airlines can spread their ICAO CORSIA eligible emissions units sourcing across multiple programmes.
This reduces exposure to programme-specific regulatory changes, while increasing access to competitive pricing in different markets.
Wherever these carbon credits are sourced, what’s important is to treat their procurement with the same approach as other commodities within the aviation space, such as Sustainable Aviation Fuel (SAF).
The same principles of risk management and forecasting apply - the only difference is the specific regulations that apply to carbon markets.
With extensive expertise in carbon markets and with specialised knowledge of the aviation sector we can secure ICAO CORSIA eligible emissions units to ensure you meet compliance and access the best price.
Our analysts can help you forecast your offsetting obligations, analyse market pricing trends, and develop targeted sourcing strategies that balance compliance with cost management.
Plan your CORSIA strategy and reduce your exposure here, now.