Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)
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CORSIA 2024: Key Updates and Compliance Guidelines for EEA and Non-EEA Aeroplane 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 achieving carbon-neutral growth in aviation from 2020 onwards. The framework for CORSIA is outlined in Annex 16, Volume IV of the Convention on International Civil Aviation, focusing on offsetting CO2 emissions beyond 2019 levels. It includes requirements for monitoring, reporting, verifying (MRV) emissions, and implementing offsetting mechanisms.
With the release of the Second Edition of SARPs Annex 16, Volume IV, effective from 31 July 2023 and applicable starting 1 January 2024, significant updates have been made. These changes apply to both European Economic Area (EEA) and non-EEA operators. This newsletter outlines the key updates in the SARPs and relevant EU directives.
According to the Second Edition of SARPs Annex 16, Volume IV, Part II, Chapter 3, several key adjustments were made due to the COVID-19 crisis. These include:
According to the Second Edition of SARPs Annex 16 , Volume IV, Part II, Chapter 3, Section 3.2.5, aeroplane operators without CO2 emissions recorded in 2019, who do not qualify as new entrants, will use a baseline of 10,000 tonnes of CO2 to calculate offsetting emissions for the ‘year under consideration.
According to the Second Edition of SARPs Annex 16, Volume IV, Appendix 2, Section 2.2.2, the operators involved in short-term leasing must obtain necessary data from third parties. When this information is not available, the use of Block-On or Block-Off data is allowed .
According to the Second Edition of SARPs Annex 16 Volume IV, Part II, Chapter 3, Section 3.4.2, if the sum of the aeroplane operator’s offsetting requirements in the three years of a given compliance period (OR1,C + OR2,C + OR3,C ) is less than 3 000 tonnes of CO2, then the aeroplane operator has no offsetting requirements for the compliance period.
According to the Second Edition of SARPs Annex 16 Volume IV, Part II, Chapter 3, Section 3.3, the TS-1 and Type 3 fuels have been added to the list of approved fuels, with an emission factor of 3.16 kg CO2/kg of fuel.
CORSIA will undergo triennial reviews, with a special review scheduled for 2032 to assess its future beyond 2035.
According to the Commission Implementing Regulation (EU) 2024/1879, the ICAO Assembly has revised the CORSIA baseline. For the period from 2021 to 2023, the baseline has been changed from the average of 2019 and 2020 CO2 emissions to the 2019 CO2 emissions level. For the period from 2024 to 2035, the baseline will be set at 85% of the 2019 CO2 emissions.
To calculate offsetting requirements under CORSIA, Member States should refer to the list of countries applying CORSIA, as published by the Commission under Article 25a(3). This list is different from the one provided by ICAO, as it excludes EEA countries, Switzerland, and the United Kingdom, focusing only on those implementing CORSIA under Directive 2003/87/EC. Additionally, the calculation should exclude routes that are exempted in accordance with Article 25a(7) of Directive 2003/87/EC to ensure equal treatment for operators within the Union.
A draft act related to the EU Emissions Trading System and countries applying CORSIA in 2024 is currently open for feedback until 24th September 2024. The final act is expected in the fourth quarter of 2024.
ICAO will release the growth factor for 2023 on 31st October 2024.
The Sectoral Growth Factor is set at zero for the years 2021 and 2022. For 2023, States will inform aeroplane operators of their offsetting requirements (if any) by 30th November 2024.
Note: The following deadlines apply if the 2023 Sectoral Growth Factor (SGF) is greater than 0. If the SGF is zero, there will be no offsetting requirements, emissions unit cancellations, or verification of the Emissions Unit Cancellation Report (EUCR) for the 2021-2023 compliance cycle (pilot phase).
Aeroplane operators must cancel emissions units for compliance during the 2021-2023 period by 31st January 2025 or within 60 days after receiving notification from the State of their total final offsetting requirements, whichever comes later (in case the 2023 Sector Growth Factor is not null).
CORSIA Eligible Emissions Units Communication Deadline: Based on the calculated growth factor and offsetting requirements, aeroplane operators must cancel the necessary CORSIA-eligible cancellation units and communicate on the respective CORSIA Eligible Emissions Unit Programme registry (or registries) public website(s) by 7th February 2025.
Submission of Reports: Operators are required to submit their Emissions Unit Cancellation Report (EUCR) to an independent verifier during the period 1st December 2024 to 30th April 2025.
Verification and Submission to Authorities: Once verified, both the aeroplane operator and the independent verifier must independently submit the verified report along with the verification report to the competent authority by 30th April 2025.
The aviation industry’s commitment to reducing carbon emissions is reinforced by the latest updates to CORSIA regulations. Both non-EEA and EEA operators face new baselines, growth factors, and compliance requirements starting in 2024. Staying informed and meeting these obligations will be crucial for operators to contribute to global carbon reduction goals. With upcoming deadlines and reviews, proactive preparation is key to ensuring smooth compliance with CORSIA.
