Transparency & Trust: Aviation Emissions Verified

French Offsetting Scheme - Article 147

Aerial view of the French countryside

Compensation of greenhouse gas emissions related to domestic flights

From 2022, Article 147 of the French Climate and Resilience Law mandates aircraft operators operating domestic flights in France to offset the associated emissions. The legislative provisions of the French law are supplemented by the implementing Decree n° 2022-667. Aircraft operators must submit a verified Offsetting Report by 31 May annually. Normec Verifavia, as a leading verifier, ensures meticulous verification, ensuring adherence to this requirement with accuracy and integrity.

Why choose Normec Verifavia?

  1. Ensure compliance: Our meticulous verification services ensure compliance with applicable regulations, transparency, and prevent penalties and legal consequences.
  2. Unmatched Expertise: Our team of aviation experts ensures a thorough and accurate verification of emissions data and related parameters.
  3. Minimize compliance risks: Ensure regulatory confidence and minimize compliance risks with our trusted verification process.
  4. Company’s Experience: Normec Verifavia has more than 10 years of expertise in validation, verification, and auditing within the aviation sector, delivering the highest standards of services.
  5. Established verification programme: For the French Decree, we have established a Verification Program (reference: FR DECREE Verification Program v.1 – May 2026), which is shared with our clients prior to the engagement phase.

The French Offsetting Scheme aims to reduce the environmental impact of domestic flights in France and take another step toward aviation carbon neutrality by 2050, reflecting France’s commitment to sustainability.

Eligibility and Compliance

Aircraft operators under the EU Emissions Trading System (EU ETS) emitting over 1,000 tCO2 per year on French domestic flights must comply. By 30 April each year, they must offset the previous year’s emissions by cancelling or financing eligible carbon credits (1 carbon credit = 1 tCO2 avoided or sequestered).

A verified Offsetting Report must be submitted annually by 31 May.

Scheme Overview and Objectives

The scheme follows a phased approach to offsetting requirements, setting targets for the percentage of total emissions from French domestic flights that must be offset:

  • 50% in 2022
  • 70% in 2023
  • 100% from 2024

Additionally, the scheme stipulates that a minimum percentage of these offsetting obligations must be met through eligible projects located within the European Union:

  • 20% in 2022
  • 35% in 2023
  • 50% in 2024 and 2025
  • 50% from 2026 (subject to revision)

Carbon Credits Criteria

Credits used for compliance must respect the principles of compensation:

  • Measurability
  • Verifiability
  • Permanency
  • Additionality

Projects certified for use under ICAO’s CORSIA or France’s “Label Bas Carbone” automatically qualify as they are recognised to respect these principles. Other projects may be accepted if they meet these principles.

Additionally, only projects that began after 31 December 2019 are eligible.

Biodiversity Bonus and Transitional Measures

A biodiversity bonus allows additional credits for projects enhancing biodiversity, capped at 50% per project and at 15% of an operator’s offsetting obligation per year. Certain criteria apply for a project to be eligible, and they depend on the sector.

Transitional measures, in place for offsetting obligations until 2025, allow offsetting through the sale of credits from new EU projects before these are generated, provided enough financing evidence is available and project eligibility criteria are met. This must be demonstrated through verification with annual follow-up until full credit retirement.

Offsetting Report

The Offsetting Report documents the cancellation or financing of carbon credits from eligible carbon offset projects, including information on such projects: type, location, sector, emissions offsets, methodology, biodiversity benefits and funding. It ensures transparency, integrity, and avoidance of double-counting.

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Process
  1. Pre-engagement

    Our commercial team engages with the client. Thereafter, a pre-contract is elaborated and sent to the client.

  2. Engagement

    During the engagement stage, clear objectives are set with the client, which involves the comprehensive definition of the operational scope, ensuring that all relevant parties have a clear and shared understanding of the verification boundaries. The engagement is formalized through a contract, setting the stage for a structured and transparent verification process.

  3. Planning

    The verification activities are determined and planned based on the claims. An Audit Preparation Letter (APL) is sent to request all the required data and documents to begin the verification process. A strategic and risk analysis is performed to assess the risks and prepare a verification plan.

  4. Execution

    A thorough analysis of data and supporting documents to verify accuracy, completeness, and consistency of the reported information. The process ensures compliance with relevant regulations.

  5. Review and Decision

    An independent technical review is conducted in accordance with ISO 17029:2019 and ISO 14065:2020 standards. After achieving reasonable assurance, a verification report is issued, ensuring that the client’s report is free from any material misstatements.

  6. Post-Verification Activities

    If there is any significant information that comes to light after the verification opinion has been issued and if such information could impact the verification results, it may necessitate a reassessment or correction in the report.

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FAQ

Find answers to the most commonly asked questions

What project types qualify for offsetting?

Renewable energy, energy efficiency, forestry, carbon capture and storage, and more, are subject to eligibility criteria. 

Can I use the same offsets for other schemes?

No, double counting is prohibited. 

What if I cannot meet the minimum EU share?

Justifications demonstrating unavailable compliant EU credits below €40/tCO2 and required volume (commercial prospects, documented communication with offset providers) are required. 

How can I ensure the legitimacy of my offsetting projects?

We connect you with verified projects that meet international standards and contribute to real carbon reduction. 

What happens if I do not comply with the scheme?

Penalty fees amounting to 100 EUR may be applicable if an operator does not comply with this scheme.