Exact details of the CORSIA will be finalised over the coming years, but here are some of the key questions operators may be asking about the scheme. Also, check out the resource centre for other links and downloads.

General questions about the CORSIA

ICAO has done some analysis on how much it will cost the industry at a global level, which works out at roughly 0.25% and 0.4% of industry revenues in the 2025-2030 period, or around $2.2 billion in 2025 to $4.3 billion in 2030. These are medium estimates. This implies that the approximate average cost for a flight, for example, from Dubai to Sydney would range from $2,500 and $6,500 in 2030, depending on CO2 and carbon price assumptions.

This compares to the 2016 cost of fuel on that same route being around $83,000 (and a $10-per-barrel increase would raise the fuel cost by $14,000) How exactly this would affect passenger fares, we simply don’t know – it will depend if airlines want to, or are even able to, pass this cost on fully or partially to passengers. The airline business is incredibly competitive and they are not always able to pass on costs to passengers. Whether they do so with CORSIA will depend on individual airline decisions.

The aviation industry is confident that technology, operations and infrastructure measures will provide long-term solutions for aviation’s sustainable growth. However, the industry recognises that some form of MBM is needed to fill any remaining emissions gap between its CO2 emissions and the target of carbon neutral growth. A failure to reach an agreement would have further exposed our industry to the costs of a complex patchwork of climate-related taxes, charges, emissions trading schemes, associated MRV requirements and other overlapping and contradictory measures.

In recent years, the number of carbon pricing instruments, such as CO2 taxes or emissions trading schemes, has grown dramatically across the globe.  A similar proliferation of carbon pricing instruments for aviation would result in an unsustainable patchwork for operators. Many operators fly into dozens of different jurisdictions. They need to have a single point of accountability.

That will depend on how many states decide to take part, but based on current expectations, over 80% of the post-2020 growth in emissions will be covered under the current proposal (and with voluntary additions, this number could go even higher).The industry has been pushing for as high as possible coverage from day one of the scheme, but recognises that this will ultimately depend on state negotiations.

We urge states to show leadership by volunteering to be part of the scheme from the outset. States which would be exempted from the second phase are also encouraged to volunteer to be part of CORSIA from the outset or, at least, from the beginning of the second phase.

No, the system is designed to allow growth to continue, but to offset the CO2 impacts of that growth. The absence of a globally-agreed mechanism would lead to a costly and complex patchwork of national and regional policy measures. This would have a much more significant impact on economic development than a global offsetting mechanism by reducing connectivity, trade and tourism.

Some developing states have indicated their intention to voluntarily join the scheme in the first phases. Volunteering to join the GMBM early has the following advantages:

  • It demonstrates a state’s commitment to address climate change and shows leadership;
  • Increased coverage will generate more demand for carbon offsets. As the vast majority of the carbon offsets will be generated from projects hosted in developing states, increased coverage will drive investment in developing countries;
  • Joining early will allow airlines in volunteering states to gain experience with carbon trading when the costs of the scheme are the lowest (since offsetting requirements in the first years of the scheme will be relatively small). This will be an advantage in the later phases of the scheme;
  • Joining the scheme increases the sustainability of international flights to/from the volunteering state, which may be an important consideration for some air travellers/freight forwarders.
  • A high level of coverage not only increases the environmental effectiveness of the scheme, but also reduces the risk of market distortions by creating uniform conditions for coverage under the CORSIA.

Paragraph 18 of Assembly Resolution A39-3 provides that the Council will undertake a periodic review of CORSIA, for consideration by the Assembly, every three years from 2022. The review should serve as a basis for the Council to consider whether any adjustments are necessary and should assess the impact of the scheme on the growth of international aviation.

This was always envisaged to be part of the process, to ensure that the scheme is working as it should and to decide if any alterations are needed as the CORSIA continues to apply. It is however important to ensure stability and predictability in the scheme as aircraft operators will need to integrate compliance with CORSIA in their planning, both at the cost level and the operational level.

In the industry’s view, the ICAO CORSIA does reflect the spirit of the Paris Agreement and the principle of equity and common but differentiated responsibilities and respective capabilities, in the light of different national circumstances, through the phased implementation and the inclusion of a sectoral component in the calculation of the emissions to be offset by individual aircraft operators.

Furthermore, whilst under the Paris Agreement each State is to decide its own level of ambition and the measures it wants to implement to achieve its own goals (“nationally determined contributions”), such a voluntary, bottom-up approach would not be suitable for international air transport.

  • For the air transport sector, one of the main benefits of a global MBM is to avoid a patchwork of national measures.
  • If emissions from international aviation were to be addressed through nationally determined contributions, operators would inevitably have to comply with a multitude of schemes as States are likely to seek to protect the competitiveness of their national carriers or increasing the environmental impact of the scheme by applying national measures to all emissions within their jurisdiction, including emissions from foreign operators within national airspace.
  • It would also inevitably introduce unacceptable market distortions as operators would have no guarantee that their competitors are subject to requirements that are equivalent.

No. The CORSIA is specifically designed for CO2 emissions from international aviation services. ICAO has a mandate over international aviation, whereas domestic aviation activity is an issue for each State to decide on as part of their commitment under the Paris Agreement. Many of the technology, operations and infrastructure CO2 mitigation options for aviation are applicable to both international and domestic services. However, implementing a market-based measure has some differences. We would urge any State wishing to implement a market-based measure for their domestic aviation sector to follow closely the design of the CORSIA, in order to reduce the administrative burden on operators (and ensure more complete coverage).

ICAO member states are responsible to ensure compliance and will have to decide on measures at national level. Accordingly, penalties are not being foreseen are ICAO level and the sanctions for compliance will be defined by individual States for their national operators.

The details of which information will be made available to the public remains to be decided by ICAO.

To build confidence amongst the public in the scheme, some of the information reported by operators to States and information on the implementation of the scheme may be made available publicly. However, given the extremely competitive nature of air transport, commercially sensitive or confidential data should only be disclosed to States in order for them to discharge their oversight function, but not to the public in general.


Operational / implementation questions

It is anticipated that such a list will be made available in due time. The exact details are still being worked on by a task force of governments, industry and NGOs at ICAO – as soon as this information is known, we will update this website.

One of the first steps in the monitoring, reporting and verification of emissions under CORSIA will be the requirement for each operator to develop an emissions monitoring plan. The emissions monitoring plan, which will need to be approved by the operator’s national authorities, will include information on the operator, its fleet and operations. The emissions monitoring plan will also detail the methods that will be used by the operator to monitor fuel use and calculate emissions and data management, flow and control.

The exact details are however still being worked on by a task force of governments, industry and NGOs at ICAO – as soon as this information is known, we will update this website and also undertake some capacity building to ensure operators are aware of their obligations.

The exact details are still being worked on by a task force of governments, industry and NGOs at ICAO – as soon as this information is known, we will update this website and also undertake some capacity building to ensure operators are aware of their obligations.

The exact details are still being worked on by a task force of governments, industry and NGOs at ICAO – as soon as this information is known, we will update this website and also undertake some capacity building to ensure operators are aware of their obligations.

By default, each aircraft operator will comply with CORSIA individually and a subsidiary company would report its fuel consumption independently from its parent company. However, ICAO is considering whether in some limited circumstances two aircraft operators may request to be treated as a single entity.

All data related to domestic operations is excluded from CORSIA. This means that if an airline only operates domestic flights, it will have no reporting or offset requirements under CORSIA.

The enforcement of CORSIA by an airline is the sole responsibility of its State of registry. No airline association or any other non-governmental entity has an obligation or responsibility to ensure airlines are compliant. However, IATA and regional associations strongly support CORSIA and believe it is in the interest of their members to provide support so that all are in a position to meet CORSIA’s requirements. This is why we are taking an active role in informing all airlines about CORSIA and assisting them with preparing for the implementation of the scheme, beyond our respective memberships.

The ICAO Global Market-Based Technical Task Force has recommended that sustainable alternative fuels should be accounted for by aircraft operators as generating CO2 emissions reductions. Work continues to define the formula and relevant emissions factors.

No “new” procedures will be required for the 2018 RTK data. Indeed, all ICAO Member States are already collecting statistical data, including RTK, from their operators through ICAO Form A on a monthly basis. The RTK data that will be used to determine which States will be “phased-in” from 2027 will be the data collected in 2018 through ICAO Form A and which MS probably already provides to your Government. 

The 2019 and 2020 CO2 data is required to determine the reference baseline emissions in the future compliance years. Given the voluntary nature of participation in CORSIA for some States, it is necessary to collect reference data for all routes. For example, if a State which would in principle be exempt from CORSIA decides to volunteer in 2031, reference CO2 data for routes to and from that State in 2019 and 2020 will be needed to determine offset requirements.