SARP: ICAO draft open for commentary by CORSIA states

The Countdown to CORSIA has begun. In December 2017, ICAO sent its letter on Standards and Recommended Practices (SARP) relating to CORSIA out to States with a request for comments back by 20th April 2018. It is time for airlines to take action. Read here to find out more.

As expected, the ICAO letter contained a lot of detail focused around Monitoring, Reporting and Verification. All Airline Operators with international routes will need to monitor and report on an annual basis their international emissions. The compliance obligation for emissions above the baseline level will only apply to international flights between States that have agreed to participate in the Pilot Phase.

Whilst there was emphasis on the development of Emission Monitoring Plans and Reporting, the Emission Unit Criteria have still not been finalized. Some are concerned that, if rules are too relaxed, projects used or developed for compliance might not be robust enough. At this stage, the Emission Unit Eligibility Criteria have been established at a program level and at a project level, but are still yet to be fully agreed upon.

Eligibility criteria for carbon offsets under discussion

There is the possibility that further developments to the criteria may include vintage restrictions such as carbon offsets created after a certain date only being eligible, or there may be some program restrictions, such as excluding certain project types. It was originally thought that the final eligibility criteria would be approved in 2018 but this may actually take longer than previously expected.

Based on current knowledge, it is expected that good quality projects from the following programs from both the compliance and voluntary carbon markets will be eligible: Clean Development Mechanism, Verified Carbon Standard, Gold Standard, Climate Action Reserve, American Carbon Registry, and a new mechanism which is being developed under the Paris Agreement.

Whether or not supply will be plenty depends predominantly on the eligibility of CDM projects and vintages, and the interaction between CORSIA and the implementation of the Paris Agreement.

Schedule for the next steps

As part of the SARP letter, ICAO sets out a rough schedule of what needs to be done both on their side and also on that of airline companies. While the priority for CORSIA members will be on developing their Emission Monitoring Plans in 2018 and monitoring in 2019 and 2020, airlines need to be mindful that ICAO continues to work on the Emissions Unit Criteria and work on Article 6 of the Paris Agreement continues. Both will affect the pool of carbon offsets available for CORSIA compliance. Once these criteria are known, those airlines with international flights that fly to countries participating in the Pilot Phase will need to turn their attention to developing their Sourcing and Compliance Strategies.

First Climate will be following developments in ICAO’s SARP finalizations and offers support in developing monitoring, reporting and verification strategies that are in accordance with CORSIA.

For specific questions please get in touch with the First Climate CORSIA team. To learn more about our services, please visit our website at

Find the full SARPs proposal letter here

The CORSIA timeline