CORSIA: The Definitive Guide

CORSIA stands for Carbon Offsetting and Reduction Scheme for International Aviation.

It is a truly international regulation because it comprises all 192 member states of the International Civil Aviation Organization (ICAO).

CORSIA was adopted during the 39th Assembly session in Autumn 2016. Its main purpose is to offset increases in CO₂ emissions from international civil aviation above 2020 levels.

Unless otherwise required by your competent authority, 28 February 2019 marks the first compliance deadline. This is the date by which you must submit an Emissions Monitoring Plan for approval.

Do I Need to Participate?

In principle, you must participate in CORSIA if your annual CO₂ emissions from international flights with aircraft having a MTOW of more than 5,700 kg (or 12,566 lbs) are above 10,000 metric tons. Emissions from domestic flights can be ignored as those are outside of the scope of CORSIA.

There are differences, however, depending on what is your administering country.

While EU based operators must participate in CORSIA as soon as they exceed the threshold mentioned above, participation of US based operators, for example, is completely optional at this stage. If you are based outside of the EU or US, we recommend you contact your competent authority to obtain some more clarification.

You might be interested to know that emissions from commercial (Part 135) and non-commercial (Part 91) flights count equally towards your total. There is also no special exemption for aircraft registered in certain jurisdictions as all aircraft registries are treated alike.

To estimate your emissions, you can use the CORSIA CO₂ Estimation and Reporting Tool (CERT).

What Does Participation Actually Mean?

Participation means that, starting from 1 January 2019, you must monitor, calculate, go through a verification and report your CO₂ emissions from all international flights you operate. The regulation uses the term MRV requirements to refer to the obligation of monitoring, reporting and verification. We will also use this terminology hereafter so don't be surprised.

In addition, you might also be subject to so called offsetting requirements. Behind this term hides the obligation to offset emissions from certain flights. Question 3 will discuss offsetting requirements in more detail.

Aircraft and Flight Exemptions

Certain aircraft and flights are outside of the scope of CORSIA so you can ignore them when calculating your emissions.

Exempt are aircraft with a MTOW of less than 5.7 metric tons and aircraft operated by the police, military, custom or the State.

Furthermore, the regulation excludes emissions from humanitarian, medical and firefighting flights. Flights preceding or following such flights are also exempt provided they were required to accomplish the humanitarian, medical or firefighting activities or to reposition the aeroplane thereafter.

Lastly, make sure you only account for emissions you are responsible for. These are emissions from flights where you are the aircraft operator.

Are You the Aircraft Operator?

According to the regulation, you are the aircraft operator of a certain flight if box 7 of the flight plan shows your ICAO designator. If you don't have an ICAO designator but an AOC, then the AC registration marking of the aircraft included in your AOC identifies you as the aircraft operator. Without an AOC, you are the aircraft operator if your Emissions Monitoring Plan includes the AC registration marking that has been used in box 7 of the flight plan. If the aircraft operator can still not be identified, then the owner of the aircraft is considered the aircraft operator for CORSIA purposes.

What Flights Are Subject to Offsetting Requirements?

We learned above that, on top of MRV requirements, your flight department might also be subject to offsetting requirements.

Offsetting requirements refer to the obligation to offset one part of the emissions produced during international flights between two participating ICAO member states.

A member state participates in CORSIA offsetting because either it has opted in to voluntarily participate or because it's mandatory.

Pilot and First Phase

Participation in CORSIA offsetting is voluntary during the Pilot Phase (2021-2023) and the First Phase (2024-2026). Member states can join in by notifying ICAO of their intention to participate by 30 June of the preceding year.

The document CORSIA States for Chapter 3 State Pairs includes a list of all participating ICAO member states. The first version will be released on ICAO's website by 1 August 2020. It will give you certainty over which countries participate in 2021.

The composition of the list is subject to change because ICAO member states can always opt out from the Pilot and First Phase.

Second Phase

By contrast, CORSIA offsetting is mandatory during the Second Phase (2027 to 2035) unless the member state is exempt.

Member states must participate in the Second Phase if:

• their individual share of international aviation activities in RTKs in 2018 is above 0.5 per cent of total RTKs, or
• their cumulative share in the list of states from the highest to the lowest amount of RTKs reaches 90 per cent of total RTKs in 2018.

 

RTK stands for Revenue tonne kilometre. A member state's RTK is calculated by adding up the RTKs of the aircraft operators attributed to this member state.

The cumulative RTK share is calculated by sorting each member state's RTK shares from the highest to lowest, then successively increasing the value by summing the RTK shares from highest to lowest until the value reaches 90 per cent. The values of all member states are considered for this calculation, regardless of whether a member state is exempt or not from offsetting requirements under CORSIA.

Least Developed Countries (LDCs), Small Island Developing States (SIDSs) and Landlocked Developing Countries (LLDCs) are exempt even if they meet the criteria above.

Starting From When Must New Entrants Participate?

You are considered a new entrant if you exceed the 10,000 tonnes CO₂ exemption threshold for the first time in 2019 or later.

As a new entrant, you must meet your MRV requirements the year in which you exceed the above stated threshold. This means, for that year, you must collect CORSIA relevant information, and create and submit a verified Emissions Report. In addition, you will need to submit an Emissions Monitoring Plan for approval within 3 months of falling within the scope.

By contrast, offsetting requirements kick in at a later stage. This is the earlier of:

• the year after three years of monitoring and reporting emissions under CORSIA, or
• the year in which your annual CO₂ emissions from international flights exceed 0.1 per cent of total emissions from the whole sector in 2020.

 

How Do I Use CERT?

The CORSIA CO₂ Estimation and Reporting Tool (or CERT) is a CO₂ emissions estimation tool which shall facilitate compliance with CORSIA.

You can use CERT:

• to determine whether you are exempt from participating in CORSIA
• as primary fuel use monitoring method (conditions apply)
• to fill data gaps.

 

But how do you use this tool?

First, you need to download the tool. It's important you download the correct version because it is updated every year. 

Second, you gather the following information:

• ICAO aircraft type designator of your aircraft
• ICAO airport code of aerodrome of departure and arrival

 

Third, you open CERT, accept the End User Licence Agreement and go to the tab CO₂ Estimation. Then you simply fill in your aircraft and flight information all uppercase in the designated green area and click the red button Calculate CO₂ Emissions.

CO₂ Estimation

The tool automatically provides values for:

• great circle distance in kilometre
• CO₂ emissions in metric tons.

 

In addition, it shows you whether the flights you have entered are covered by CORSIA or whether they are outside of the scope.

 

If you enter the flight information manually, you can even group the flights you have operated with a particular aircraft type into aerodrome pairs. Per definition, an aerodrome pair is directional. This means, for example, that LFPB EGGW and EGGW LFPB are two different aerodrome pairs.

If you don't want to copy paste your flight information into CERT, you can also import your flights from a csv file. This is our preferred option because it is much faster than the manual input of flight data.

Summary Assessment

Another useful feature of CERT is the summary assessment which can be generated by a click of a button. The following illustration shows you section B and C of the summary assessment.

 

 

The summary assessment:

• calculates total CO₂ emissions from all international flights;
• shows your status as Yes or No depending on whether you are exempt or not. No means you are exempt. Yes means you must participate in CORSIA;
• confirms whether you can use CERT as primary fuel use monitoring method;
• generates a list of state pairs for your Emissions Monitoring Plan and Emissions Report.

 

Who Is My Competent Authority?

CORSIA is implemented on member states level which means that your primary point of contact is the competent authority of the member state you are assigned to.

If you have an ICAO designator, you'll find your member state in the ICAO document entitled CORSIA Aeroplane Operator to State Attributions (or alternatively on Wikipedia*). If you have no ICAO designator, but a valid AOC, your member state is the state that has issued your AOC. If you have neither ICAO designator nor AOC, your member state is where your company is registered.

Now, you know your member state. But what ministry or agency is your point of contact for compliance with CORSIA?

If you haven't been contacted yet by your competent authority, we suggest you get in touch with ICAO to find out. Alternatively, you can contact us.

To complicate things even more, your member state can even form an administrative partnership with another member state and delegate certain administrative tasks. If your member states goes this path, it is required to notify you of the start of an administrative partnership or any changes to it thereafter.

* If you use Wikipedia, we recommend you double check with the proposed member state that it is indeed your member state.

 

 

What Do I Need to Do By When?

As discussed under Question 2, you must participate in CORSIA if your annual emissions from international flights are above the exemption threshold of 10,000 metric tons CO₂ , unless your competent authority has stated clearly that the participation in CORSIA is voluntary.

As a participating aircraft operator, you must:

• prepare an Emissions Monitoring Plan and submit it for approval to your competent authority ideally by 30 September 2018 but no later than 28 February 2019;
• starting from 1 January 2019, monitor and record fuel use from international flights using an eligible monitoring method;
• by 30 May 2020 (or by 31 March 2020 if you are administered by an EU member state), submit to your competent authority a verified Emissions Report and associated Verification Report for 2019. It's important to note this is a recurring task and that, starting from 2022, the reports for the previous year are due a month ahead by 30 April;
• cancel emissions units for compliance with the CORSIA Pilot Phase (2021-2023) by 31 January 2025 (or 60 days after your competent authority informs you of your final offsetting requirements for the Pilot Phase);
• by 30 April 2025, submit to your competent authority a verified Emissions Unit Cancellation Report and associated Verification Report for the Pilot Phase;
• keep CORSIA relevant records for a period of 10 years.

 

What Is an Emissions Monitoring Plan?

An Emissions Monitoring Plan is in the heart of the MRV process because it tells you exactly how you need to monitor and report your emissions data.

As mentioned above, you must submit your Emissions Monitoring Plan for approval to your competent authority ideally by 30 September 2018, but no later than 28 February 2019.

What if you don't have an approved monitoring plan when CORSIA starts on 1 January 2019?

In this situation, you can monitor fuel use and emissions in accordance with the eligible monitoring method you intent to use.

What Information Does the Monitoring Plan Contain?

An Emissions Monitoring Plan:

• identifies you as an aircraft operator and provides basic company information including a brief description of the type of operations and ownership structure
• gives the regulator detailed information about your fleet and the countries you fly to
• contains a complete and transparent description of your CORSIA data management and control system including the method you have chosen for calculating fuel use and CO₂ emissions
• includes a documentation and record keeping plan which describes the system you have in place for storing CORSIA relevant information.

 

ICAO has made available a standardised monitoring plan template. You can use it for your monitoring plan unless your member state requires the use of its own template.

 

New Entrants Rule

If you are below the exemption threshold at the start of CORSIA, but exceed it somewhen down the road, you will be required to submit your Emissions Monitoring Plan within 3 months of falling within the scope.

Consolidation to Reduce Admin Burden

If you have a wholly owned subsidiary that is legally registered in the same state, you can apply to be treated as a single consolidated aircraft operator. To take advantage of this provision, you need to submit a monitoring plan covering both your company and the wholly owned subsidiary along with evidence that you meet the criteria.

Surely, this might be a good idea to reduce your admin burden. You need to be careful, however, if both aircraft operators are individually below the 10,000 tonnes CO₂ exemption threshold. Because combining the two entities could lift you above the threshold and, as a result, require you to participate in CORSIA, where otherwise, both aircraft operators would have been exempt.

When Do I Need to Update My Monitoring Plan?

Once you have an approved Emissions Monitoring Plan, you will need to keep it up-to-date. You must even resubmit your monitoring plan to your competent authority for review and approval in case of material changes.

Material Changes

Changes are material if these changes affect:

• your status or eligibility for a monitoring method
• the decision by your member state with regards to whether implemented monitoring procedures conform with the regulation
• your attribution to a member state or the means for having international flights attributed to your flight department.

 

Changes Affecting your Regulator's Oversight

Another category of changes are those affecting your regulator's oversight, such as changes of company name, address or point of contact. Those chances are not subject to approval, but they must be notified.

How Do I Monitor Fuel Use?

You have to follow a certain method for calculating fuel use and CO₂ emissions from international flights. CORSIA offers 6 different methodologies.

The CORSIA CO₂ Estimation and Reporting Tool (CERT) is one of the six which can only be used, however, if you meet the eligibility criteria. The other five methods can be chosen from freely, even if you are eligible to use CERT, except if you are administered by an EU member state in which case your choice narrows down to only two methods, namely method A and B.

The starting point is your Emissions Monitoring Plan. Because this is where you pick your preferred monitoring method. Once your monitoring plan is approved, you must apply it consistently throughout the reporting year.

CORSIA CO₂ Estimation and Reporting Tool (CERT)

Under Question 5, we have shown you how to use CERT to find out whether you are exempt or whether you have any obligations under CORSIA.

Depending on whether you meet the eligibility criteria, you might also be allowed to use the fuel and emissions estimates from CERT in your Annual Emissions Report.

Eligibility Criteria

The eligibility criteria depends on the reporting year.

You can use CERT for 2019 and 2020 if your total annual CO₂ emissions from international flights are below 500,000 metric tons.

For 2021 to 2035, there are no restrictions on the use of CERT if you use this tool to estimate emissions from flights that are not subject to offsetting requirements. By contrast, CERT can be used for emissions subject to offsetting requirements only if those emissions do not pass the 50,000 metric tons mark.

Change of Monitoring Method

Things get a little bit more complicated if you are below the threshold in one year, but above in another year.

Let's assume you have opted in to use CERT and you exceed the 500,000 tonnes threshold in 2020. Can you still use CERT for 2020 emissions?

Yes, you can.

But what if this happens to you in two consecutive years?

Let's say you exceed the 50,000 tonnes threshold in 2021 and you stay above this threshold in 2022.

In this case, your competent authority would expect you to swap CERT for a monitoring method based on actual fuel use and submit a revised emissions monitoring plan by 30 September 2023.

Method A

You can use method A if you have access to the following two information:

• the amount of fuel contained in the tanks once fuel uplift is complete (T)
• fuel uplift as documented in the fuel delivery note (U)

 

The formula is

where:

• F(N) stands for the fuel consumption of flight N
• flight N is followed by flight N+1.

 

There are a few things you need to keep in mind.

To avoid data gaps, you need to record fuel measurements for each flight including the uplift for a domestic flight that follows an international flight. Otherwise you will not be able to calculate fuel consumption for the international leg using method A.

Where no uplift takes place, fuel in tanks shall be measured at block-off.

Where the amount of fuel uplift is determined in units of volume, you need to multiply the volume figure with an actual or standard fuel density value of 0.8 kg per litre.

To calculate CO₂ for a certain flight, you will need to multiply mass of fuel in metric tons with a fuel conversion factor of 3.16 (in kg CO₂/kg fuel) for Jet-A fuel.

Method B

Method B is similar to Method A in that it uses tank readings and fuel uplift.

The difference is that we don't use tank readings after fuel uplift (or block-off), but tank readings at block-on (R).

The formula is

where:

• F(N) stands for the fuel consumption of flight N
• U(N) stands for fuel uplift for flight N as documented in the fuel delivery note
• flight N-1 precedes flight N.

 

Same as with method A, you should record all fuel measurements regardless of whether it is for a domestic or international flight. This is because you need fuel information from the previous flight.

Block-off / Block-on

The third monitoring methodology is Block-off / Block-on.

The formula is

where:

• F(N) stands for the fuel consumption of flight N
• D(N) stands for the amount of fuel contained in the tanks at block-off of flight N
• R(N) stands for the amount of fuel contained in the tanks at block-on of flight N

 

Block-off is any time between last door closed and first engine on. Block-on is any time between last engine out and first door open.

If you take block-off or block-on measurements at a different point in time, you will need to include in your monitoring plan a description of your existing operational procedures. This is important because your competent authority must approve any deviation from the above definition.

Fuel Uplift

If the subsequent flight (N+1) has an uplift before departure, you can calculate the fuel consumption for flight N using the formula:

where:

• F(N) stands for the fuel consumption of flight N
• U(N) stands for fuel uplift for flight N as documented in the fuel delivery note

 

If there is no fuel uplift before a flight, you have to use the last uplift and information on block hours to allocate fuel use.

Fuel Allocation with Block Hour

This fuel monitoring method involves two steps.

Calculating ABFR

First, you must calculate the average fuel burn ratio (AFBR) for each aircraft type you operate. You can have one AFBR for all flights or two different AFBRs (one for international and one for domestic flights). The calculation of ABFR must be repeated each year.

The formula is

where:

• AFBR stands for the average fuel burn ratio in tonnes per hour
• Σ U(n) stands for the sum of fuel uplifts during a year
• Σ BH(h) stands for the sum of all actual block hours during a year

 

Calculating Fuel Consumption

Second, you must calculate fuel consumption for a specific flight using the following formula:

where:

• F(N) stands for the fuel consumption of flight N
• BH(N) stands for block hours of flight N

 

Please note ABFR must be rounded to at least three decimal places.

 

 

How Do I Deal With Data Gaps?

Data gaps may occur if you fail to record data that is necessary for the calculation of fuel consumption for one or more international flights.

So how to remedy this problem?

First of all, if you detect data gaps, you will need to find the root of the problem and take corrective actions in a timely manner to avoid this from happening again.

Next, check if you can prevent data gaps by using secondary data sources. This is data recorded elsewhere which can be used to fill the void. A look in your emissions monitoring plan will tell you which secondary data sources you can use.

If this, too, doesn't help, you might be allowed to fill the data gaps with the help of CERT. But not everyone can use CERT for this purpose. It depends entirely on the number of international flights with data gaps (not the amount of CO₂ emissions).

For the 2019-2020 period, you can use CERT if the data gap does not exceed 5 percent of international flights.

For the 2021-2035 period, you can use CERT if the data gap is below 5 percent of international flights subject to offsetting requirements.

If you are above the 5 percent threshold, you must estimate the percentage of data gaps and engage with your member state in order to resolve this problem.

How Do I Report My Emissions?

ICAO has developed a standardised emissions report template. We recommend you use this template. But please check before with your member state as they might use a slightly different template. For example, if you are administered by an EU member state, you will need to use an integrated EU ETS / CORSIA template.

 

Emissions Report Content

The emissions report template from ICAO includes information on:

• your company and your verifier
• your emissions report, monitoring plan and monitoring method used
• your aircraft fleet
• fuel density
• total fuel mass per type of fuel (only if you use a monitoring method other than CERT)
• total number of international flights and flights subject to offsetting requirements
• total CO₂ emissions from international flights and from flights subject to offsetting requirements
• CO₂ emissions and number of international flights per state pair or aerodrome pair (your member state will inform you about the level of aggregation
• required by 30 April 2019 at the latest)
• percentage of data gaps and the reason which led to data gaps.

 

State and Aerodrome Pair

You might be wondering what is a state and aerodrome pair.

A state pair is a group of two contracting states composed of a departing contracting state or its territories and an arrival contracting state or its territories.

An aerodrome pair is similar in that the direction matters. For instance, emissions from flights from LFPB to EGGW must be allocated to the aerodrome pair LFPB EGGW, whereas emissions from flights from EGGW to LFPB must be allocated to the aerodrome pair EGGW LFPB.

Submission Deadline

You must submit your emissions report for 2019 to your competent authority by 31 May 2020 (or by 31 March 2020 if you are administered by an EU member state).

Please bear in mind that your competent authority will only accept emissions reports which are verified by an accredited auditor. You obtain proof of verification from your verifier in the form of a verification report. This report must be submitted to your competent authority along with your emissions report by yourself and by your verifier independently.

How Do I Get My Emissions Report Verified?

You must engage a verification body for the verification of your Annual Emissions Report. This obligation still holds even if you use CERT as monitoring method.

Make sure that your verifier is eligible to perform an emissions report audit. Eligible are verifiers that are accredited by a national accreditation body under ISO 14065:2013 and that meet the relevant requirements in Appendix 6, Section 2 of Annex 16, Volume 4.

If you are unsure, we recommend you get the ICAO document entitled CORSIA Central Registry (CCR): Information and Data for Transparency. It tells you which verification bodies are accredited in your member state.

What Does the Verification Entail?

The aim of the verification is to reach an opinion with reasonable assurance that the emissions information in your emissions report is fairly stated and that your existing procedures conform to the regulation.

Therefore, your verifier will check whether:

• your emissions report is free from material misstatements
• you have monitored, calculated and reported your emissions in accordance with Annex 16, Volume 4 and the approved Emissions Monitoring Plan.

 

To avoid unnecessary delays and to reduce verification costs, we recommend you perform an internal pre-audit before you start the verification.

What Are CORSIA Eligible Emissions Units?

CORSIA eligible emissions units are at the heart of ICAO's offsetting system. We need them for carbon neutral growth. In other words, to make sure that an increase in international aviation emissions goes hand in hand with a reduction of emissions elsewhere. CORSIA achieves this by requiring aircraft operators to offset a part of their emissions through the purchase and cancellation of CORSIA eligible emissions units.

One Emissions unit (also known as carbon credit) represents the reduction of 1 metric ton CO₂ elsewhere. This can be within our outside of the aviation sector.

There are many different emissions units for sale on the carbon market. CORSIA restricts, however, the use of emissions units to those which meet the CORSIA eligible emissions units eligibility criteria.

The CORSIA eligible emissions units eligibility criteria are available for download on the ICAO website. ICAO will also release a list of emissions units which meet the eligibility criteria. Look out for the document entitled CORSIA Eligible Emissions Units.

How Many Emissions Units Do I Need?

Starting from 2021, you must comply with the offsetting rules (also known as offsetting requirements) if you operate non-exempt international flights between two participating member states (see Question 3 to find out which flights are subject to offsetting requirements). This is achieved through the purchase of CORSIA eligible emissions units.

But how many emissions units do you need?

Your competent authority will let you know by 30 November 2024 what your final offsetting requirements are for the Pilot Phase (2021-2023).

Calculating your offsetting requirements for 2023

where:

• OR(2023) are your offsetting requirements for 2023
• OE(2020 or 2023) are your reported emissions from flights subject to offsetting requirements for 2020 or 2023 (PS: Your competent authority will let you know which year)
• SGF(2023) is the sectoral growth factor for 2023.

 

The sectoral growth factor (SGF) for 2023 is calculated using the following formula:

where:

• SE(2023) are total sectoral CO₂ emissions from flights subject to offsetting requirements for 2023
• SE(B) is the average of total sectoral CO₂ emissions from flights subject to offsetting requirements during 2019 (the baseline)

 

It's important to note that baseline emissions are not necessarily the same in 2021, 2022 and 2023. This is because ICAO will recalculate baseline emissions when routes subject to offsetting requirements change as a result of member states opting in or withdrawing their participation in CORSIA.

Where Do I Buy and How Do I Cancel Emissions Units?

You can purchase CORSIA eligible emissions units from carbon trading companies that have access to the carbon market.

These companies will also help you with the surrendering process. ICAO uses the term “cancellation” to describe the permanent removal and single use of an emissions unit such that the same emissions unit may not be used more than once.

The quantity of emissions units to surrender (or to cancel) must be equal to the amount of your final offsetting requirements for a given compliance period. Your first compliance period is the Pilot Phase which spans from 2021 to 2023.

The emissions units you buy for the Pilot Phase must be cancelled before you can report their cancellation to your competent authority.

How Do I Report The Cancellation of Emissions Units?

You have to report the cancellation of emission units to your competent authority.

But how do you do this?

First of all, you need to create an Emissions Units Cancellation Report. The Emissions Units Cancellation Report contains:

• basic company information
• compliance year
• your final offsetting requirements in metric tons, as informed by your competent authority
• total quantity of emissions units cancelled
• a number of technical specifications about the cancellation.

 

Secondly, you must contract a verification body for the verification of your emissions unit cancellation report. Upon successful verification, your verifier will issue a verification report which must be submitted to your competent authority together with the verified Emissions Units Cancellation Report by 31 January 2025 (or 60 days after your competent authority informs you of your final offsetting requirements for the Pilot Phase). Your verifier will also submit the same documentation independently.

As mentioned under Question 13, the verifier you pick must be accredited by a national accreditation body under ISO 14065:2013 and meet the relevant requirements in Appendix 6, Section 2 of Annex 16, Volume 4.

What Information Is Published?

Certain information will be published in the ICAO document entitled CORSIA Central Registry (CCR): Information and Data for Transparency.

ICAO will disclose the following information:

• list of verification bodies accredited in each member state
• total average CO₂ emissions for 2019 and 2020 aggregated for all aircraft operators on each state pair
• total annual CO₂ emissions aggregated for all aircraft operators on each state pair (with identification of state pairs subject to offsetting requirements)
• aircraft operator specific information, including
  • aircraft operator name
  • member state to which aircraft operator is assigned
  • reporting year
  • total annual CO₂ emissions
  • total annual CO₂ emissions for state pairs subject to offsetting requirements
  • total annual CO₂ emissions for state pairs not subject to offsetting requirements
  • various information on emissions reductions from the use of sustainable aviation fuels
  • total final offsetting requirements over the compliance period
  • total quantity of emissions units cancelled over the compliance period

 

To avoid the disclosure of confidential information (e.g. aerodrome pair specific emissions information), you may apply in writing to your competent authority that certain information should only be published at a higher level of aggregation. 

CORSIA can become a problem if:

• you have either a very limited number of state pairs subject to offsetting requirements or a very limited number of state pairs not subject to offsetting requirements
• only a very limited number of aircraft operators conduct flights between certain state pairs.

 

What Happens If I Don't Meet the Deadlines?

This depends on the member state you are assigned to.

The ICAO regulation requires all member states to establish national policies and a regulatory framework for the compliance and enforcement of CORSIA.

What this means in terms of sanctions and penalties is not clear at this stage. We will need to wait for the member states to transpose the regulation into national law.