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CORSIA take-off: Market dynamics expected to accelerate procurement for aeroplane operators
19 December 2025 4 minute read

CORSIA take-off: Market dynamics expected to accelerate procurement for aeroplane operators

Carbon markets & climate policy
Judit Legrady
Judit Legrady Sr. Managing Consultant, Article 6 and CORSIA

In 2025, CORSIA evolved from a ‘policy to be monitored’ to a 'compliance plan to be executed' for impacted aeroplane operators.

This year marked a pivotal moment for the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) with the transition from a voluntary scheme to an active, compliance mechanism. One of the key moments was ICAO's 42nd Assembly, where CORSIA was reaffirmed as the only global market-based measure for international aviation CO2. At the same time, ICAO expanded Phase I eligible programme options and confirmed the first set of standards that are approved for Phase II. What's more, for the first time, airlines started receiving state notifications indicating their 2024 offsetting requirements. The result: many operators are expected to move from CORSIA estimates to CORSIA procurement plans.

This blog post is for sustainability, compliance, treasury and procurement teams within aeroplane operators impacted by CORSIA obligations and focuses on what changed this year, what it means for your sourcing strategy, and what to do next.

The policy pivot: from framework to fixed obligation

The most immediate change for operators is the definitive shift from scenario planning to concrete, measurable compliance requirements. Two recent developments are accelerating procurement:

  • A published (and positive) 2024 Sectoral Growth Factor (SGF): The SGF reflects the growth of international aviation emissions above a pre-defined baseline. For 2024, it was set at approximately 15.4%, serving to determine the offsetting obligations for that year. This means aeroplane operators now have a set liability for 2024 emissions.
  • State notification: guidance for operators required States to communicate final obligations by 30 November 2025. This shifts operators from estimates into execution.

Bottom line: aeroplane operators impacted by CORSIA requirements must update their procurement plans to match their internal strategy with market reality, contracting lead times, and the January 2028 Phase I deadline.

Navigating the evolving supply landscape

While demand is moving ahead, the supply side of the market is characterised by constraints, driven by specific ICAO criteria and evolving regulatory bottlenecks. This situation creates strategic urgency: despite an estimated total market demand for the 2024 year alone of around almost 50 million eligible carbon credits (Source: Carbon Pulse), the pool of fully eligible and tagged on the approved registries remains limited, currently sitting at only an estimated ~18 million tonnes (Sources: GSF Registry, ART Registry, as of 18/Dec/25). This significant gap highlights a key strategic risk: delayed procurement might expose operators to volatility, potential price spikes, and competition for a limited volume of verified units.

Key factors shaping CORSIA supply:

  • To address some of the gaps mentioned above, ICAO has expanded the potential supply pool, though with increased complexity. For Phase I (2024–2026), ICAO broadened the list of approved standards by adding Isometric and Premium T-Ver, joining the existing six approved standards (including Gold Standard and Verra). However, units generated under any standard must still adhere to specific project types and vintage restrictions (e.g. limits on grid-connected renewables over 15 MW and certain large-scale REDD+ projects).
    Why does this matter for airlines? Supply is expanding, but near-term “buyable" volumes are still limited, and the gap matters for price and delivery risk.
  • Gold Standard has approved new insurance products that support CORSIA eligibility pathway under its programme, adding policies from providers including Artio, CFC and Oka.
    Why does this matter for airlines? It will increase the number of projects able to reach CORSIA eligible labelling on the registry.
  • The Council of the European Union shared the position of potential additional requirements on the units, originating from (1) states implementing the Paris Agreement and (2) participating in CORSIA.
    Why does this matter for airlines? For EU-based carriers, an additional eligibility filter with premium may apply. (Further implementation act to follow possibly in Q1)

From the cost of inaction to a strategic procurement plan

Given the tighter market and clearer obligations, the most resilient approach is to treat CORSIA liability and turn it into a manageable compliance asset by:

  1. Translate your obligation into a buying plan
    Build an internal forecast for 2024–2026 needs and stress-test timing vs. the Jan 2028 deadline.
  2. Define your eligibility filters upfront and your risk appetite
    Programme-approved is different to unit-eligible. Build a screening checklist including the following criteria: ICAO scope, host authorisation/corresponding adjustment evidence, registry CORSIA label and EU overlay, if relevant.
  3. Diversify supply risk
    Consider multiple programmes/project types that fit your integrity criteria, and watch "readiness" signals (e.g. authorisations/corresponding adjustment pathways) globally.
  4. Develop a hedging strategy with the right partner
    Building a CORSIA hedging strategy early with the right partner helps airlines stay aligned with evolving requirements while reducing exposure to penalties, supply tightness, and last-minute execution risk. It also gives you more flexibility, control over time and diversifies eligible supply globally, as part of a robust compliance plan.

Where to start? South Pole can help!

South Pole supports aeroplane operators for more than a decade. We leverage close to two decades of carbon market experience and a global platform to help operators secure compliance obligations strategically and cost-effectively.

  • CORSIA supply pipeline: We hold one of the largest portfolios of CORSIA-eligible projects, including 30+ projects across 6 technologies (e.g., clean cooking, water purification, biogas) and three continents. This diversified pipeline ensures hedging opportunities and a stable source of supply for Phase I and the future.
  • Strategic advisory: We work with operators to define their long-term offset strategy, providing a government roadmap regarding their host country's Article 6 of the Paris Agreement plans, and the implications for unit eligibility.
  • Proven aviation track record: Our experts have supported 50+ aviation companies since 2015, providing comprehensive guidance on carbon market journeys, including advisory for flagship carriers on compliance and portfolio optimisation.
  • Compliance certainty: We help navigate the intricate details of ICAO and jurisdictional requirements, ensuring that every procured unit meets both ICAO's technical eligibility and any specific EU or national rules.
A Quick Guide to CORSIA

A Quick Guide to CORSIA

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Get in touch with our CORSIA experts today
Judit Legrady, Sr. Managing Consultant, Article 6 and CORSIA

Get in touch with our CORSIA experts today

Contact our team today to explore how we can help you understand and develop effective CORSIA strategies for your decarbonisation journey.

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