Learn how CORSIA applicability is determined, including operator thresholds, route coverage, aircraft exemptions, participating States, and common compliance challenges.
By Emissence
In our previous article, we introduced the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) and explained its role in addressing emissions from international aviation.
One of the most common questions aircraft operators ask is whether they are actually required to comply with CORSIA. The answer depends on several factors, including the type of operation, emissions levels, aircraft size, and the routes being flown.
Understanding applicability is the first step toward building an effective compliance programme.
CORSIA applies only to international flights between ICAO Member States. Domestic flights are excluded from the scheme.
Examples of routes that may fall within the scope of CORSIA include:
Whether a specific route is covered depends on the participation status of the States involved.
A flight operating entirely within a single country does not fall under CORSIA, regardless of the emissions generated.
An aircraft operator becomes subject to CORSIA monitoring, reporting, and verification requirements when both of the following conditions are met:
Once an operator exceeds this threshold, monitoring and reporting obligations generally apply for future reporting periods.
The 10,000-tonne threshold applies only to international aviation emissions.
Many operators incorrectly assume that total company emissions determine applicability. In reality, only emissions from international flights are considered.
This distinction is particularly important for operators with large domestic networks and relatively limited international operations.
Certain aircraft are excluded from CORSIA requirements.
Flights performed by aircraft with a maximum certificated take-off mass (MTOM) below 5,700 kg are exempt.
This exemption removes many smaller business aviation and general aviation operations from the scheme.
Several categories of flights are excluded from CORSIA, including:
These exemptions recognize the public service nature of these operations.
ICAO provides specific provisions for new entrants entering the market.
Operators commencing international operations after the introduction of CORSIA may be subject to modified requirements during their initial years of operation before standard applicability provisions apply.
CORSIA applicability is not determined solely by the operator. The participation status of the departure and destination States also plays an important role.
As ICAO Member States continue to join subsequent implementation phases, the number of routes covered by CORSIA continues to expand.
Operators should therefore periodically review route applicability rather than assuming that current obligations will remain unchanged indefinitely.
Many operators face difficulties in:
These challenges often become more significant as international operations expand.
Determining whether an operator falls within the scope of CORSIA is more complex than simply reviewing flight activity. Thresholds, exemptions, aircraft characteristics, and route applicability must all be considered.
In our next article, we examine the practical aspects of CORSIA compliance, including emissions monitoring, verification, CORSIA Eligible Fuels, and offsetting requirements.
Emissence supports aircraft operators with CORSIA applicability assessments, Monitoring Plans, emissions reporting, and verification readiness.
Our team helps operators understand their obligations and establish efficient compliance processes.
Contact us at [connect@emissence.com](mailto:connect@emissence.com) to discuss your CORSIA compliance requirements.
ICAO has published an updated overview of CORSIA Eligible Emissions Units (CEEUs), providing transparency on approved carbon credit programmes and the emissions units available for use during the 2024–2026 CORSIA First Phase.
An introduction to CORSIA, ICAO’s global carbon offsetting scheme for international aviation, including applicability, reporting requirements, and why it matters for aircraft operators.
Understand the practical aspects of CORSIA compliance, including emissions monitoring, annual reporting, independent verification, CORSIA Eligible Fuels, and offsetting requirements.
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