CORSIA compliance

Howden has been appointed by Gold Standard and Verra to approve third party insurance policies to enable the supply of CORSIA Eligible Emission Units or Verified Carbon Units

What is CORSIA?

CORSIA stands for the Carbon Offsetting and Reduction Scheme for International Aviation. It is a global market-based measure developed by the International Civil Aviation Organization (ICAO) to address CO2 emissions from aviation.

 

What is CORSIA trying to solve?

CORSIA aims to stabilise net CO2 emissions from international aviation at 2019 levels.

The ultimate goal is to support the aviation industry's commitment to achieving net-zero carbon emissions by 2050. This aligns with global efforts to limit the increase in global average temperature to well below 2°C above pre-industrial levels, as outlined in the Paris Agreement.

What is the timeline for CORSIA implementation?

CORSIA is being implemented in phases to accommodate the diverse circumstances of states, particularly developing nations, and to minimise market disruptions. 
  • Pilot Phase (2021-2023): Voluntary participation, focus on monitoring and reporting.
  • First Phase (2024-2026): Voluntary participation, mandatory offsetting begins.
  • Second Phase (2027-2035): Mandatory participation, expanded offsetting requirements.

The baseline for CORSIA is set at 85% of 2019 emissions levels for the period from 2024 to 2035. This means that airlines participating in CORSIA will need to offset any growth in their emissions above this 85% threshold.

How will CORSIA maximise impact?

This ensures transparency and accountability in the offsetting process.

There are two main fuel options: Sustainable Aviation Fuels (SAF) and Lower Carbon Aviation Fuels (LCAF). To ensure that these fuels meet the required criteria, they must be certified by approved Sustainability Certification Schemes (SCS). These schemes evaluate the fuels based on the CORSIA sustainability criteria and provide certification for compliance.

This means that for any increase in emissions beyond the set baseline, airlines must buy credits known as CORSIA Eligible Emissions Units.

These credits are generated by projects that reduce or remove CO2 from the atmosphere, such as reforestation, clean energy projects, and other verified carbon reduction initiatives.
plane flying over modern building

Ensuring eligibility for CORSIA

To be eligible for CORSIA these carbon credits must be issued by ICAO-approved standards and then pass through certain technical steps in order to be accepted under the CORSIA scheme.

List of ICAO-approved standards:

• ART TREES
• ACR (American Carbon Registry)
• Climate Action Reserve (CAR)
• Global Carbon Council (GCC)
• Gold Standard *
• Verra*
• Isometric*

* In 2026 Howden was appointed by Gold Standard, by Verra, and by Isometric to approve insurance policies on their behalf. 

CORSIA, political risk and carbon insurance

  • Eligibility

    To qualify under CORSIA, carbon credits must be issued by standards approved by the ICAO and meet specific eligibility criteria. These include demonstrating reductions that are real, measurable, and permanent; having crediting periods that begin after 2016; and having emission reductions occurring after 2021. Additionally, the credits must originate from ICAO-approved standards and be accompanied by a Letter of Authorisation from the host country to avoid double-counting.

  • Corresponding adjustments

    A key component of eligibility for CORSIA is a carbon credit having a ‘corresponding adjustment’ - essentially, an accounting mechanism to make sure that if a credit is generated in one country and sold to a buyer in another, then the environmental benefit is not claimed in both countries - i.e. double counted or double claimed.

  • Mandatory insurance

    For CORSIA compliance, either corresponding adjustments or insurance must be in place. Howden helps project developers, financial intermediaries and airlines navigate complexities and understand the risk transfer options. In the case of CORSIA, insurance policies for carbon project developers can mitigate political risks associated with generating credits by addressing the failure to make the corresponding adjustments. This could be because a government revokes the Letter of Authorisation or because of a lack of technical infrastructure to make the adjustments.

  • Risk mitigation

    There are risks in this process that can be mitigated via insurance. Howden has been leading the development of this market. In 2023 Howden partnered with Abatable to produce a VCM Country Attractiveness Index, and in 2024 Howden was appointed by Gold Standard to consult on insurance solutions for CORSIA.

At Howden, we're ahead of the game

In addition to supporting the development of insurance to specifically meet CORSIA standards, we continue to support the carbon market as a whole:

Our global team of aviation specialists is here to help airlines and aviation businesses navigate their insurance and risk management needs with confidence. Explore our aviation insurance offering here and download our full capabilities brochure here for more information.

This is a perfect example of how embedded insurance enhances carbon market integrity, in this case supporting the aviation energy transition by allowing the issuance of credible carbon credits and facilitating compliance with CORSIA
Charlie Pool- Head of Carbon Markets

How can we help you?

There are steps along the way to CORSIA compliance that can be mitigated by insurance.

  1. If you are an insurer, read more about the process for approving policies in line with , , or .
  2. For project developers and investors seeking insurance cover please contact us 
  3. We can help airlines manage risks associated with CORSIA compliance. This includes project analysis, efforts to reduce aviation emissions, such as technological advancements and the use of sustainable aviation fuel (SAF), and risk transfer. 

For any enquiries please contact the [email protected]

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  • Photo of Thomas Kelly

    Thomas Kelly

    Associate Director, Howden CAP