Aviation Emissions Compliance

From 1st January 2019, all aeroplane operators conducting flights between any of ICAO’s Member States will have to monitor and report their annual carbon emissions. ICAO’s new Carbon Offsetting and Reporting Scheme for International Aviation (“CORSIA”) also requires each operator to submit a Monitoring, Reporting and Verification plan. These obligations are currently in addition to the EU’s Emission Trading system (“EU ETS”) regulations and the UK’s Emissions Trading System (”UK ETS”) regulations.

CORSIA could create a significant compliance burden for aeroplane operators and exposes aircraft beneficial owners to additional risks. The picture is further complicated in that the regulations are being introduced incrementally, as each ICAO Member State is at liberty to amend ICAO’s Standards and Recommended Practices and moreover, to introduce whatever non-compliance penalties they deem appropriate.