The COVID-19 pandemic has posed unprecedented challenges to the world, including the international air transport sector. This web page aims to provide up-to-date information on various impacts of the ongoing situation
on the implementation of the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), as well as the remedial measures and decisions being taken by ICAO.
Impact of COVID-19 on CORSIA implementation in 2020
2020 CORSIA reporting timelines
CORSIA implementation is undertaken as per the Standards and Recommended Practices (SARPs) contained in
Annex 16, Volume IV, the First Edition of which
became applicable on 1 January 2019. Appendix 1 of Annex 16, Volume IV includes timelines for the 2020 reporting of CO2 emissions from international aviation activity in 2019, namely:
Identified challenges for verification and site visit
Since the outset of the COVID-19 pandemic, several States and aeroplane operators alike have expressed concerns regarding their capacity to meet the 2020 CORSIA reporting timelines above. A frequent cause of the concern is the difficulty to conduct the verification of the aeroplane operators’ Emissions Reports, due to the fact that mobility restrictions pose a challenge to the organization of verification bodies’ site visits to the operators’ facilities.
In the context of the verification of aeroplane operators’ Emissions Reports,
site visits are not a requirement as per the SARPs in Annex 16, Volume IV, although they are recommended in the guidance provided in the Second Edition of the
Environmental Technical Manual (Doc 9501), Volume IV.
ETM, Volume IV describes the site visit as an essential part of the verification activities, in order for the verification body to collect sufficient and appropriate evidence to confirm whether the Emissions Report is free from material misstatements and material non-conformities. The decision to undertake a site visit as part of the verification of the aeroplane operator’s Emissions Report is to be taken by the verification body on the basis of a risk analysis during the preparatory stage of the verification.
Alternative approach (e.g. remote verification) with risk analysis and coordination
ETM, Volume IV provides additional information on the procedure to be followed in the event of a verification body’s decision to not conduct site visits in the context of the verification of an aeroplane operator’s Emissions Report:
If the verification body decides to replace a site visit(s) with other means, this has to be clearly indicated in the Verification Report. This includes the reasoning for the decision on the basis of the risk analysis as well as a detailed explanation of the technical systems used. The verification body should coordinate with the State of the aeroplane operator before replacing the site visit with an alternative approach.
— ETM, Volume IV, 188.8.131.52
In line with this, several States may need to consider flexibility to replace a site visit with remote verification techniques as part of the verification process, in coordination with their national accreditation bodies, aeroplane operators and verification bodies. Some States are already taking steps to provide a certain degree of flexibility to their operators regarding the date of submission of the verified Emissions Reports, while at the same time still considering 31 August 2020 as a plausible date for the submission of aggregated information from States to ICAO.
Mindful of the concerns from States and aeroplane operators in terms of their capacity to meet the 2020 CORSIA reporting requirements and timelines in light of the COVID-19 pandemic, ICAO adjusted the planned CORSIA capacity building activities, including the deployment of additional activities, to allow for a continuous support to States.
Thus far, the following activities have been undertaken:
Impact of COVID-19 on CORSIA design
While more information is needed to accurately quantify the impact of the COVID-19 pandemic on the aviation sector's CO2 emissions in 2020 and subsequent years, this impact has resulted so far in a sharp decline in aviation activity, with an expected related decrease in the sector's CO2 emissions in 2020, compared to the forecasted 2020 CO2 emissions prior to the pandemic.
CORSIA's sectoral baseline is defined as the average of total CO2 emissions for the years 2019 and 2020 on the routes covered by CORSIA offsetting in a given year from 2021 onwards (Assembly Resolution A40-19, paragraph 11). Therefore, the expected reduction of the 2020 CO2 emissions from international aviation due to the COVID-19 pandemic will lead to a decrease of the CORSIA baseline, compared to the non-COVID-19 scenario.
It is important to note that the COVID-19 pandemic is expected to affect not only the global aviation sector's 2020 activity, but also that of subsequent years. The impact on the sector's CO2 emissions in years to come is being assessed by the development of possible recovery scenarios from 2021 onwards, which are subject to a high level of uncertainty.
The impact of the COVID-19 pandemic on the
CO2 emissions from international aviation in 2020 and subsequent years could affect the following three CORSIA's design features, defined in
Assembly Resolution A40-19, as follows:
Considerations on the need and timing to adjust the CORSIA baseline and other design features above, if appropriate, need to be based on proper technical data and assessment. On the matter of timing, for potential adjustments, due consideration has to be given to the timeline for CORSIA implementation, as described in Appendix 1 of Annex 16, Volume IV, and to the related milestones, as follows:
Any adjustment to CORSIA's design features is a matter that requires careful consideration by the relevant ICAO bodies. The ICAO Council, at the 220th Session in June 2020, considered an analysis by the Committee on Aviation Environmental Protection (CAEP) on the COVID-19 impact on CORSIA's design features.
In addition to the impact assessment, the Council also considered the legal and reputational aspects related to the various options, as well as the importance of maintaining the originally-agreed balance between the scheme's economic impacts and environmental benefits together with its simplicity and practicality, whilst responding to this unprecedented crisis.
The Council agreed that, in order to safeguard against inappropriate economic burden on aeroplane operators, 2020 emissions should not be used for the three CORSIA design features listed above. In this regard,
the Council decided that during the pilot phase, 2019 emissions shall be used for 2020 emissions and published in all relevant ICAO documents referenced in Annex 16, Volume IV. There was no change for the provisions of Annex 16, Volume IV or Assembly Resolution A40-19 text.
In addition to the above, it is important to note that paragraph 17 of Assembly Resolution A40-19 includes a provision that the ICAO Council will conduct a periodic review of the CORSIA every three years from 2022. In this regard,
the Council highlighted the importance of undertaking the 2022 periodic review, with technical contribution of the Committee on Aviation Environmental Protection (CAEP), which will offer an opportunity to examine the impact of COVID-19 on CORSIA on various issues, including the impact on the baseline beyond the pilot phase.
In March 2021, the ICAO Council agreed on the process and methodology for the CORSIA periodic review toward 2022, and on the framework for the consideration of inputs from its subsidiary bodies (such as the CAEP and the TAB). Any recommendations by the Council will be forwarded for consideration by the 41st ICAO Assembly scheduled for 2022.
In June 2021, the updated CAEP scenario-based analyses on potential impacts of COVID-19 on CORSIA and its executive summary were presented to the 223rd session of the ICAO Council (C-WP/15209).