Airlines and airline associations have broadly welcomed ICAO’s new carbon offsetting scheme, scheduled to commence on January 1, 2019. However, the scheme’s Standards and Recommended Practices (the SARPs) impose an immediate compliance obligation on international airlines and raise a number of potential risks for aircraft financiers and lessors.

In June 2016, the 39th Assembly of the International Civil Aviation Organization (ICAO) agreed to adopt a global market-based measure to control aviation carbon dioxide (CO2) emissions,1 This scheme is referred to as the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). On June 27, 2018, ICAO’s Council adopted the First Edition of Annex 16, Volume IV, which details the international SARPs for CORSIA.2 Ultimately, over 700 aircraft operators3 (Operators) worldwide will be compelled to comply with various aspects of the scheme.

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