CORSIA Services in the UAE and the Middle East

CORSIA Consultant for the UAE and the Gulf

CORSIA, the Carbon Offsetting and Reduction Scheme for International Aviation, matters more to Gulf aviation than to almost any other region. The large hub carriers in Dubai, Abu Dhabi, Doha and Riyadh fly almost entirely international networks, so nearly all of their CO2 falls within the scheme's scope, whereas carriers with big domestic markets have a large share of their flying outside it. Cargo operators, business aviation operators and newer carriers in the region face the same rules on a smaller scale.

DSTechnoverse supports CORSIA compliance in the Middle East on both sides of the market. For aircraft operators we cover applicability checks, Emissions Monitoring Plans, Annual Emissions Reports, verification readiness, offsetting requirement estimates and the sourcing, transfer and cancellation of CORSIA Eligible Emissions Units (EEUs). For project developers and credit holders in the region we cover eligibility screening, programme selection, the host-country authorisation pathway and buyer matching. The full service scope is set out on our CORSIA carbon credit services page; this page explains how it applies in the Gulf.

Where the Gulf States Stand on CORSIA Offsetting

CORSIA has three phases: a pilot phase from 2021 to 2023, a first phase from 2024 to 2026 and a second phase from 2027 to 2035. Participation in the pilot and first phases is voluntary. An offsetting requirement arises only on routes where both the State of departure and the State of arrival participate in that year. All six GCC States have notified ICAO that they are participating, though they joined at different times:

• United Arab Emirates, Saudi Arabia, Qatar and Oman: identified in ICAO Assembly working papers as volunteering for both the pilot phase and the first phase.
• Kuwait: notified ICAO in June 2023 that it would participate voluntarily, which brought it in from 2024.
• Bahrain: notified ICAO in June 2024, and it appears in ICAO's list of States participating from 1 January 2025.

What This Means for Gulf Routes

Because all six GCC States participate, intra-Gulf routes and routes between the Gulf and most of Europe, North America, the UK and many African and Asian States carry offsetting obligations in the first phase. Routes to States that have not volunteered remain subject to monitoring and reporting but not to offsetting. Because the list changes every year, any offsetting estimate should be built from the current edition of the ICAO document "CORSIA States for Chapter 3 State Pairs" for the relevant year, not from memory.

Monitoring, reporting and verification (MRV) applies to any operator emitting more than 10,000 tonnes of CO2 a year from international flights with aeroplanes above 5,700 kg maximum take-off mass, whether or not its routes are subject to offsetting. From 2024 the baseline is 85% of 2019 emissions, and until 2032 each operator's obligation is calculated with a 100% sectoral growth factor. Under ICAO Resolution A41-22 this changes to 85% sectoral and 15% individual for 2033 to 2035, which matters for fast-growing Gulf carriers. Our offsetting requirement calculation explainer works through the formula.

CORSIA in the UAE: GCAA, National Registry and Carbon Market

In the UAE, the General Civil Aviation Authority (GCAA) administers CORSIA for operators attributed to the UAE. It reviews Emissions Monitoring Plans, receives verified emissions reports, reports to ICAO and sets each operator's offsetting requirement. The UAE has taken part since the pilot phase. At the end of December 2024 the GCAA launched what it described as the region's first digital platform for CORSIA implementation, replacing manual data submissions by national carriers with an online system that stores emissions records and calculates offsetting values. Operators attributed to the UAE should expect their monitoring, reporting and EEU cancellation evidence to pass through that platform, so data quality and consistency with the approved monitoring plan matter from the start.

Outside aviation, the UAE has built a national legal framework for emissions and carbon credits. Federal Decree-Law No. 11 of 2024 on the reduction of climate change effects sets out emissions measurement and reporting duties, and Cabinet Resolution No. 67 of 2024 established a National Register for Carbon Credits under the Ministry of Climate Change and Environment (MOCCAE). The register covers measurement, reporting, verification and trading of emissions and credits, and its definitions refer to credits that can be transferred internationally under Article 6 of the Paris Agreement. CORSIA eligibility, however, is decided only by the ICAO Council, and a first-phase unit also needs a Letter of Authorization from its host country and a corresponding adjustment. A UAE group whose airline and non-aviation businesses both buy carbon credits will therefore need two separate compliance tracks, with careful labelling so that units are not counted twice.

Saudi Arabia, Qatar, Oman, Bahrain and Kuwait

The national authorities across the region follow the same ICAO standards (Annex 16, Volume IV), but each issues its own regulations, templates and deadlines. The main points we have verified are:

• Saudi Arabia (GACA): the General Authority of Civil Aviation has written CORSIA into its regulations through GACAR Part 157, which covers offsetting applicability, emissions reductions from CORSIA eligible fuels and total offsetting requirements. Saudi Arabia volunteered for the pilot and first phases. The Public Investment Fund and Saudi Tadawul Group set up the Regional Voluntary Carbon Market Company, which has auctioned credits including CORSIA-eligible units and launched an exchange platform in November 2024.
• Qatar (QCAA): the Qatar Civil Aviation Authority volunteered for the pilot and first phases and has trained other States in the region under ICAO's ACT-CORSIA buddy programme. Qatar also hosts the Global Carbon Council, a crediting programme that has been approved by the ICAO Council to supply units for the first phase.
• Oman (CAA): the Civil Aviation Authority issued a national CORSIA regulation (CAR-CORSIA) effective 1 March 2025, setting out the duties of operators and the authority for emissions monitoring, reporting and offsetting. Oman volunteered for the pilot and first phases.
• Bahrain (Bahrain CAA): Bahrain's civil aviation authority notified ICAO of voluntary participation in June 2024, and Bahrain is listed among the States participating from 1 January 2025.
• Kuwait (DGCA): Kuwait's Directorate General of Civil Aviation notified ICAO in June 2023, bringing Kuwait into offsetting from 2024.

What Operators Based in the Region Need to Do

For an airline, cargo operator or business aviation operator attributed to a Gulf State, the compliance cycle in the first phase follows the ICAO sequence, adapted to the national authority's templates and dates:

1. 1Confirm applicability: international emissions against the 10,000-tonne MRV threshold, aircraft mass, and which routes are offsetting routes for the year in question.
2. 2Keep the Emissions Monitoring Plan current, updating it for fleet changes, new routes, new fuel monitoring methods or changes of ownership.
3. 3Compile the Annual Emissions Report from fuel and flight data and prepare it for verification by an accredited third-party verification body. We prepare operators for verification; we are not a verification body. See our CORSIA verification guide.
4. 4Estimate the offsetting requirement each year from published growth factors, so that finance teams can set budgets before the compliance-period total is final.
5. 5Source and cancel first-phase EEUs with complete authorisation and corresponding adjustment evidence, then submit the cancellation report to the national authority.

Foreign Operators Flying to the Gulf

An operator based in Europe, Asia, Africa or the Americas that flies into Dubai, Abu Dhabi, Doha, Riyadh, Jeddah, Muscat, Bahrain or Kuwait does not report to the GCC authority at the destination. Under CORSIA each operator is attributed to one State, normally the State that issued its Air Operator Certificate, and that State's authority administers its MRV and offsetting. What the Gulf destination does change is the route classification: because all six GCC States participate, a flight between a participating home State and the Gulf counts towards the offsetting obligation.

For foreign operators, the practical work is route-level accuracy: separating flights to the Gulf from flights to non-participating States, checking that technical stops and fifth-freedom sectors are recorded correctly, and modelling how expanded Gulf schedules affect the next offsetting estimate. We support foreign operators on these points remotely, working to their own authority's requirements. Our CORSIA compliance roadmap for airlines sets out the annual cycle.

Buying CORSIA Eligible Emissions Units from the Gulf

First-phase EEU supply is tight. The binding constraint is not the number of carbon credits in existence but the small number of host countries that have issued Letters of Authorization and committed to corresponding adjustments. Industry bodies including IATA have repeatedly asked governments to release more authorised units. For Gulf buyers, whether airline sustainability teams, group treasury functions or trading desks in Dubai and Abu Dhabi, this changes how units should be sourced and checked.

Our due diligence on each unit or batch checks the following, in line with our CORSIA credit due diligence checklist:

• The programme is on the current ICAO list of first-phase eligible programmes, and the unit falls within that programme's approved scope.
• The vintage and the project's crediting-period start date fall within the eligibility window for the compliance period.
• A host-country Letter of Authorization exists for use in CORSIA, and there is evidence of a corresponding adjustment or a clear commitment to one.
• The unit carries the programme registry's CORSIA label, and there are no double-claiming risks from domestic registers or voluntary claims.
• The contract covers delivery risk, replacement obligations if authorisation fails, and the registry account and cancellation steps.
• Price is benchmarked against comparable eligible supply, using our CORSIA carbon credit price guide as background.

Project Developers in the Region Selling into CORSIA

The Gulf is both a buyer and a potential supplier of eligible units. Renewable energy, methane capture, waste and industrial efficiency projects in the region, and projects that Gulf-based developers own in Africa and Asia, may be able to supply CORSIA demand if they meet the eligibility rules. Programmes active in the region include the Qatar-based Global Carbon Council alongside the international standards on the ICAO list of CORSIA eligible emissions units.

For developers, the hardest step is usually authorisation. The host government has to issue a Letter of Authorization for CORSIA use and apply a corresponding adjustment, which links each sale to the country's own Nationally Determined Contribution. In the UAE that question sits alongside the National Register for Carbon Credits; in other host countries it sits with the national Article 6 authority. We screen projects for eligibility, compare programme routes, map the authorisation process for the host country and introduce suitable projects to buyers. The corresponding adjustments guide explains the mechanism.

Sustainable Aviation Fuel in the Gulf and CORSIA Claims

Operators can reduce their offsetting requirement by using CORSIA eligible fuels, which are sustainable aviation fuel (SAF) and lower carbon aviation fuel certified against the CORSIA sustainability criteria. Gulf supply is still at an early stage but is growing:

• The UAE's General Policy for Sustainable Aviation Fuel sets a voluntary goal for locally produced SAF to supply at least 1% of fuel for national airlines at UAE airports by 2031, together with a domestic production target of 700 million litres a year by 2030. UAE officials have said publicly that a move towards a mandatory requirement is being studied.
• In Saudi Arabia, SAF blended with conventional jet fuel has been available at Red Sea International Airport, where Saudia began operating flights on uplifted SAF in 2025. GACA's environmental sustainability programme and SATORP's certified SAF produced from used cooking oil point to further supply.
• Fuel suppliers in the region, including ADNOC in the UAE, have obtained sustainability certification to supply SAF. For a CORSIA claim, what matters is that each batch is certified by a scheme approved for CORSIA and that the documentation reaches the operator.
• Our role is to check that SAF purchases are documented in a way that supports a CORSIA emissions-reduction claim, that the same fuel is not claimed twice under another scheme or a corporate customer programme, and that the claim is reflected correctly in the emissions report.

How We Work with Gulf Clients

Our CORSIA team works remotely with operators and companies across the GCC, and our branch office in Dubai (205B Al Nakheel Building, Karama; +971 52 735 8300) means meetings in Dubai can be arranged when a working session in person is useful. Proposals and invoices can be issued in US dollars. Data is exchanged through secure shared folders, and outputs are prepared in the format the national authority requires.

A typical engagement starts with a short scoping call and a review of your current monitoring plan, latest emissions report and route list. Fuel teams can also bring their SAF supply contracts for an emissions-reduction claim review using our SAF and CORSIA guidance. We then confirm scope and timing in writing. To discuss your requirements, contact us.

Frequently Asked Questions

Guides and Resources

• CORSIA Carbon Credit Services →
• CORSIA Carbon Credits: Complete Guide →
• CORSIA Carbon Credit Price Guide →
• CORSIA Compliance Roadmap for Airlines →
• Sustainable Aviation Fuel and CORSIA →
• CORSIA Eligible Emissions Units →
• CORSIA Phases and Timeline →
• CORSIA Registries and Cancellation →