CORSIA Services in the United States for Airlines, Buyers and Project Developers

CORSIA support for the US market

The United States has the largest international aviation footprint of any single State, and its carriers account for a large share of the emissions covered by the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). At the same time, the US position on CORSIA has become harder to read since 2025. For a sustainability manager at an airline, a cargo or business aviation operator, a corporate buyer or a project developer, that combination means two things: the monitoring and reporting work continues, and decisions about offsetting and units need to be taken with a clear view of what is settled and what is not.

DSTechnoverse supports US clients across that whole picture: applicability checks, Emissions Monitoring Plans and Annual Emissions Reports, preparation for third-party verification, offsetting requirement estimates, sourcing and due diligence of CORSIA Eligible Emissions Units (EEUs), registry and cancellation support, CORSIA eligible fuel claims, and eligibility screening for project developers. We are a consultancy, not a verification body, and we do not represent any government. Our main service page, CORSIA carbon credit services, sets out the full scope; this page explains how it applies to the US market.

The US position on CORSIA: what the record shows

The US position has shifted over time, and parts of it are contested. Below is what public sources say, with dates. We report these as sources describe them and recommend checking the current position with the FAA and ICAO before taking compliance or purchasing decisions.

• 2016: the United States supported the ICAO Assembly resolution that created CORSIA, and the FAA states that the US volunteered for the voluntary phases, meaning the pilot phase (2021 to 2023) and the first phase (2024 to 2026).
• March 2019: the FAA announced its CORSIA Monitoring, Reporting and Verification (MRV) Program in the Federal Register. The notice describes the programme as voluntary and says that offsetting under CORSIA, which may require rulemaking or other action, would be addressed at a future time.
• 2019 onwards: the FAA has renewed the information collection for the programme with the Office of Management and Budget, covering an Emissions Monitoring Plan template, an Emissions Report template and a CORSIA eligible fuels annex. We have not found a final Federal Register rule that places CORSIA offsetting obligations on US operators in domestic law.
• 23 September 2025: at the 42nd ICAO Assembly, US Transportation Secretary Sean Duffy criticised ICAO for spending resources on climate initiatives and said reform would factor into US support for ICAO. Trade press reported that the speech did not refer to CORSIA directly. The same Assembly reaffirmed CORSIA in its climate resolution.
• 27 January 2026: the US withdrawal from the Paris Agreement took effect, one year after notice was given in January 2025. This matters for US-hosted carbon projects, as explained below.
• 2026: commentators disagree on what comes next. Some analysis, including a Carbon Market Watch piece of March 2026, argues the US has made no commitment to enforce offsetting beyond the voluntary phases. Trade press in June 2026 reported United Airlines as saying the US government may give formal backing to airline participation. Advocacy groups have also called for US withdrawal. None of these is a formal government decision.

What applies to US operators on international routes

Under the CORSIA Standards in Annex 16, Volume IV, monitoring and reporting applies to an aircraft operator whose annual CO2 emissions from international flights exceed 10,000 tonnes, using aircraft above 5,700 kg maximum take-off mass, subject to the listed exemptions such as humanitarian, medical and firefighting flights. In the US this is administered through the FAA programme, which uses the FAA's own templates and timelines.

The FAA programme is voluntary. According to FAA material, operators can choose not to take part, in which case the FAA estimates their emissions and reports them to ICAO. The same material says the programme covers over 98 per cent of US emissions subject to CORSIA and includes all major US operators. In practice, most US airlines and many larger cargo and business aviation operators treat CORSIA reporting as a standard annual task.

• Applicability: confirm which flights are international, which are exempt, and whether you cross the 10,000 tonne threshold. See exempt flights and operations and state pairs and route classification.
• Monitoring plan: choose a fuel use monitoring method or, for smaller emitters, the CORSIA CO2 Estimation and Reporting Tool, and keep the plan current as fleets and routes change. Our monitoring plan guide covers the content.
• Annual report and verification: an Emissions Report verified by an accredited verification body, submitted to the FAA within the programme's deadlines.
• Business aviation: US-registered private and charter operators flying internationally are often closer to the threshold than they expect, especially with long-range jets. A threshold check is usually the first step.

Offsetting for US operators: the open question

Monitoring and reporting are only one part of CORSIA. The other is offsetting: operators on routes between two participating States must cancel EEUs to cover their share of the sector's growth above the baseline, which from 2024 is 85 per cent of 2019 emissions. For the first phase, the 2024 to 2026 compliance period, units must be cancelled by 31 January 2028. Our offsetting calculation guide walks through the formula.

The difficulty for US operators is that ICAO calculates and notifies offsetting requirements through States, but enforcement depends on national implementation. The FAA has said offsetting would be addressed separately, and we have not found a final domestic rule. From 2027 the second phase begins, and under ICAO Resolution A41-22 participation becomes expected of States above set aviation activity thresholds, which the US exceeds. How the US will treat that obligation domestically is not settled in public sources.

Our advice to US operators is to plan for both outcomes rather than guess. That means calculating the potential first-phase requirement on your own data, deciding a board position on whether and when to buy units, documenting that decision, and watching the FAA and ICAO for formal notices. Some operators also hold or retire units for reasons outside CORSIA, such as foreign route exposure, investor expectations or their own climate targets.

Foreign operators flying to and from the United States

A foreign airline does not report to the FAA because it flies to New York, Miami or Los Angeles. Under CORSIA, each operator reports to one administering State, normally the State that issued its air operator certificate. A European, Gulf, Asian or Latin American carrier on US routes therefore follows its home authority's rules, and its US routes are counted in the same way as any other international route.

Whether those routes attract offsetting depends on whether both States in the pair appear in the ICAO document CORSIA States for Chapter 3 State Pairs for the year in question. That document is updated annually; ICAO reports 130 participating States for 2026 and 134 for 2027. Foreign operators with large US networks should check the current edition and keep their route classification consistent with it. Where a group runs both a US-certificated subsidiary and a foreign one, each certificate holder has its own administering State and its own obligations.

US corporate buyers of CORSIA eligible units

US companies outside aviation sometimes ask to buy CORSIA eligible units for their own climate claims, because those units carry host-country authorisation and, for the first phase, a corresponding adjustment. There is no rule that stops a non-airline from buying and retiring them, but buyers should understand what they are paying for and why the price is usually higher than for ordinary voluntary credits. See can companies buy CORSIA eligible credits and the price guide.

For a US buyer, the useful questions are practical: does the unit appear under an approved programme and eligible vintage, is there a Letter of Authorization from the host country, has the corresponding adjustment been applied or committed, which registry holds the unit, and how will retirement be recorded so that the claim can be defended to auditors and stakeholders. We run that due diligence and help draft the claim language.

• Eligibility check against the ICAO CORSIA Eligible Emissions Units document for the relevant period.
• Letter of Authorization and corresponding adjustment evidence, including any conditions in the letter.
• Registry account set-up, transfer and retirement records, with a clear beneficiary statement.
• Contract terms covering delivery risk, replacement and price if authorisation is withdrawn.

US project developers and the approved programmes

Three of the CORSIA-approved crediting programmes are well known to US developers: ACR (American Carbon Registry), Verra's Verified Carbon Standard and Gold Standard. All three were approved for the pilot phase and the first phase, and in October 2025 the ICAO Council approved each of them to supply units for the second phase's first compliance period, 2027 to 2029. Approval is not blanket: the ICAO eligible units document lists eligible methodologies, vintages and exclusions, and Verra's second-phase approval, for example, excludes certain cookstove and other project types. Check the current edition of the document before relying on any methodology. Our approved programmes overview explains the structure.

The harder issue for projects located in the United States is authorisation. First-phase and later units need a Letter of Authorization from the host country and a corresponding adjustment under the Paris Agreement. With the US withdrawal from the Paris Agreement effective from 27 January 2026, we are not aware of a route for US-hosted projects to obtain that authorisation, so US-hosted credits are unlikely to qualify for the first phase as things stand. US-based developers with projects abroad face a different question: whether the host country has an Article 6 authorisation process and how long it takes. See corresponding adjustments explained.

We help developers screen projects against the programme and methodology rules, map the host-country authorisation pathway, choose a programme, assemble a documentation pack and identify buyers among airlines and corporates.

Sustainable aviation fuel in the US and CORSIA eligible fuel claims

Operators can reduce their CORSIA offsetting requirement by claiming CORSIA eligible fuels (CEF), including SAF certified under an ICAO-approved sustainability certification scheme. The reduction is based on the fuel's life cycle emissions value compared with the fossil jet baseline. Our SAF and CORSIA guide and eligible fuels page cover the rules.

US SAF policy changed in 2025. The Inflation Reduction Act's SAF-specific credit under section 40B applied to fuel sold in 2023 and 2024, and the section 45Z clean fuel production credit took over from 2025. The law signed on 4 July 2025, known as the One Big Beautiful Bill Act, extended 45Z to fuel produced through 2029, removed the extra SAF premium for fuel produced after 2025 so that SAF is treated like other clean fuels, limited qualifying feedstocks to those from the US, Canada and Mexico, and excluded indirect land use change from the carbon intensity calculation. Treasury and the IRS have since issued proposed regulations. Several states also offer their own SAF incentives, and federal and state compliance credits can apply to the same fuel.

• Tax and compliance credits are generally claimed by the producer or blender, while a CEF claim is made by the aircraft operator. These can coexist, but CORSIA requires the operator to declare the other greenhouse gas schemes it takes part in and to avoid claiming the same batch twice.
• If the environmental attributes of a batch have been sold as SAF certificates to a corporate customer under a book and claim arrangement, the airline should not count the same reduction under CORSIA. Purchase contracts need to say who owns which claim.
• Batch-level evidence matters: sustainability certificates, proof of sustainability, purchase and blending records, and the life cycle value used. We review this before verification.

Our CORSIA services for US clients

• Applicability and threshold check for airlines, cargo and business aviation operators.
• Emissions Monitoring Plan drafting or review using the FAA templates, and change management as fleets and routes change.
• Annual Emissions Report preparation and readiness review before third-party verification. We are not a verification body and do not verify reports ourselves.
• First-phase and second-phase offsetting requirement estimates, with scenarios for policy uncertainty.
• EEU sourcing support and due diligence: programme approval, methodology, vintage, Letter of Authorization and corresponding adjustment.
• Registry account set-up, transfers, cancellation and cancellation reporting support. See registries and cancellation.
• CORSIA eligible fuel claim support, including review of contracts with SAF suppliers and certificate buyers.
• Project developer support: eligibility screening, authorisation pathway, programme selection and buyer matching.

How we work with US clients

We work remotely from Indore, India, with a branch office in Dubai. US engagements run on video calls, shared document folders and email, and we issue quotes in US dollars. Data stays in the systems you choose, and we can work under your confidentiality terms.

Time zones are manageable with a little planning. India is 9.5 to 10.5 hours ahead of US Eastern time depending on daylight saving, so an early-morning call in New York or Washington, D.C. falls in our evening. West Coast clients in California usually prefer a late-afternoon slot Pacific time, which is our early morning. Teams in Texas and Florida fit either pattern. We agree a fixed weekly call during busy periods such as report preparation and verification.

1. 1Short scoping call to understand your fleet, routes or portfolio.
2. 2Written proposal with scope, deliverables and a US dollar quote.
3. 3Data request and review, followed by draft deliverables.
4. 4Review calls, revisions and support through verification or transaction close.

Getting started

If you are a US operator deciding how to handle first-phase offsetting, a foreign carrier with a large US network, a corporate buyer looking at CORSIA eligible units, or a developer weighing ACR, Verra or Gold Standard, send us the details through our contact page. For background reading, start with the CORSIA carbon credits complete guide and the compliance roadmap for airlines.

Frequently Asked Questions

Guides and Resources

• CORSIA carbon credit services →
• CORSIA carbon credits complete guide →
• CORSIA carbon credit price guide →
• Sustainable aviation fuel and CORSIA →
• CORSIA compliance roadmap for airlines →
• CORSIA Eligible Emissions Units →
• CORSIA registries and cancellation →
• CORSIA phases and timeline →