CORSIA Carbon Credit Supply vs Demand: Will Airlines Be Ready for 2028 Compliance?

July 25, 2025
4
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TL;DR

CORSIA faces a critical supply-demand imbalance with only 15.84 million credits currently available against potential demand of 144 million EEUs by January 2028. While 4,000+ projects could technically supply credits, only 1,500 are located in countries ready for Article 6 authorizations. Expert consensus suggests partial compliance with limited supply is the most likely outcome, as fewer than 15 countries have defined CORSIA enforcement rules despite the approaching deadline.

How CORSIA compliance is shaping up right now

With just 18 months until CORSIA's First Phase compliance deadline, the aviation industry faces an uncomfortable truth: the market for CORSIA carbon credits barely exists, and compliance readiness remains dramatically underdeveloped globally.

The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) was designed to achieve carbon-neutral growth in international aviation from 2020 onward. However, as airlines approach the January 31, 2028 deadline to retire Eligible Emissions Units (EEUs) covering 2024-2026 emissions, both supply availability and compliance frameworks remain uncertain.

This creates what industry experts describe as a "chicken-and-egg" challenge: project developers and host countries need clear demand signals to unlock supply, but demand signals remain muted because airlines are waiting for supply certainty and regulatory clarity on enforcement.

At Sylvera, we conducted an industry-first market modeling to project the feasible outcomes of CORSIA Phase 1, under different supply, demand, and compliance constraints.

CORSIA supply and demand volumes

Supply reality: Severe constraints ahead

Current available supply: As of June 2025, only 15.84 million CORSIA-eligible credits have been issued—all from Guyana's jurisdictional REDD+ program. When these credits were auctioned in late 2024 at $21.70 per unit, only 11 airlines purchased fewer than 400,000 credits, highlighting the market's nascent state.

Potential vs. accessible supply: While over 4,000 projects across ICAO-approved registries could technically supply EEUs, the reality is far more constrained. Only approximately 1,500 projects are located in the 16 countries that demonstrate moderate readiness for Article 6 authorizations under the Paris Agreement.

Supply projections: Market modeling suggests CORSIA EEU supply could range dramatically:

  • Maximum scenario: 274 million EEUs by end of 2027 (assumes 30+ countries ready to authorize)
  • Moderate scenario: 170-191 million EEUs (assumes 15+ countries ready)
  • Constrained scenario: Just 136-144 million EEUs (assumes only 7 countries provide authorizations)

The wide range reflects the fundamental uncertainty around host country willingness and capacity to provide the necessary authorizations with corresponding adjustments.

Demand uncertainty: Will airlines actually comply?

Theoretical demand: If all airlines in participating jurisdictions comply with CORSIA offsetting requirements, First Phase demand would reach 144 million EEUs. Airlines regulated in just four regions—the EU, US, UAE, and UK—could represent half of this demand.

Compliance reality check: Despite 129 countries voluntarily participating in CORSIA's First Phase, compliance readiness tells a different story:

  • Out of 36 countries responsible for 90% of international aviation emissions, fewer than 15 have indicated willingness to implement CORSIA through national regulation
  • The top two emitters, China and the USA, have not confirmed their intention to enforce the scheme
  • Most countries have not yet defined rules around CORSIA enforcement in their jurisdictions

Expert consensus: A survey of 40+ policy and market experts revealed that partial compliance with limited supply is considered the most likely outcome, with this scenario receiving 31% of expert votes. Combined with delayed compliance scenarios, over half of experts expect supply constraints to significantly impact CORSIA implementation.

The authorization bottleneck

The most critical constraint isn't project availability—it's host country authorizations. Under Article 6 of the Paris Agreement, countries must authorize carbon credit exports and implement corresponding adjustments against their Nationally Determined Contributions (NDCs).

Current Status: Only Guyana has successfully completed this process for CORSIA-eligible credits. Most other potential host countries lack the institutional frameworks, technical capacity, or political willingness to authorize credit exports at scale.

Expert Assessment: When asked to rank six key uncertainties facing CORSIA, 59% of experts voted "volume of credits with authorizations and corresponding adjustments" as either the most or second-most important concern—far exceeding worries about credit integrity, enforcement, or EU endorsement.

Strategic tips for airlines to prepare for variable CORSIA supply

1. Assess your compliance exposure

Airlines should immediately evaluate their specific offsetting requirements under different compliance scenarios. Even carriers in jurisdictions without clear enforcement may face competitive pressure to demonstrate CORSIA compliance voluntarily.

Key questions:

  • What are your projected excess emissions for 2024-2026?
  • How does your regulatory jurisdiction plan to enforce CORSIA?
  • What reputational risks exist from non-compliance even without legal requirements?

2. Monitor supply development actively

Given supply constraints, airlines should track host country authorization progress closely. Countries developing Article 6 frameworks directly impact credit availability from projects in their territories.

Priority monitoring:

  • Track the 16 countries showing moderate Article 6 readiness
  • Monitor JREDD+ program developments (particularly ART TREES and Verra programs)
  • Watch for PACM credit program launches, which could provide significant supply

3. Prepare for multiple scenarios

Airlines should develop contingency plans for different supply-demand outcomes:

  • Full compliance scenario: Secure 144 million EEUs collectively across industry
  • Partial compliance scenario: Plan for 74 million EEUs with regional enforcement focus
  • Delayed compliance scenario: Prepare for potential deadline extension to January 2030

CORSIA compliance approaches

With CORSIA supply development requiring 12-24 months for authorization processes and credit issuance, the window for addressing supply-demand imbalances is rapidly closing. Airlines that begin compliance planning now position themselves to navigate whatever market conditions emerge. Those who wait risk facing acute supply shortages and premium pricing as the deadline approaches.

The question isn't just whether airlines will be ready for CORSIA compliance—it's whether the entire market infrastructure will exist to enable compliance at scale.

Get the Complete CORSIA Market Analysis

This supply-demand challenge is a key focus as part of Sylvera's industry-first CORSIA First Phase Scenario Modeling report, based on consultations with 40+ industry experts and detailed market modeling across six implementation scenarios.

Download the full report for complete supply projections, country-by-country readiness assessments, detailed compliance scenarios, and strategic recommendations for navigating CORSIA market development.


Helping airlines navigate CORSIA complexity

With deep expertise in both carbon markets and policy, Sylvera provides the critical intelligence and tools needed to succeed in the evolving CORSIA landscape.

Strategic CORSIA compliance & market intelligence

Our policy experts help airlines, investors, and carbon market participants develop robust CORSIA compliance strategies by providing realistic assessments of market scenarios and regulatory developments. We help you navigate uncertainty and position for action before prices rise, ensuring your strategies remain resilient across multiple scenarios.

End-to-end support

From initial discovery through rigorous due diligence to ongoing monitoring, Sylvera supports your complete journey with CORSIA-eligible credits. Our trusted ratings provide deep project-level analysis to assess true quality and risk. With limited supply and intensifying demand for CORSIA-eligible credits, we help you identify high-quality opportunities in this nascent market.

Data-driven decision making

Having reliable data and insights is crucial for informed decision-making. Sylvera's Market Data provides real-time market intelligence, and our in-house scenario modeling helps you take low-risk climate action.

If you need expert guidance in navigating CORSIA, our team is ready to help. Get a free Sylvera demo here.

Frequently asked questions about CORSIA Phase 1 supply and demand

How much CORSIA carbon credit supply is currently available?

Only 15.84 million CORSIA-eligible credits are currently available, all from Guyana's JREDD+ program. While 4,000+ projects could technically supply credits, only ~1,500 are in countries ready for Article 6 authorizations. Total supply could range from 136-274 million EEUs by 2027.

What is the demand for CORSIA carbon credits?

CORSIA First Phase demand is estimated at 74-144 million EEUs, depending on compliance levels. Full compliance would require 144 million EEUs, while partial compliance (major jurisdictions only) would need approximately 74 million EEUs.

Will airlines comply with CORSIA requirements?

Compliance remains uncertain. While 129 countries participate in CORSIA Phase 1, fewer than 15 out of 36 countries responsible for 90% of aviation emissions have indicated willingness to enforce CORSIA. Expert consensus suggests partial compliance is most likely.

What's the biggest challenge for CORSIA compliance?

Host country authorizations represent the primary bottleneck. Countries must authorize carbon credit exports under Article 6 of the Paris Agreement, but most lack the necessary institutional frameworks. Only 16 countries show moderate readiness for authorizations.

What happens if there aren't enough CORSIA credits available?

If supply falls short of demand, airlines may face compliance penalties in enforcing jurisdictions, the compliance deadline could be delayed, or CORSIA could face partial implementation. Price spikes and supply shortages would likely occur as the deadline approaches.

About the author

This article features expertise and contributions from many specialists in their respective fields employed across our organization.

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