CORSIA Eligible Emissions Units 2026–2028: The Credit Supply Gap, Price Risk and Procurement Decisions Before January 2028
By Green Fuel Journal Research & Intelligence Team
Last reviewed: October 2026 · Next review trigger: publication of the 2025 Sector Growth Factor, due by 31 October 2026
Published 9 October 2026 · Data as of 9 October 2026, under the ISSN 2979-3777
Written for energy investors, airline procurement teams and carbon-credit developers.
THIS REPORT IS IN 2 PARTS
Legal disclaimer
This report is research and analysis for information only. It is not investment, legal, tax or financial advice, and it is not an offer to buy or sell any security or carbon credit. Carbon-credit markets carry risks of loss, including regulatory, delivery and counterparty risk. Readers should take independent professional advice before acting. Green Fuel Journal and its authors accept no liability for decisions made on the basis of this report. Full terms are at greenfueljournal.com/disclaimers.
Executive Summary
Phase 1 of CORSIA has about 36.6–41 million eligible units issued and labelled (OPIS, 2 July 2026; EDF, 27 July 2026), against demand estimates of 100–150 million tonnes (the ICAO range quoted by EDF) to 200–250 million units (IATA, 18 September 2026). Government paperwork, not credit production, is the bottleneck: Sylvera counts about 300 million issued units that could qualify, yet only about 38 million have cleared every gate (16 June 2026). Prices have fallen despite the shortage, with OPIS at USD 15.75 on 1 July 2026 and an Argus low of USD 9.30 in early July, against USD 21.70 at IATA's first Guyana auction (announced 22 January 2025).
The publishers that state a gap put it at about 125 million units (Sylvera, 16 June 2026) and about 150 million units (IATA). Their definitions differ, so the figures do not reconcile, but all of them show eligible supply far below first-phase demand. IATA counts about 72 million units covered by 42 host-country Letters of Authorisation (August 2026 data), only 5 countries had reported corresponding adjustments by June 2026, and Kenya's refusal of one developer's authorisation removed about 13 million tCO2e of expected supply. Airlines must cancel units by 31 January 2028, and no source reviewed shows an ICAO penalty for missing that date: enforcement sits with each State, and many have not legislated.
Entry timing is therefore the investor's central risk. Sylvera models USD 15–53 per unit by January 2028 (single source), and two decisions could move the market first: the European Commission proposal of 17 July 2026, which is not yet law, and the ICAO Council's October–November 2026 session. The test this report applies is deliverable supply, not headline supply: the units that can clear every gate and be cancelled before 31 January 2028.
1. Executive Intelligence Synthesis
DIRECT ANSWER
About 36.6–41 million CORSIA-eligible units are issued and labelled as of 9 October 2026, against demand estimates of 100–150 million tonnes (ICAO, via EDF) to 200–250 million units (IATA); that shortfall is the CORSIA supply gap. Sylvera states a gap of about 125 million units and IATA about 150 million, but the definitions differ, so the figures do not reconcile. On every published basis, eligible supply sits far below first-phase demand.
The gap is a deliverability problem. Five signals follow, each with the check it implies.
Signal 1: The gate, not production, limits supply
FINDING: Sylvera counts about 300 million issued units that could qualify for CORSIA, but only about 38 million have cleared every authorisation gate (16 June 2026).
SO WHAT: Headline issuance overstates what an investor can buy, because value sits with units that carry authorisation and adjustment evidence.
NOW WHAT: Ask every seller which gates each unit has cleared before comparing prices.
Together they have made available a total of 38 million EEUs. That's far from what's needed,"
said Willie Walsh, Director General of IATA, in his speech to the IATA 82nd AGM on 7 June 2026.
Signal 2: The gap has no agreed size
FINDING: Published gaps run from about 125 million units (Sylvera, 16 June 2026) to about 150 million (IATA, 18 September 2026) and about 175 million (an IATA slide in an ICAO deck, 9 June 2026), each on a different demand and supply base.
SO WHAT: A seller who quotes "the gap" without a definition gives a buyer nothing to compare.
NOW WHAT: Require every seller and analyst to state the supply definition and the demand base in writing.
Chart 2 data: Phase 1 demand estimates (ICAO via EDF 100–150 in tonnes; Sylvera 163.1 and 197.9; IATA 200–250) against supply measures (36.6–41 labelled; 38 cleared, Sylvera; 72 LoA-covered, IATA; 104 "likely", Sylvera; 154 aggregator figure, Carbon Pulse). Demand and supply use different definitions and the ICAO figure is in tonnes. Sources: EDF, 27 July 2026; Sylvera, 16 June 2026; IATA, 18 September 2026; OPIS, 2 July 2026; Carbon Pulse, 7 May 2026.
Signal 3: Prices sit below earlier forecasts
FINDING: OPIS assessed Phase 1 units at USD 15.75 on 1 July 2026, Argus recorded a low of USD 9.30 in early July, and IATA's first Guyana auction cleared at USD 21.70 (announced 22 January 2025).
SO WHAT: Prices fell while the shortage was widely published, which suggests the market is pricing delivery doubt and weak enforcement as well as scarcity (analyst judgement).
NOW WHAT: Compare any quote with the assessor, date and instrument before treating it as a benchmark.
Ben Rattenbury, Vice President Policy at Sylvera, wrote on 3 June 2026:
"The strangest thing about this market is that everyone is behaving rationally and the outcome is still irrational."
Signal 4: Enforcement rests with States
FINDING: HFW (modified 16 June 2026) and Roland Berger (modified 27 June 2026) both state that CORSIA itself imposes no sanction for failing to cancel units, and no ICAO sanction appears in any source reviewed.
SO WHAT: Airline urgency may arrive late and all at once, because penalties depend on national law that many States have not passed (analyst judgement).
NOW WHAT: Check the home-State penalty rules of each airline counterparty before assuming it must buy on a fixed timetable.
Signal 5: Two decisions could reset the market
FINDING: The European Commission proposal of 17 July 2026 is not law, and the ICAO Council holds its 239th session in October–November 2026.
SO WHAT: Either outcome can change which units are eligible and how much demand reaches the CORSIA market.
NOW WHAT: Track both decisions before committing capital to units whose value depends on them.
2. Macro Context & Strategic Drivers
DIRECT ANSWER
CORSIA works by requiring airlines to offset international emissions above 85% of 2019 levels. The first phase covers 2024–2026 emissions, with 130 participating States in 2026 (ICAO, June 2026) and 134 in 2027 (ICAO, July 2026). Operators cancel eligible units by 31 January 2028 in most sources. The ICAO Council approves crediting programmes on the advice of its Technical Advisory Body (TAB). Data as of 9 October 2026.
2.1 How the first phase works and when it ends
FINDING: Operators must cancel eligible units by 31 January 2028, States obtain the 2025 Sector Growth Factor (SGF) by 31 October 2026, and States inform operators of their 2025 requirements by 30 November 2026 (ICAO newsletters, June and July 2026).
SO WHAT: These dates set when airline buying pressure can start, and so when delivery risk turns into default risk.
NOW WHAT: Build a purchase calendar around 30 November 2026 and the cancellation window, and confirm the window wording with the relevant State.
The deadline wording conflicts. An IATA release of 6 June 2026 says "December 2027", an ICAO deck of 9 June 2026 gives a window of 1 December 2027 to 31 January 2028, and HFW (article first published July 2024) says that where a State's total final offsetting requirement exceeds 3,000 tCO2, operators must cancel by 31 January 2028 or 60 days after the State informs them of the final requirement, whichever is later. Reporting on cancelled units begins in April 2028. Participating States rose from 88 in 2021 to 130 in 2026, yet the European Commission's assessment, relayed by EDF, is that they cover under 70% of international aviation emissions. Airlines offset only emissions above 85% of 2019 levels, which Sylvera says covers roughly 60% of global aviation emissions.
2.2 Demand estimates and why they differ
FINDING: Phase 1 demand estimates run from 100–150 million tonnes (ICAO via EDF, 27 July 2026) to 197.9 million units (Sylvera, 16 June 2026) and 200–250 million units (IATA, 18 September 2026).
SO WHAT: The spread is wide enough to turn a small shortfall into a very large one, so the chosen estimate drives the investment case.
NOW WHAT: Test any thesis against the lowest and the highest demand estimate, not the one a seller prefers.
The estimates differ on units versus tonnes and on scope. Sylvera's 163.1 million base case excludes intra-EEA flights and States below 0.5% of global revenue tonne-kilometres; its 197.9 million case assumes full implementation. IATA's own range moved from 170–236 million in June to more than 200 million in September.
Table T2. Phase 1 demand estimates (million; units unless stated)
Publisher | Estimate | Date | Definition and note |
ICAO, quoted by EDF | 100–150 (tCO2) | 27 Jul 2026 | Tonnes; ICAO primary not retrieved; single source |
Sylvera, partial implementation | 163.1 | 16 Jun 2026 | Excludes intra-EEA flights and small States; other Sylvera figures: 174.5 (GreenAir, 9 Jun) and 177 (African Business, 2 Jun) |
Sylvera, full implementation | 197.9 | 16 Jun 2026 | Scenario; single source |
IATA, June | 170–236 (central 213) | 7 and 9 Jun 2026 | Walsh speech and ICAO deck slide |
IATA, September | 200–250 | 18 Sep 2026 | IATA Economics chart |
Abatable | 200–220 | 12 Mar 2026 | Reported by GreenAir, which has ceased publication |
Climate Impact Partners | 150–200 | 31 Mar 2026 | Specialist publisher |
Roland Berger | about 180 | Sep 2025 | Older than 12 months |
Sources: EDF, Sylvera, IATA, GreenAir News, Climate Impact Partners, Roland Berger (full URLs in Section 12).
2.3 Regional regulatory map
FINDING: Only Canada has a binding offsetting regime verified by this report, while the US runs a voluntary monitoring programme and the EU and UK regimes are mid-change.
SO WHAT: Demand strength differs by jurisdiction, so a buyer's home State matters as much as the buyer's balance sheet.
NOW WHAT: Weight counterparties by the enforceability of their home-State rules, and treat unverified regions as unknown, not neutral.
In North America, the FAA's CORSIA monitoring programme is "currently voluntary" and no US offsetting rule was found; Canada applies Part X of the Canadian Aviation Regulations. In the EU, Directive (EU) 2023/958 applies CORSIA to EEA operators on extra-EEA flights, and the Commission proposal of 17 July 2026 would extend ETS coverage to some extra-EEA departures from 2029 while keeping CORSIA in EU law to 2035. In the UK, the Department for Transport consulted from December 2024 to February 2025 on offsetting rules and no made order was found.
China's status is not verified. India is covered in Section 3.
In Southeast Asia, Thailand, Laos and Cambodia lead on authorisation while Vietnam has issued no Letter of Authorisation.
In Latin America, Guyana is the only verified labelled supplier and Brazil's status is contested.
Sub-Saharan Africa supplies most emerging projects. Evidence for Australia and the Gulf is thin (Section 11.1).
Readers tracking fuel-side compliance in the same jurisdictions can compare this credit market with the cost of the physical alternative in the ReFuelEU Aviation 2026–2030 analysis and the UK SAF Mandate 2026–2030 fuel supplier playbook.
Table T1. Regional verification status, as of 9 October 2026
Region | Verified | Not verified |
Global (ICAO) | 2024–2026 scope; 130 States in 2026 and 134 in 2027 (June and July 2026 newsletters); ten approved programmes (June 2026 newsletter) | Per-programme volumes; ICAO source for the 100–150 MtCO2 requirement |
North America | US voluntary monitoring (FAA, 2023); Canada Part X binding | Any 2025–26 US offsetting rule; Air Canada or WestJet purchases |
EU / UK | Directive 2023/958; 17 Jul 2026 proposal (via law-firm summaries); UK Order SI 2021/534 | Proposal text; UK made offsetting order; named airline purchases |
China | ICAO Oct 2025 newsletter lists CCER for 2016–2020 pilot units only | Any 2025–26 status, Chinese primary document, LoA or exposure |
India | State Action Plan (2026): offsetting from 2027 | Primary Indian government documents; LoA; airline exposure |
Southeast Asia | OPIS data of 2 Jul 2026; Laos and Cambodia LoAs; Vietnam none | National legal instruments; the Abatable report itself |
Latin America | Guyana labelled supply; Brazil monitoring rules | Any Brazilian LoA; Colombia and Costa Rica evidence |
Sub-Saharan Africa | 80 or 67 published LoAs (Sylvera); Rwanda, Madagascar, Nigeria supply | Zambia, Ghana volumes; AfDB and IRENA material |
Australia and Gulf | Australia participates; Emirates exposure estimate (MSCI via AGBI) | Any implementing instrument, LoA or Gulf airline purchase |
Sources: ICAO, FAA, European Commission, GOV.UK, Sylvera, OPIS, AGBI (Section 12).
Table T13. Regulatory instruments by region
Region | Instrument | Date | Material difference |
Global | ICAO Council decision C-DEC 236/3 | 31 Oct 2025 | Re-assessed ACR, Architecture for REDD+ Transactions (ART TREES), Gold Standard and Verified Carbon Standard (Verra); reaffirmed ICAO outreach and national coordination to expedite attestations |
US | FAA CORSIA monitoring programme FAQ | 24 Jul 2023 | Voluntary; no statute cited; older than 12 months |
Canada | Canadian Aviation Regulations Part X | Consolidated to 17 Feb 2025 | Binding; fines and route bar in 2020 proposed text (final registration not verified) |
EU | Directive (EU) 2023/958 | In force 5 Jun 2023 | Credits only from countries in both the Paris Agreement and CORSIA |
UK | Order SI 2021/534; draft 2025 amendment order | 2021; draft Feb 2025 | GBP 100 per unit penalty proposed; no made offsetting order located |
India | State Action Plan, ICAO APAC DGCA/61 | 2026 | Offsetting from 2027; not participating voluntarily |
Brazil | ANAC Resolution 743/2024; Law 15.042/2024 | 2024 | Monitoring rules exist; authorisation framework disputed |
Rwanda | REMA Letter of Authorisation (Likano) | 6 Aug 2026 (report date) | Up to 1.77 million tCO2e; renewable once |
Sources: ICAO, FAA, Transport Canada, Canada Gazette, EUR-Lex, GOV.UK, Carbon Herald (Section 12).
2.4 Where CORSIA sits against other carbon costs
EU Allowances traded near EUR 82.40 (USD 91.87) at 07:50 GMT on 5 October 2026, and UK Allowances traded at GBP 62 on 29 September 2026 (S&P Global; both single source). Against the OPIS Phase 1 assessment of USD 15.75, CORSIA units were a fraction of both. The comparison is not like-for-like, because the dates differ, no exchange rate is given for the UK price, and the instruments carry different legal obligations. Investors should treat the gap as context, not as a forecast of convergence. The Commission proposal ties its no-double-charging deduction to the ratio of the average EUA price to the average eligible CORSIA price (HSF Kramer), so both prices would enter the same deduction formula if the proposal passes.
3. India-Specific Analysis
DIRECT ANSWER
India, while not participating voluntarily in CORSIA, will begin offsetting from 2027, according to its own State Action Plan to ICAO (2026). The plan applies monitoring to operators emitting more than 10,000 tCO2 a year. It reports aviation CO2 emissions of about 20,746 kt in 2024, up from about 11,950 kt in 2013, without limiting those figures to international flights. No Indian Letter of Authorisation had been found as of 9 October 2026.
3.1 Status and timeline
FINDING: India's State Action Plan, submitted to the ICAO Asia-Pacific DGCA/61 meeting in 2026, says that India, "while not participating voluntarily, will begin offsetting from 2027".
SO WHAT: On this wording, Indian operators sit outside the 2024–2026 cancellation obligation and enter the buyer base in the second phase (analyst judgement).
NOW WHAT: Model Indian airlines as Phase 2 buyers, and ask counterparties for the implementing rules before assigning them any Phase 1 demand.
The document does not show its submission date, so this report dates it to 2026. It is India's own statement, not an entry on ICAO's list of participating States, which this report did not retrieve. GreenAir reported on 12 March 2026 that Brazil, China and India had yet to confirm their participation, so India's own paper is the strongest status evidence this report found (analyst judgement).
3.2 Exposure at national level
FINDING: India's State Action Plan (2026) reports aviation CO2 emissions rising from about 11,950 kt in 2013 to about 20,746 kt in 2024 and applies monitoring to operators above 10,000 tCO2 a year; the paper does not limit the emissions figures to international flights.
SO WHAT: The emissions base is large and growing, but the offsetting requirement depends on a sector growth factor that no source reviewed provides for India.
NOW WHAT: Wait for the published SGF and the State's operator allocation before converting this base into a credit or rupee figure.
This report does not convert the emissions figures into units or costs. Any such number would rest on an assumption the sources do not support, and no IndiGo or Air India exposure figure was found.
3.3 Supply-side signals
FINDING: A Ministry of Environment, Forest and Climate Change (MoEFCC) memo of 25 September 2025 cut India's Article 6 positive list from 14 to 13 categories and removed clean cookstoves from export-eligible activities (Carbon Pulse; single source, with only the opening lines visible behind a paywall).
SO WHAT: Cookstoves are the dominant project type in CORSIA supply (OPIS and Abatable), so India may have closed a large potential source, which is an analyst judgement because the memo text was not read.
NOW WHAT: Do not underwrite Indian cookstove credits for CORSIA until the memo and any Letter of Authorisation rules are confirmed in primary documents.
IETA published recommendations on strengthening India's Article 6 framework on 27 May 2026. In an organisational statement, IETA said "a clear, predictable, and market-aligned framework will be critical to unlocking India's significant potential". Cookstoves also underpin much of the tagged supply from Rwanda and Nigeria (Section 5), which shows the scale of what the memo may close. For the wider question of where India's low-carbon fuel exports are verified, see the Green Ammonia Exports 2027 analysis on India and China.
3.4 What is not yet known
FINDING: No Indian Letter of Authorisation, no Article 6.2 bilateral agreement, no CORSIA-eligible Indian volume and no primary document from India's civil aviation, power or energy-efficiency authorities was found.
SO WHAT: The absence is itself a finding for developers: India is not a supply source today, and its demand timetable is set by rules not yet seen.
NOW WHAT: Track the three developments listed below, and treat any Indian supply claim as unverified until a Letter of Authorisation appears.
Table: India, verified versus open, as of 9 October 2026
Item | Status | Source or gap |
Offsetting start | Verified (India's own statement) | State Action Plan, 2026 |
Monitoring threshold | Verified | 10,000 tCO2 a year per operator |
Emissions base | Verified | 11,950 kt (2013); 20,746 kt (2024); not limited to international flights in the paper |
Article 6 positive list | Partly verified | 25 Sep 2025 memo; lede only |
Letter of Authorisation | Not found | No Indian LoA located |
Airline exposure | Not found | No IndiGo or Air India figure |
Government primary documents | Not found | No PIB, BEE or civil aviation ministry document retrieved |
Sources: India State Action Plan (ICAO APAC DGCA/61); Carbon Pulse, 25 Sep 2025; IETA, 27 May 2026.
For Indian developers, the Rwandan authorisation in Section 5.3 shows what a usable LoA looks like: a named volume, named vintages and a renewal limit. Three developments to watch: any Indian government notification that links aviation to a domestic or Article 6 carbon market (none was found), the first Indian Letter of Authorisation, and any allocation of offsetting requirements to Indian operators by the civil aviation ministry.
4. Operational & Technical Deep-Dive
DIRECT ANSWER
A carbon credit is CORSIA-eligible when it clears five tests: it comes from an ICAO-approved programme, falls in an eligible vintage, carries a host-country Letter of Authorisation, is protected against double claiming by a corresponding adjustment or an approved insurance product, and is cancelled within the compliance window. As of 9 October 2026, ICAO lists ten approved programmes, and Sylvera found only 5 countries reporting adjustments by June 2026.
4.1 The eligibility stack
FINDING: Each unit must pass an authorisation gate controlled by the host government before it counts, and host governments, not credit producers, control the two slowest gates.
SO WHAT: A project with strong credit quality but no Letter of Authorisation has little value for CORSIA, as KOKO Networks shows in Section 5.
NOW WHAT: Check gates in order of who controls them: government gates first, programme and registry gates second.
The first gate is the approved programme. The second is the vintage window. The third is the Letter of Authorisation (LoA), a written attestation from the host country's national focal point, or its designee, that covers the units used under CORSIA and describes the steps taken to stop the same mitigation counting toward the host's own targets (HFW). The fourth is protection against double claiming, through a corresponding adjustment (CA), an adjustment to the host's emissions balance when it reports, or, in the interim, an approved insurance policy. The fifth is issuance and labelling in the registry, and the last is cancellation by the operator inside the window.
1 Approved programme | 2 Eligible vintage | 3 Host-country LoA | 4 Adjustment or approved insurance | 5 Issuance and labelling | 6 Cancellation in window |
Visual V5: the eligibility stack, in the order a diligence review should test it.
Table T3. Eligibility gates
Gate | What it proves | Who controls it | Typical failure | Evidence |
Approved programme | Council approved the programme on TAB advice | ICAO Council | Programme absent from list; counts of 7, 8 and 10 conflict | ICAO June 2026 newsletter |
Eligible vintage | Units fall inside the programme's window | ICAO and programme | Vintage outside window | HFW: ACR and ART 1 Jan 2021–31 Dec 2026 |
Letter of Authorisation | Host authorises use for CORSIA | Host government | Refusal (Kenya); none issued (Vietnam) | IATA: 42 LoAs; Sylvera: 67 (June) and 80 (May) |
Adjustment or insurance | Host will not claim the same unit | Host or insurer | Few adjustments reported; insurance pending | Sylvera: 5 countries; DelAgua about 640,000 units pending (21 Jul 2026) |
Issuance and labelling | Unit exists and carries the CORSIA label | Registry and programme | Units expected but not issued | OPIS; EDF |
Cancellation in window | Operator retires the unit on time | Operator and State | Late State notice; wording conflict | ICAO deck; HFW |
Sources: ICAO, HFW, IATA, Sylvera, OPIS, EDF, BNN Bloomberg (Section 12).
4.2 Approved programmes and vintages
FINDING: ICAO's June 2026 newsletter lists ten approved programmes, but an IATA deck (16 June 2026) lists seven and ICAO's 26 November 2025 news item lists eight for Phase 1.
SO WHAT: The count is unreconciled, so a seller's "approved" claim needs checking against the current Council decision, not a summary.
NOW WHAT: Ask for the programme's name and approval document, and the vintage rule it applies.
Table T4. Programme counts and conflicts
Source | Date | Count | Note |
ICAO CORSIA Newsletter | Jun 2026 | 10 | ACR, ART TREES, BioCarbon Fund (Sustainable Forest Landscapes), Climate Action Reserve, Forest Carbon Partnership Facility, Global Carbon Council, Gold Standard, Isometric, Premium Thailand VER, Verra |
ICAO Council decision C-DEC 236/3 | 31 Oct 2025 | Adds Cercarbono | Cercarbono is named in the decision but not in the newsletter list |
IATA deck (hosted by ICAO) | 16 Jun 2026 | 7 | Supply data only for Verra, Gold Standard and ART TREES |
ICAO news item | 26 Nov 2025 | 8 (Phase 1), 4 (Phase 2) | Earlier list |
Sources: ICAO newsletters and Council decision; IATA deck (Section 12).
The two programmes added to reach ten were approved in "April 2026" (May newsletter) or "early 2026" (June newsletter). Vintage windows differ: HFW gives 1 January 2021 to 31 December 2026 for ACR and ART, and ICAO's October 2025 newsletter gives 1 January 2021 to 31 December 2029 for Premium Thailand VER. Per-programme issued volumes could not be retrieved from ICAO.
4.3 Three quantities: potential, deadline-deliverable and investable supply
FINDING: Sylvera's pipeline shows about 640 million potentially eligible units, about 300 million issued and potentially eligible, about 38 million cleared, and 48 million confirmed or 104 million likely by the deadline (16 June 2026).
SO WHAT: These numbers measure different things, so adding or comparing them without a shared definition produces false gaps and false comfort.
NOW WHAT: Place every supply figure you receive into one of the three categories below before using it.
Sylvera's own comparison shows the theoretical pool at 17 times current confirmed supply and nearly four times expected demand (3 June 2026), which is why headline pipeline numbers mislead. This report separates supply into three quantities. Potential supply is what could qualify in theory. Deliverable supply is what can clear every gate and be cancelled by the deadline. Investable supply is the part of deliverable supply that exists today, carries the label and can be bought with documented protections.
Table: Published supply figures mapped to the three quantities
Quantity | Published figures placed here | Source and date |
Potential | About 640 million potentially eligible; about 300 million issued and potentially eligible (13% actually eligible); 340 million expected future issuance | Sylvera, 16 Jun 2026 (single source) |
Deadline-deliverable | About 72 million units covered by 42 LoAs (IATA); 48 million confirmed and 104 million likely; 154 million "insured and authorised in time" (basis unstated, unclassified) | IATA, 18 Sep 2026; Sylvera, 16 Jun 2026; Carbon Pulse, 7 May 2026 |
Investable | 36.6 million fully authorised from 57 projects; about 41 million labelled; 7.8 million insurance-enabled (Sylvera) and over 10 million insured (Oka); the pools are not reconciled | OPIS, 2 Jul 2026; EDF, 27 Jul 2026; Sylvera; Fastmarkets, 9 Jul 2026 |
Sources: Sylvera, IATA, OPIS, EDF, Carbon Pulse, Fastmarkets (Section 12).
Methodology note.
Potential, deliverable and investable supply are definitions, not forecasts. Each published figure is assigned to the category that matches its stated basis; where a source does not state its basis, the figure is shown but left unclassified. The assignment is structured analyst judgement, not a statistical model.
The six-gate matrix below applies the same logic to five real pipelines. Each gate is marked Met, Not met or Not verified, and each row carries an evidence grade: A means a primary document was opened, B means a named specialist publisher with two independent sources, and C means a single source, a secondary summary or a headline only.
Table: Supply-readiness matrix (as of 9 October 2026)
Pipeline | Programme | Vintage | LoA | Adjustment or insurance | Issued and labelled | Protections disclosed | Grade |
Guyana (ART TREES) | Met | Met (2023 vintage) | Met | Not verified | Met (about 9.1 million, Feb 2026) | Not verified | B |
Rwanda, Base Carbon and DelAgua | Met (Verra) | Not verified | Not verified | Not met for about 640,000 units (21 Jul 2026) | Met (639,609 tagged, 28 Sep 2026) | Not verified | C |
Rwanda, Econetix and Likano | Met (Verra) | Not verified | Met (up to 1.77 million) | Not verified | Not verified | Not verified | C |
Kenya, KOKO Networks | Not verified | Not verified | Not met (refused) | Not met | Not verified | Not verified | B |
Vietnam (all projects) | Not verified | Not verified | Not met (none issued) | Not verified | Not verified (10.5 million issued) | Not verified | C |
Sources: Fastmarkets, 9 Feb 2026; Base Carbon, 28 Sep 2026; BNN Bloomberg, 21 Jul 2026; Carbon Herald, 6 Aug 2026; OPIS, 2 Jul 2026 (Section 12).
Methodology note.
Each pipeline is scored against six gates: approved programme, eligible vintage, host-country LoA, adjustment or approved insurance, issuance and labelling, and disclosed contract protections. Each gate is marked Met, Not met or Not verified. Evidence grades are A (primary document opened), B (named specialist publisher, two independent sources) and C (single source, secondary summary or headline only). No star ratings are used. The matrix is structured analyst judgement; it does not weight gates or produce a score.
4.4 Authorisation, adjustments and insurance in practice
FINDING: Gold Standard requires a deed of undertaking plus an approved policy where no adjustment exists, with MIGA political-risk insurance the only approved product identified, and Verra requires a CORSIA accounting representation plus a certificate from an approved product.
SO WHAT: Insurance bridges the gap only for units whose paperwork is complete, so the policy itself becomes part of the asset.
NOW WHAT: Ask for the LoA, the host's adjustment report or the insurance certificate, and the programme's liability position before signing.
"Credits must be transferred between these systems to avoid double-counting, which has become an important bottleneck,"
said Marie Owens Thomsen, Senior Vice President Sustainability and Chief Economist at IATA, in a press release on 6 June 2026. HFW adds that crediting programmes carry liability to the ICAO Council if a host fails to make the adjustment. From the 2026 TAB cycle, LoAs should include the compliance cycle, the timeline for applying and reporting adjustments, and the host's definition of "first transfer" (Fastmarkets, 12 March 2026), which Fastmarkets says "will likely add further restrictions to supply" in Phase 2.
5. Named Company Case Studies
DIRECT ANSWER
Japan Airlines, through Shell, retired 180,000 Gold Standard credits for CORSIA Phase 1 (announced 24 March 2026), and Singapore Airlines and Scoot retired 250,000 credits in two tranches by July 2026. On the supply side, Econetix holds a Rwandan authorisation for up to 1.77 million tCO2e, and Base Carbon had 1,959,812 credits tagged by 28 September 2026. Position date: 9 October 2026.
5.1 Japan Airlines, with Shell: the first large retirement and the quality question
FINDING: Shell retired 180,000 Gold Standard credits for CORSIA Phase 1 on behalf of Japan Airlines, announced 24 March 2026.
SO WHAT: It is the first large-scale retirement of Gold Standard credits by a commercial airline in the sources, yet the airline says it cannot judge quality or price.
NOW WHAT: Treat early retirements as evidence of intent, not as price discovery.
The credits came from a biomass project in Malawi (130,000, project GS11677) and a cooking project in Tanzania (50,000, project GS11732).
Hideki Ochiai, Vice President sustainability and ESG promotion at Japan Airlines, said at the IETA Asia Climate Summit in Hong Kong, as reported by Fastmarkets on 9 July 2026:
"We don't have any sense to identify whether this is quality and what the price is."
The Gold Standard release says the credits were retired to meet obligations under Phase 1 and that further retirements are expected throughout 2026 and 2027, while Fastmarkets says JAL has already begun buying toward a January 2028 surrender.
5.2 Singapore Airlines and Scoot: buying in tranches
FINDING: Singapore Airlines and Scoot retired 150,000 credits on 14 April 2026 and a second tranche of 100,000 on 6–7 July 2026, taking the recent total to 250,000 tonnes.
SO WHAT: Buyers are purchasing in small steps, against a requirement the sources measure in the tens or hundreds of millions of units.
NOW WHAT: Watch retirement counts, not announcements: Sylvera put all retirements at about 400,000 tonnes by June 2026, about 0.2% of demand.
The first tranche came from cookstove and water-filtration credits on the Verra registry (QCIntel). Carbon Pulse's same-day story calls the buyer "an Asian airline"; the name Singapore Airlines comes from the QCIntel headline alone.
5.3 Econetix and Likano: authorisation as the product
FINDING: Rwanda's Environment Management Authority issued Econetix GmbH a Letter of Authorisation for up to 1.77 million tCO2e from the Likano improved cookstove project, renewable once (reported 6 August 2026).
SO WHAT: The LoA, not the credit, is the scarce asset, and its vintage window decides how much of the volume serves Phase 1.
NOW WHAT: Ask which vintages fall inside the Phase 1 window and who applies the adjustment.
Eligible vintages run from 1 September 2022 to 31 August 2027, and most volume is expected in Phase 1, with Rwanda to apply corresponding adjustments (Carbon Herald). The vintage rule for this programme was not retrieved, so the share of the volume that falls inside Phase 1 cannot be confirmed.
Chief executive Jakob Zenz called securing the LoA
"one of the hardest steps on that path"
(Carbon Herald, 6 August 2026). Econetix is a member of IATA's Supporting Alliance.
5.4 Base Carbon and DelAgua: tagged is not the same as protected
FINDING: Base Carbon announced on 28 September 2026 that 639,609 credits from its Rwanda cookstoves project, run with project partner DelAgua, were newly tagged as CORSIA-eligible, taking cumulative tagged credits to 1,959,812.
SO WHAT: Tagging proves labelling, not protection: on 21 July 2026 about 640,000 credits from the project still needed insurance.
NOW WHAT: Ask whether tagged units also carry an adjustment or an approved policy.
The release does not state the vintage or the LoA country, and about 2.6 million more credits are expected at roughly six-month intervals. The 21 July release put total CORSIA-eligible holdings near 1.1 million, and the two releases do not reconcile that with the 1,959,812 figure. These are company-reported numbers. Fastmarkets (9 February 2026) reported that Base Carbon had sold around 300,000 tCO2e of Phase 1-eligible credits in recent weeks.
5.5 Guyana: the largest labelled supplier and its concentration
FINDING: Guyana's ART TREES programme issued about 9.1 million vintage-2023 credits labelled Phase 1-eligible in February 2026, and a ministry official said sales had reached over 19 airlines in 18 months (Guyana Chronicle, 19 March 2026).
SO WHAT: One sovereign programme carries a large share of labelled supply, so its pricing and delivery decisions move the whole market.
NOW WHAT: Size any exposure with Guyana-specific concentration in mind.
IATA's first procurement event (28 October–29 November 2024) saw 32 airlines take part and 11 buy at USD 21.70 per tonne (the release shows the price as "$21.70"), and the release quotes Pegasus's chief financial officer but does not list the buyers. Pradeepa Bholanath, Senior Director for Climate and REDD+ at Guyana's Ministry of Natural Resources, said in a television interview reported by the Guyana Chronicle on 19 March 2026 that sales had come "…at prices that have gone beyond the levels that we have sold our carbon credits for…". Sylvera puts Guyana as the largest authorised tranche at 24.9 Mt. The volumes and prices of the 19-airline sales were not stated.
5.6 KOKO Networks: the failure case
FINDING: Kenya refused KOKO Networks a Letter of Authorisation, removing about 13 million tCO2e of expected Phase 1 supply, 5–10% of potential supply (Fastmarkets Analytics, 9 February 2026).
SO WHAT: Authorisation can be refused after a developer has built the project, and one trader estimated credits without it at only USD 3–4 (Fastmarkets).
NOW WHAT: Make LoA delivery a condition of payment, not a milestone after it.
Two sources confirm the refusal (GreenAir, 12 March 2026; African Business, 2 June 2026). They differ on the company outcome: Fastmarkets says KOKO's Kenyan entities went into administration, and African Business says the company went bankrupt in February 2026.
5.7 What the cases show
Across the six cases, the scarce item is government authorisation, not credit production or buyer interest.
Table T5. Case comparison
Case | Region | Key verified figure | Investor lesson | Grade |
Japan Airlines with Shell | Japan | 180,000 credits, 24 Mar 2026 | Buyer cannot judge quality or price | B |
Singapore Airlines and Scoot | Singapore | 150,000 + 100,000 = 250,000 | Tranche buying; attribution partly inferred | C |
Econetix and Likano | Rwanda | LoA up to 1.77 million tCO2e | Authorisation is the product | C |
Base Carbon and DelAgua | Rwanda | 1,959,812 cumulative, 28 Sep 2026 | Tagging is not protection | C |
Guyana (ART TREES) | Latin America | About 9.1 million, Feb 2026 | Concentration risk | B |
KOKO Networks | Kenya | About 13 million tCO2e lost | LoA can be refused | B |
Sources: Gold Standard; Fastmarkets; Carbon Pulse; QCIntel; Carbon Herald; GlobeNewswire; Guyana Chronicle (Section 12).
Methodology note. Evidence grades follow the definitions in Section 4.3: A is a primary document opened, B is a named specialist publisher with two independent sources, and C is a single source, secondary summary or headline only. The grades are structured analyst judgement and do not weight or score the cases.
Smaller buyers are also moving, such as South Korea's Trinity Airways, which signed a memorandum of understanding on 21 September 2026 stating plans to procure 20,000 tonnes (Carbon Herald). No US, UK or EU airline retirement or large offtake could be verified.
6. Friction, Risk & Systemic Bottlenecks
DIRECT ANSWER
The main risks to CORSIA credit supply before January 2028 are host-country authorisation delays, few reported corresponding adjustments (5 countries by June 2026), dependence on insurance where adjustments are missing, supplier concentration in Guyana and Rwanda, and enforcement left to individual States. No ICAO sanction for missing the 31 January 2028 deadline appears in any source reviewed, as of 9 October 2026.
6.1 Authorisation and adjustment throughput
FINDING: Only 10 countries had made units available by 7 June 2026, and sources count 42 (IATA), 67 (Sylvera, June) and 80 (Sylvera, May) published LoAs on different definitions.
SO WHAT: The binding constraint is government throughput, a reading the evidence supports but no source states directly (analyst judgement).
NOW WHAT: Track country-level LoA and adjustment filings as leading indicators of supply.
"To date only 10 countries have made EEUs available,"
said Willie Walsh on 7 June 2026.
The ten were Guyana, six African countries, Laos, Cambodia and Uzbekistan. Sylvera counts 5 countries reporting adjustments by June 2026, while EDF cites 14 countries with authorisation and tracking arrangements and 86 more considering them. Vietnam has 10.5 million units issued and has issued no LoA, and Kenya refused KOKO. The TAB accepted that hosts could alter adjustments in final reports due in 2032, case by case (Fastmarkets).
6.2 The enforcement vacuum
FINDING: HFW says sanctions are "left to each individual State" and many have "not yet fully implemented" the rules; Roland Berger says CORSIA "has no legal authority to enforce compliance".
SO WHAT: What happens to a late State is untested, and Sylvera reports that enforcement signals vary significantly across jurisdictions.
NOW WHAT: Price in the possibility of delayed or partial buying until national penalties are legislated.
Climate Impact Partners (31 March 2026) agrees, and Sylvera says enforcement signals "vary significantly across jurisdictions". Argus wrote on 17 July 2026: "Lack of such affirmation by countries has kept potential airline demand for CP1-tagged credits at bay so far." The affirmation it refers to is the EU's commitment to keep CORSIA in law. Canada's proposed text carries fines up to CAD 25,000 per infraction for corporations and a bar on flying routes between subject States (2020 text, final registration not verified), while the US programme is voluntary. No source reports any proposal to extend the 31 January 2028 deadline or any ICAO treatment of carry-forward. Roland Berger warns that late buyers may pay USD 20–50 for "whatever is available" in 2027.
6.3 EU–ICAO conflict
FINDING: The Commission proposal of 17 July 2026 would keep CORSIA in EU law to 2035 but extend ETS coverage to some extra-EEA departures from 2029, and ICAO, IATA, Airlines for America and Emirates oppose it.
SO WHAT: The proposal drops extra Phase 1 quality criteria, which helps supply now, but leaves Phase 2 criteria open.
NOW WHAT: Follow the 2027 trilogue and the Phase 2 criteria rather than the July headline.
In an organisational statement reported on 20 July 2026, ICAO said the proposal "would undermine the only globally harmonized measure applying to CO2 emissions from international aviation".
"The EU is repeating a historic error,"
said Willie Walsh in an IATA statement on 17 July 2026.
Rosie Burton, environmental products trader at Marex, said in Argus reporting on 17 July 2026:
"We had anticipated a bifurcated market if the EU maintained additional criteria."
The sources also date the dropping of extra Phase 1 criteria differently: 15 June 2026 (committee minutes, per Fastmarkets), 14 July 2026 (Commission confirmation, per Sylvera), 15 July 2026 (minutes seen by Platts, per S&P Global) or 17 July 2026 (the proposal). S&P Global reported on 15 July 2026 that the Commission would introduce additional eligibility criteria for the second phase only, so Phase 2 criteria remain open. The sources disagree on the distance anchor (Frankfurt, Paris or the Union's geographic centre) and on the share of Phase 1 supply the earlier draft criteria would have excluded: 84% (Allied Offsets), about 90% (Argus) or about 93.5% (Sylvera, single source).
6.4 Concentration and single-point failure
FINDING: Guyana is the largest authorised tranche at 24.9 Mt, and Rwandan cookstoves are second at 2.8 Mt (Sylvera, 3 June 2026).
SO WHAT: Single-country decisions can move the market, an analyst judgement from the concentration data.
NOW WHAT: Spread exposure across host countries and project types.
Cookstoves are the dominant project type (OPIS and Abatable), which links the supply risk to host-country policy, as India's 2025 memo shows in Section 3. KOKO shows the same dependence in reverse: one refusal removed a project that Fastmarkets Analytics expected to supply 5–10% of potential volume.
6.5 Risk matrix
FINDING: Eight risks are rated below, and five of them carry a High rating for likelihood or impact on the evidence reviewed.
SO WHAT: Most High ratings sit with government-controlled gates, which a buyer cannot remove by negotiation alone.
NOW WHAT: Match each risk to the mitigation shown and require it in the contract.
Table T6. Risk matrix
Risk | Likelihood | Impact | Evidence grade | Mitigation |
Authorisation delays or refusal | High | High | B | Buy units that already hold an LoA |
Few adjustments reported (5 countries) | Medium | High | C | Require adjustment evidence or an approved policy |
Dependence on insurance | Medium | Medium | B | Inspect the policy and its conditions |
Supplier and country concentration | Medium | High | B | Diversify across hosts and project types |
National-only enforcement, late buying | Medium | High | B | Check home-State penalty rules |
EU–ICAO rule conflict | Medium | Medium | B | Track trilogue and Phase 2 criteria |
Price volatility | High | Medium | B | Stage purchases; date every quote |
Deadline wording ambiguity | Medium | Low | A | Confirm the window in writing with the State |
Sources: Sections 4 to 6 of this report and the sources cited there.
Methodology note. Likelihood and impact are rated Low, Medium or High by structured analyst judgement. The criteria are the number of independent sources reporting the risk, proximity to the January 2028 deadline, whether the risk is reversible, and its size relative to current labelled supply. Each rating shows its evidence grade as defined in Section 4.3.
7. Capital & Investment Implications
DIRECT ANSWER
CORSIA Phase 1 credits were assessed at USD 15.75 by OPIS on 1 July 2026, with an Argus low of USD 9.30 in early July, against USD 21.70 at IATA's first Guyana auction (announced 22 January 2025). Sylvera's model gives USD 15 to 53 per unit for January 2028 (single source). Price depends on authorisation status, and no October 2026 spot value was obtained.
Chart 1 data: IATA/Xpansiv 21.70 (announced 22 Jan 2025); Platts 21.85 (2 Jul 2025); Fastmarkets 18.30 (9 Feb 2026); OPIS 15.75 (1 Jul 2026); Argus low 9.30 (early Jul 2026); Carbon Pulse "below 13" (28 Jul 2026) shown as a hollow marker because only the headline was visible. Assessors and instruments differ, so the series is not a single index. Sources: Xpansiv, S&P Global, Fastmarkets, OPIS, Argus, Carbon Pulse.
7.1 Price evidence
FINDING: In early July 2026, OPIS assessed Phase 1 at USD 15.75 (1 July) and Argus recorded a low of USD 9.30, and Argus then reported its largest rise in spot prices since it began assessing in November 2025.
SO WHAT: Assessors and instruments differ, so no single number is "the price", and the spread between them is itself a risk.
NOW WHAT: Quote the assessor and date with every price, and ask sellers which assessment their offer references.
Table T7. Phase 1 price observations (USD per tCO2e unless stated)
Date | Price | Assessor or instrument | Note |
22 Jan 2025 (announced) | 21.70 | IATA first Guyana procurement via Xpansiv | Older than 12 months; event ran 28 Oct–29 Nov 2024 |
2 Jul 2025 | 21.85 | Platts | Older than 12 months |
30 Jan 2026 | Bid 17.05; offer 18.50 | Exchange quotes | Bid size 2,000 t (Climate Impact X) |
9 Feb 2026 | 18.30 | Fastmarkets Phase 1 spot | Down from 19.00 |
2 Jun 2026 | 11 (recent fall) | African Business summary | Journalist summary; airlines budgeted 18–20 |
1 Jul 2026 | 15.75 | OPIS; spot down 19.7% in H1 2026 | Specialist assessor |
Early Jul 2026 | 9.30 (low) | Argus | Differs from OPIS; not reconciled |
28 Jul 2026 | "Below 13" | Carbon Pulse headline | Headline only |
Sources: Xpansiv; S&P Global; Fastmarkets; Carbon Pulse; African Business; OPIS; Argus (Section 12).
No separate prices were found for Guyana, authorised, adjusted or insured units. The only unit-type datum is one trader's estimate that credits without an LoA, such as KOKO's, traded around USD 3–4 (Fastmarkets, 9 February 2026). Fastmarkets launched a conditional-offtake assessment on 29 April 2026 to show the spread to spot, but no value was visible.
Hoang Anh Dung, Founder and CEO of INTRACO Carbon, said at a panel reported by Fastmarkets on 9 July 2026:
"I can see a lot of demand. But if you say about buying, actually very, very little."
No October 2026 spot price was obtained; an October level needs a Platts, Argus or ICE data feed.
7.2 Cost exposure for buyers
FINDING: Sylvera estimates sector Phase 1 exposure of USD 2.4 billion at USD 15 per unit, and USD 1.08 billion to USD 3.8 billion for the top ten airlines at USD 15 and USD 53 (16 June 2026).
SO WHAT: The cost sits in a wide band that moves with price and authorisation, so airlines can budget only with large ranges.
NOW WHAT: Compare any airline cost headline with its price and demand assumptions before using it.
Chart 3 data (log scale): OPIS Phase 1 USD 15.75 (1 Jul 2026); EUA USD 91.87 (07:50 GMT, 5 Oct 2026, single source); SAF abatement about USD 480 per tCO2e (S&P Global worked example, illustrative, single source). UKA at GBP 62 (29 Sep 2026) is kept out of the chart because no exchange rate is given for it. The figures differ in date and basis.
Other published exposures include Sylvera's USD 2–5 billion of compliance spend that hinges on authorisations (3 June 2026), IATA's USD 4–5 billion of first-phase climate finance (6 June 2026), and an MSCI estimate relayed by AGBI that Emirates could face up to USD 8 billion of costs over 2024–2035 in a higher-price scenario. All are single-source or unconfirmed.
For how the physical alternative compares, the SAF Price Premium cost intelligence report (Part I) and Part II set out the cost of sustainable aviation fuel against credits, and the SAF Feedstock Reality Check 2026 explains why fuel supply limits make credits a compliance route.
7.3 Contract protections to demand
FINDING: The mechanisms described in this report (LoA, adjustment or insurance, programme liability, vintage windows) each convert into a contract term that shifts risk back to the seller.
SO WHAT: Without these terms, a buyer holds the risk that a unit fails a gate after payment.
NOW WHAT: Use the checklist below as the minimum term sheet for any forward purchase.
Table T8. Contract protections to request
Protection | What to request | Basis |
LoA evidence and scope | Copy of the LoA, volume, vintages, compliance cycle | Tighter LoA content from the 2026 TAB cycle (Fastmarkets, 12 Mar 2026) |
Adjustment or approved insurance | Host adjustment report or insurance certificate | Gold Standard and Verra interim requirements (Norton Rose Fulbright) |
Vintage and programme warranty | Seller warrants approved programme and vintage | HFW vintage windows; programme-count conflict |
Replacement or refund | Replacement units or refund if a unit fails to qualify | Units can fail after payment (KOKO) |
Delivery before the window | Delivery before 1 Dec 2027 | ICAO deck cancellation window |
Programme-liability position | Written statement of who bears double-claim liability | HFW: programmes carry liability to the ICAO Council |
Sources: Fastmarkets, Norton Rose Fulbright, HFW, ICAO (Section 12).
"The constraint isn't price, it's supply,"
said Linus Bauer, Founder of BAA & Partners, in AGBI reporting dated July 2026 from the page address. Bauer's point is that supply, not price, binds buyers. Burton's, quoted in Section 6.3, is that eligibility rules can split the market. Both support paying for documented protections rather than buying on headline price alone (analyst judgement).
7.4 Illustrative per-tonne sensitivity and worked example
FINDING: Against observed entry prices of USD 9.30, USD 15.75 and USD 21.70, Sylvera's modelled USD 15, USD 33 and USD 53 by January 2028 imply anything from a 31% fall to a 470% rise per unit.
SO WHAT: Entry price matters less than whether the unit will qualify, because a unit that fails earns nothing at any price.
NOW WHAT: Use the table to size loss and gain per unit, then apply the delivery test in the worked example.
Table T9. Illustrative sensitivity: change from entry price to Sylvera modelled value (USD per unit)
Entry observation | To 15 (lower bound) | To 33 (median) | To 53 (upper bound) |
9.30 (Argus low, early Jul 2026) | +5.70 (+61.3%) | +23.70 (+254.8%) | +43.70 (+469.9%) |
15.75 (OPIS, 1 Jul 2026) | −0.75 (−4.8%) | +17.25 (+109.5%) | +37.25 (+236.5%) |
21.70 (IATA first auction, announced 22 Jan 2025) | −6.70 (−30.9%) | +11.30 (+52.1%) | +31.30 (+144.2%) |
Sources: Argus; OPIS; IATA; Sylvera CORSIA Countdown (16 June 2026; single source).
Arithmetic: change = modelled value − entry price; percentage = change ÷ entry price.
Methodology note. Table T9 is arithmetic only: dated entry observations set against Sylvera's modelled values of USD 15, USD 33 and USD 53 per unit. It excludes transaction costs, financing, liquidity and counterparty loss, because no source reviewed gives data on them. It is an illustration, not a forecast and not a return model.
WORKED EXAMPLE: APPLYING THE THREE-QUANTITIES TEST AND THE PRICE TABLE (ILLUSTRATIVE)
What is sourced and what is illustrative. Sourced: the price points of USD 15.75 (OPIS, 1 July 2026) and USD 33 (Sylvera median for January 2028, single source). Illustrative, invented for this example and not drawn from any source: the airline, its 500,000-unit requirement, the broker's offer of 1,000,000 units, and the split of that offer.
Part A:
price exposure for a fictional airline, "Example Air", needing 500,000 units.
At USD 9.30: 500,000 × 9.30 = USD 4,650,000.
At USD 15.75: 500,000 × 15.75 = USD 7,875,000.
At Sylvera's USD 15 / 33 / 53: USD 7,500,000 / USD 16,500,000 / USD 26,500,000.
Part B:
the delivery test. A broker offers 1,000,000 units at USD 15.75, so the headline cost is 1,000,000 × 15.75 = USD 15,750,000.
Applying the framework in Section 4.3, assume 400,000 units pass every gate (deliverable), 350,000 hold an LoA but are not yet issued, and 250,000 have no LoA. In this stress case only the 400,000 count.
Cost per deliverable unit = 15,750,000 ÷ 400,000 = USD 39.375 (about USD 39.38), more than twice the headline USD 15.75.
Now assume Example Air must replace the 600,000 failed units at USD 33.
Replacement cost = 600,000 × 33 = USD 19,800,000.
Without a refund clause, total spend = 15,750,000 + 19,800,000 = USD 35,550,000 for 1,000,000 usable units, or USD 35.55 per unit.
With a refund of the price paid on failed units (600,000 × 15.75 = USD 9,450,000),
total spend = 15,750,000 − 9,450,000 + 19,800,000 = USD 26,100,000, or USD 26.10 per unit.
Reading. The refund clause is worth USD 9,450,000 in this stress case. The calculation excludes transaction costs, financing and liquidity, and it is not a forecast.
8. Future Scenarios & Forecast (2026–2035)
DIRECT ANSWER
No one can yet say how much CORSIA supply will exist by January 2028, because four published bases disagree: about 41 million labelled units (EDF), 72 million covered by Letters of Authorisation (IATA, 18 September 2026), 104 million "likely" (Sylvera) and 154 million "likely insured and authorised" (an unnamed aggregator cited by Carbon Pulse, 7 May 2026). Figures as of 9 October 2026.
8.1 Supply scenarios to January 2028
FINDING: Three scenarios, anchored to the published figures, leave gaps of 9.1 to 209 million units against demand of 163.1 to 250 million.
SO WHAT: Only the most optimistic supply basis nearly closes the gap against the lowest demand case, and none closes it against IATA's 250 million.
NOW WHAT: Watch the trigger events in the table, since they would move the market between scenarios.
Labelled supply rose from 31.3 million in early February 2026 (GreenAir) to above 40 million by 3 July 2026 (GenZero, via S&P Global, 7 July 2026), but each addition depended on a government act, so the past pace is not a forecast. The Constrained case assumes supply stays near the labelled stock. The Central case assumes units under existing LoAs are issued and protected in time: IATA's 72 million counts units under existing LoAs and may include units not yet issued, and Sylvera counts 48 million as confirmed (38 million issued plus 10 million expected). The Expanded case needs insurance and adjustments to scale quickly, from today's 7.8 million insurance-enabled units (Sylvera) or more than 10 million insured units (Oka, 9 July 2026). IATA's Supporting Alliance has set a target of 225–250 million units by spring 2027, which is a goal, not a supply figure.
Table: Supply scenarios to 31 January 2028
Scenario | Published anchor (million units) | What would have to happen |
Constrained | About 41 (labelled, EDF) | Few new LoAs or adjustments; supply stays close to today's labelled stock |
Central | 72 (LoA-covered, IATA) to 104 ("likely", Sylvera) | Units under existing LoAs are issued, labelled and protected in time |
Expanded | 154 (aggregator, paywalled) | Insurance and adjustments scale quickly; the basis of this figure is unstated |
Methodology note. The three scenarios are anchored only to published supply figures: labelled supply, LoA-covered supply and the "likely" figures from Sylvera and the unnamed aggregator. No probability weights are assigned, because that would need evidence on LoA conversion rates that no source reviewed contains. Likelihood is described in words, with the trigger events (LoA issuance, adjustment reporting, ICAO Council decisions) that would move the market between scenarios.
Table T10. Gap arithmetic: demand less supply (million units)
Supply basis | vs Sylvera base 163.1 | vs IATA low 200 | vs IATA high 250 |
41 (labelled, EDF) | 122.1 | 159 | 209 |
72 (LoA-covered, IATA) | 91.1 | 128 | 178 |
104 (Sylvera "likely") | 59.1 | 96 | 146 |
154 (aggregator) | 9.1 | 46 | 96 |
Arithmetic: demand − supply. The columns mix publishers and definitions; the gaps stated by publishers are about 125 million (Sylvera) and about 150 million (IATA).
8.2 Phase 2 and 2028–2035
FINDING: ICAO's Phase 2 requirement is 880–1,350 million tCO2 for 2027–2035 (EDF, 27 July 2026), and the EU proposal would keep CORSIA in EU law to 2035 with an effectiveness review by 1 July 2032.
SO WHAT: The Phase 2 requirement is about 6 to 13.5 times the Phase 1 range (ratio of the ICAO ranges relayed by EDF: 880–1,350 million against 100–150 million), so today's authorisation habits will shape supply for a decade.
NOW WHAT: Treat Phase 1 as the test of host-country capacity, and favour programmes and hosts that meet the stricter 2026 LoA content rules.
Price views for Phase 2 are thin. Sylvera models a Phase 2 ceiling of USD 49 by January 2030, MSCI is quoted by AGBI at about USD 15 today and up to USD 100 by the mid-2030s (single source), and IATA says first-phase climate finance of USD 4–5 billion could reach "potentially $100 billion by 2035" (IATA, 6 June 2026). The ICAO Council's 239th session also decides the 2027–2029 TAB cycle, for which 25 organisations applied (ICAO May 2026 newsletter). Few primary sources extend beyond 2030, so this section is bounded accordingly.
For the fuel side of the same period, the SAF compliance outlook for 2026–2030 and the Green Molecules Economy 2035 report cover the supply that would reduce reliance on credits.
8.3 Catalyst calendar
Eight dated events fall between 31 October 2026 and April 2028, from the 2025 Sector Growth Factor to unit-cancellation reporting. Each can move supply, demand or eligibility, so a position should be reviewed against this calendar. The most important is the 30 November 2026 State notification, because it is the first date many airlines hold a State-confirmed requirement for 2025 (analyst judgement).
31 Oct 2026: SGF | Oct–Nov 2026: ICAO Council | 2 Nov 2026: Platts Phase 2 | 30 Nov 2026: State notices | 2027: EU trilogue | 1 Dec 2027–31 Jan 2028: window | Apr 2028: reporting |
Visual V4: regulatory and compliance timeline.
Table T11. Catalyst calendar
Date | Event | Why it matters |
31 Oct 2026 | States obtain the 2025 Sector Growth Factor | Sets the base for 2025 requirements |
Oct–Nov 2026 | ICAO Council 239th session decides the 2027–2029 TAB cycle | Programme approvals and Phase 2 supply rules |
2 Nov 2026 | Platts launches Phase 2 assessments; its Phase 1 assessment continues to January 2028 | New price transparency (values subscriber-only) |
30 Nov 2026 | States notify operators of 2025 requirements | First firm demand figure |
Spring 2027 | IATA alliance target of 225–250 million units | Test of the alliance's supply goal |
2027 | EU trilogue on the 17 Jul 2026 proposal | Eligibility and double-charging rules |
1 Dec 2027–31 Jan 2028 | Cancellation window | Hard delivery date |
Apr 2028 | Unit-cancellation reporting begins | First public compliance record |
Sources: ICAO newsletters and SB64 deck; S&P Global Platts; IATA; EDF (Section 12).
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