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CORSIA Eligible Emissions Units 2026–2028: The Credit Supply Gap, Price Risk and Procurement Decisions Before January 2028 - Part II

Writer: Green Fuel Journal
Green Fuel Journal
40 minutes ago
10 min read


9. Strategic Recommendations

DIRECT ANSWER

Before buying CORSIA credits, investors should ask four questions: what is the unit's status (issued and labelled, LoA issued but unissued, LoA pending, or no LoA); what protects it against double claiming (host adjustment, approved insurance or neither); whether its vintage and programme sit inside the approved window; and whether delivery falls before the cancellation window opens on 1 December 2027. Position as of 9 October 2026.


9.1 For industry: airlines, procurement teams and developers

  • FINDING: Few airlines had moved to secure supply by June 2026 (Sylvera), and retirements stood at about 400,000 tonnes, about 0.2% of demand.

  • SO WHAT: Buying that bunches near the deadline would meet a market with few deliverable units.

  • NOW WHAT: Start with the five actions below.

    1. State the supply definition and the demand base in every contract (Table T2 shows why).

    2. Sequence purchases against the 30 November 2026 notification and the 2027 window.

    3. Hold an evidence file for each unit: LoA, adjustment report or policy certificate.

    4. Developers should secure host-country authorisation before spending on issuance, as the KOKO case shows.

    5. Confirm the cancellation-window wording with the relevant State in writing.


9.2 For investors

  • FINDING: Value sits with units that have cleared the authorisation gates, and prices have not yet separated by unit type in any source reviewed.

  • SO WHAT: An investor who buys on headline price may pay for units that never qualify, or miss a premium for those that do.

  • NOW WHAT: Apply the five actions below, each tied to its evidence.

    1. Order diligence by readiness grade, testing government gates first (Section 4.3 matrix).

    2. Insist on the Table T8 protections, above all replacement or refund (KOKO; worked example in Section 7.4).

    3. Treat headline-only prices as signals, not marks (Carbon Pulse headlines were paywalled).

    4. Watch the two catalysts, the EU trilogue and the ICAO Council session (Sections 6.3 and 8.3).

    5. Cap exposure to any one host country, since Guyana holds 24.9 Mt of the authorised tranche (Sylvera, 3 June 2026).


No source reviewed supplies a return model, and this report does not invent one; the arithmetic in Section 7.4 is illustrative only.


9.3 For policymakers

  • FINDING: ICAO Council decision C-DEC 236/3 reaffirms ICAO outreach and national coordination to expedite attestations, yet only 10 countries had made units available by June 2026.

  • SO WHAT: The supply gap is mainly a state-capacity gap, which only governments can close.

  • NOW WHAT: Four actions follow.

    1. Speed LoA issuance and adjustment reporting (consistent with C-DEC 236/3 and IATA's alignment point).

    2. Legislate national penalties, since CORSIA leaves sanctions to States (HFW; Roland Berger).

    3. Clarify the cancellation window wording (IATA, ICAO and HFW differ).

    4. Resolve the EU–ICAO double-charge overlap (ICAO, 20 July 2026).

    5. Five States, Guyana, Madagascar, the UK, Zambia and Zimbabwe, had joined IATA's Aviation Carbon Market Compact by 23 June 2026 (IATA, 23 June 2026), which gives States that want to move faster a route to do so.


Table T12. Recommendation summary

Audience

Priority action

Evidence

Industry

Define supply and demand bases in contracts

Gap figures of 125, 150 and 175 million

Industry

Hold LoA and adjustment evidence

5 countries reporting adjustments

Investors

Diligence by readiness grade

About 300 million issued, about 38 million cleared

Investors

Require refund or replacement

KOKO; worked example

Policymakers

Speed LoAs and adjustments

10 countries supplying

Policymakers

Legislate penalties

HFW; Roland Berger

Sources: sections of this report and the sources cited there.


The four questions above form a screening aid.

A unit that is issued and labelled, has a reported adjustment or approved policy, sits inside an approved window and delivers before 1 December 2027 is Tier 1 (lowest evidence risk).

A unit with no LoA, an unverified vintage or no double-claim protection is Tier 4 (do not commit without protection). Tier 2 covers units that hold an LoA and a label but whose adjustment or policy is still pending. Tier 3 covers units whose LoA is issued but whose units are not yet issued, or whose LoA is pending. The screener gives no price and no probability, and it is not advice.


Methodology note. The screener is a rule-based test built from the gate logic in Section 4 and the protections in Section 7.3. It outputs a diligence tier and a list of protections to request, not a price or a probability.


9.4 The action for energy investors before 30 November 2026

The investable CORSIA position today is the small pool of units that already hold a Letter of Authorisation and a label, about 36.6–41 million against demand estimates of 100–250 million. Value therefore sits in documented deliverability, not in headline volume or headline price. Before the States notify operators of their 2025 requirements on 30 November 2026, request the LoA, the adjustment report or insurance certificate, and a refund-or-replacement clause from every seller, place each unit in Tier 1 to 4, and prioritise Tier 1 and Tier 2 units until the ICAO Council and Commission decisions are known.


10. Executive FAQ


How many CORSIA credits will actually be available by January 2028?

Between about 41 million and 154 million units, depending on the definition used. EDF reported about 41 million labelled units (27 July 2026), IATA counted about 72 million covered by Letters of Authorisation (18 September 2026), Sylvera calls 104 million "likely", and an unnamed aggregator cited by Carbon Pulse put "likely insured and authorised" supply at 154 million (7 May 2026). No source reconciles these bases.


Why are CORSIA credit prices falling if there is a shortage?

Because buying has been slow and enforcement is national. Sylvera reported in June 2026 that few airlines had moved to secure supply, and Argus wrote on 17 July 2026 that the lack of affirmation by countries, meaning national laws that commit to CORSIA as the EU proposes to do, has kept potential airline demand at bay. Doubt over authorisation also weighs on prices: one trader estimated credits without a Letter of Authorisation at USD 3–4 (Fastmarkets, 9 February 2026).


What makes a carbon credit eligible for CORSIA?

Five tests, all of which must be met. The credit must come from an ICAO-approved programme, fall in an eligible vintage, carry a host-country Letter of Authorisation, be protected against double claiming by a corresponding adjustment or an approved insurance product, and be cancelled by the operator within the compliance window.


What happens if an airline cannot cancel enough credits by 31 January 2028?

The consequence rests with each State, and the sources show no ICAO sanction. HFW and Roland Berger both say CORSIA leaves enforcement to national law, and many States have not legislated penalties. No source reviewed reports an extension of the deadline, and what a State will do when the shortage is public remains untested.


Which countries and projects are supplying CORSIA credits today?

Ten countries had made units available by 7 June 2026, according to IATA's Willie Walsh. The supplying countries are Guyana, Laos, Cambodia, Uzbekistan and six African countries. Guyana's jurisdictional forest credits and Rwandan cookstove projects lead the authorised supply (Sylvera, 3 June 2026), Nigeria's first tagged units followed on 30 July 2026, and Kenya refused KOKO Networks an authorisation.


What does CORSIA mean for Indian airlines from 2027?

Offsetting begins in 2027, according to India's own State Action Plan to ICAO (2026), which says India, while not participating voluntarily, will begin offsetting from that year. Monitoring applies to operators above 10,000 tCO2 a year. No airline-level exposure figure and no Indian Letter of Authorisation was found, so the cost to Indian carriers cannot yet be stated.


11. Legal Disclaimer and Research Limitations


11.1 Research limitations

This report found no primary government document for China or India, and no Indian Letter of Authorisation. These gaps limit how much weight each part can bear. It did not obtain an October 2026 spot price: the latest numeric prices date from July 2026. ICAO's per-programme volumes and vintage rules could not be retrieved, nor could the source of its 100–150 million tonne requirement. The EUA, UKA and SAF figures each rest on a single source. Brazil, Australia and the Gulf have thin evidence, with no implementing instrument or Gulf authorisation found. No registry or database was queried directly, so every volume comes from secondary reports, several of them paywalled with only headlines visible. Prices by unit type are unknown beyond one USD 3–4 estimate. No quote from a named ICAO official or regional regulator was found. Figures should be checked against the cited source before they support a transaction.


11.2 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.


12. References & Strategic Sources


This report is backed by authoritative research, institutional analysis, industry intelligence, and strategic data sources.


© 2026 Green Fuel Journal. All rights reserved. No part of this report may be reproduced or distributed without written permission.



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