ICAO Approves VCS Program for CORSIA Eligibility: Details and Verra Response

The United Nations International Civil Aviation Organization (ICAO) has announced that the Verified Carbon Standard (VCS) Program is eligible for the first phase (2024–2026) of the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA). This is a long-awaited decision for the fledgling CORSIA carbon market. It opens a new lifeline of credit supply for airlines mandated under CORSIA to halt the rise in net aviation emissions.

ICAO also published an updated Eligible Emissions Units (PDF) document with detailed information about the VCS credit categories and vintages that are eligible for the first phase of CORSIA.

The approval extends the VCS Program’s eligibility from CORSIA’s pilot phase (2021–2023) into its first phase (2024–2026), significantly increasing the number of Verified Carbon Units (VCUs) that may become eligible for CORSIA labels.

In principle, all VCUs are covered by the eligibility decision except for the following project types or methodologies that ICAO has excluded:

• Projects using a methodology under sectoral scope 16 (Carbon Capture and Storage [CCS]) have not yet been granted eligibility, with ICAO stating that it needs more time to consider how to apply its criteria to carbon dioxide removal (CDR) activities.
• Large-scale renewable energy projects have been excluded where they have a maximum electricity generation of more than 15 megawatts.
• Cookstove projects using two older methodologies, AMS-II.G. Energy efficiency measures in thermal applications of non-renewable biomass (external) from the Clean Development Mechanism (CDM) and Verra’s modification of this methodology, VMR0006 Energy Efficiency and Fuel Switch Measures in Thermal Applications, are not eligible. Projects using VCS Methodology VM0050 Energy Efficiency and Fuel-Switch Measures in Cookstoves are eligible under CORSIA’s first phase.

Note: Verra provides a pathway for cookstove projects using older methodologies to update to VM0050 and to requantify VCU issuances from past verification periods, using its Methodology Change and Requantification Procedure (PDF).

As with the pilot phase, VCUs from Agriculture, Forestry, and Other Land Use (AFOLU) projects in REDD+ countries are currently eligible for the first phase if the following conditions apply:

• The projects are expected to generate fewer than 7,000 tCO₂e of reductions and removals per year; or
• The projects use one of the following methodologies: VM0012, VM0017, VM0021, VM0022, VM0024, VM0026 (and VMD0040), VM0032, VM0033, VM0036, VM0041, VM0042; or
• The projects are “nested” into jurisdictional REDD+ accounting in the context of Scenario 2a or Scenario 3 of the VCS Jurisdictional and Nested REDD+ (JNR) Framework. This makes way for projects using Verra’s new REDD methodology (VM0048) to be eligible under CORSIA in its first phase.

Verra suggests that the following exclusions – which seem to have not been applied consistently across all eligible programs – should be reviewed in the next round of CORSIA eligibility decisions and is working with ICAO to address them:

• Exclusion of the cookstove methodologies AMS-II.G. and VMR006: Credits issued under these methodologies have been excluded from the first phase eligibility for the VCS Program but not for other crediting programs that use the same or similar methodologies. This brings into question the consistency with which eligibility decisions for CORSIA have been applied.
• Exclusion of methodologies under sectoral scope 16 (CCS): Projects involving CCS are crucial if we are to be successful in limiting global warming. In Section 4.4.1 of the TAB report (PDF), ICAO stated it is still considering whether CDR activities meet CORSIA requirements, but it is important to note that CCS does not only include CDR activities. Verra believes these new methodologies fully meet the CORSIA criteria and warrant unrestricted inclusion or should at least be eligible when they occur in countries that have an ICAO-approved greenhouse gas program that covers these activities. 
• Exclusion of certain AFOLU projects not “nested” into jurisdictional REDD+ accounting: Verra further suggests that stronger consideration should be given to the rigorous quality of accounting applied for AFOLU projects under the latest generation of methodologies, such as VM0045 Methodology for Improved Forest Management Using Dynamic Matched Baselines from National Forest Inventories, VCS Methodology VM0047 Afforestation, Reforestation, and Revegetation, and VCS Methodology VM0048 Reducing Emissions from Deforestation and Forest Degradation.

VCUs with vintages of 2021 onward will require an “Article 6 Authorized – International mitigation purposes” label to be eligible for use toward CORSIA because the mitigation impact of these credits occurs within the period of the Paris Agreement. Information on Article 6 labels for VCUs is available in Article 6 Label Guidance (PDF). A new version of the Article 6 Guidance incorporating the outcomes from COP29 will be released in the new year. 

For the mitigation outcomes represented by VCUs with vintages of 2021 onward, Verra requires additional assurances that there is no double claiming. Verra is currently finalizing requirements that must be met and intends to release these shortly.