CORSIA Carbon Credit Demand and the Price Gap

International aviation entered the first mandatory phase of its carbon offsetting scheme in 2024, and the scheme's rules accept only a small subset of the credits the voluntary market produces. The International Air Transport Association has estimated that airlines may need on the order of 100 to 150 million tonnes of eligible credits across the 2024 to 2026 phase. Eligible supply, by contrast, was measured in the single-digit millions of tonnes through most of 2025. That mismatch between regulated demand and qualifying supply is now the most important price signal in the carbon credit market, and it is a signal built on data quality.

What CORSIA actually requires

The Carbon Offsetting and Reduction Scheme for International Aviation, agreed through the International Civil Aviation Organization, obliges airlines on international routes to offset emissions growth above a baseline set at 85% of 2019 levels. The pilot phase from 2021 to 2023 was voluntary for states. The first phase, running from 2024 through 2026, is also voluntary for state participation but mandatory for airlines from participating states, and the large aviation markets of North America, Europe and much of Asia are in. The second phase from 2027 becomes mandatory for nearly all states with meaningful international traffic.

Source: https://www.icao.int/environmental-protection/CORSIA/Pages/default.aspx

The scheme's rules matter more than its headline. To count toward a CORSIA obligation, a credit must come from a crediting program approved by ICAO's technical advisory body, must be issued against activity in a vintage window the scheme accepts, and, critically, must carry a corresponding adjustment from the host country. A corresponding adjustment is the host government's commitment not to count the same emission reduction toward its own Paris Agreement target. Without it, the credit cannot be used for CORSIA.

That last requirement is what separates eligible units from the broader market. The voluntary carbon market has issued well over a billion credits over the past decade. Only a small fraction of those credits sit in approved programs, in the right vintage window, with a host-country letter of authorization attached. By mid-2025 the credits that met all three tests came mostly from a single jurisdictional forestry program in South America, with a pipeline of projects elsewhere working through the authorization process.

A two-tier market with a widening gap

The consequence is a two-tier market. Generic nature-based credits without corresponding adjustments have traded for a few dollars per tonne, sometimes less, as buyers retreated from projects with integrity questions. CORSIA-eligible units with a corresponding adjustment have traded at a multiple of that, with price assessments during 2025 placing them in the low-to-mid twenties of dollars per tonne. Two credits representing one tonne each, from similar project types, can differ in price by a factor of five or more purely because of eligibility status.

The World Bank's State and Trends of Carbon Pricing report for 2025 records that compliance carbon pricing instruments now cover roughly a quarter of global emissions and raised more than $100 billion in revenue in 2024. CORSIA is small against that backdrop, but it is the first global compliance mechanism that buys credits from the project market rather than from a government auction. It is, in effect, the first regulated bid for voluntary-market supply, and the supply side has been slow to respond.

Source: https://www.worldbank.org/en/publications-reports/state-and-trends-of-carbon-pricing

Why has eligible supply lagged? Three reasons recur in conversations with project developers and buyers.

Why this is a data problem before it is a supply problem

Look closely at the eligibility tests and every one of them is a question of verifiable record. Which program issued the credit? What vintage? Has the host country issued an authorization, and does the registry record reflect it? Has the credit already been retired or used against another obligation? These are not questions about the forest or the cookstove. They are questions about data, and today that data sits across multiple registries, government letters, and spreadsheets maintained by brokers.

The pricing gap persists partly because confirming eligibility is slow and expensive. An airline buying 500,000 credits for a 2024 obligation has to verify each batch against the ICAO eligible-units list, the registry's own record, and the host-country authorization, then hold the credits until its reporting deadline and cancel them in the registry. Brokers charge for that diligence. Smaller airlines, and corporates who want to buy CORSIA-grade credits as a quality signal, often cannot do it at all.

This is where a digital capital markets approach changes the economics. When a carbon credit is represented as a digital asset whose metadata carries the issuing program, the vintage, the authorization reference and the retirement status, and when that metadata is attested by an independent oracle rather than asserted by the seller, eligibility becomes something a buyer can check in seconds rather than days. The credit becomes a verifiable fact rather than a claim. Commertize treats carbon credits as one asset class inside an open marketplace for real-world assets, alongside gold, energy, digital infrastructure and commercial real estate, and the common requirement across all of them is that the operating data behind the asset be independently checkable. Our pillar piece on what RWA tokenization is sets out the general principle.

What better market structure would do for the price gap

A market where eligibility is verifiable at the instrument level would narrow the gap in three ways.

Forward contracts become financeable. The biggest constraint on eligible supply is that developers cannot fund authorization and verification without a committed buyer. If a forward purchase of CORSIA-eligible credits can be structured as an instrument with transparent delivery terms and verifiable project milestones, it can be financed by investors who are not airlines. That brings capital into the supply side at the moment it is needed. The structures for doing this are the same ones used for any contracted real-asset cash flow, as described on our how it works page.

Settlement risk falls. Credit transactions today settle through registry transfers that can take days and that depend on both parties' registry accounts being in order. Settling the credit and the cash leg together, atomically, removes the window in which one side has delivered and the other has not. For a compliance buyer facing a reporting deadline, settlement certainty has real value.

Smaller participants can take part. The eligible-credit market today is a dealer market serving large airlines. A marketplace where a corporate treasury, a fund or an individual investor can buy a verified CORSIA-eligible credit in a small lot, hold it with a clear ownership record, and retire it or sell it, widens the buyer base. A wider buyer base supports a deeper and more stable price. The Commertize marketplace is designed around exactly that kind of broad access to verified real-world assets.

The questions that remain open

None of this removes the underlying scarcity. If governments do not issue corresponding adjustments, no amount of transparency creates eligible credits. The second phase of CORSIA from 2027 will raise demand further, and the sector's own analyses suggest that Phase 2 obligations could run to several hundred million tonnes per year by the early 2030s. Whether supply catches up depends on policy in a few dozen host countries.

There is also an integrity question that data alone does not answer. A credit can be fully eligible on paper and still represent a reduction that would have happened anyway. Buyers increasingly want evidence of additionality and permanence alongside eligibility, and the market is moving toward rating and verification services that provide it. Verifiable metadata makes those ratings portable, but it does not replace them.

What verifiable data does do is turn the CORSIA price gap from an opaque dealer spread into a visible market signal. When any participant can confirm in seconds that a credit meets the scheme's rules, the premium for eligibility reflects real scarcity rather than diligence cost. That is a better market for airlines, for project developers who have done the work of authorization, and for the investors who are being asked to fund the next phase of supply.

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