The European Commission has pushed adoption of an implementing regulation setting detailed eligibility requirements for carbon credits used by EU-based airlines under the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) to the first quarter of 2027, according to its updated legislative planning page, Carbon Pulse reported. The delay matters for airlines, credit suppliers and project developers because the act will define which credits count toward CORSIA compliance in the EU, and the market now faces an extended stretch without final eligibility criteria as the first compliance cycle approaches.
The New Timeline From Brussels
The Commission expects to publish the draft implementing act for public feedback in the fourth quarter of 2026, with adoption planned for the first quarter of 2027. “The commission expects to publish the draft implementing act for public feedback in the fourth quarter of 2026, and plans the adoption for the first quarter of 2027,” officials said, Argus Media reported.
Officials described the revised schedule as “well ahead” of the compliance deadline for CORSIA Phase 1, which falls on 31 January 2028, Argus Media reported. The new timeline has now been reflected on the Commission’s website.
The directorate general for climate action is currently drafting the implementing act and had earlier planned adoption by the end of this year. Once published, the draft act must undergo a four week public consultation period before adoption can proceed.
What the Implementing Act Will Decide
The regulation will set the detailed eligibility requirements that determine which carbon credits EU-based aircraft operators can use to comply with CORSIA, Carbon Pulse reported. Until the act is adopted, the specific criteria that gate access to EU aviation demand remain undefined.
That makes the implementing act the central piece of secondary legislation for airlines’ offsetting obligations: it is the missing link between the scheme’s high level obligations and the credits that can actually be surrendered against them. For credit suppliers, it will determine whether existing inventory and pipeline projects can serve EU-based operators at all.
Why the Commission Moved the Date
The delay follows pressure from the market. After pushback from market stakeholders, the Commission agreed to scrap the planned requirements for CORSIA Phase 1 in what was described as a “gesture of goodwill” to feedback from industry, Argus Media reported.
The sequence suggests industry feedback, rather than drafting capacity alone, drove the change. The consultation planned for the fourth quarter of 2026 gives stakeholders a formal channel to shape the final criteria before adoption.
Implications for Airlines and Credit Suppliers
For EU-based aircraft operators, the slip compresses the runway between regulatory clarity and compliance. Eligibility criteria are now expected roughly ten months before the 31 January 2028 deadline, leaving limited time to structure procurement around rules that do not yet exist.
For credit suppliers and project developers, eligibility risk now extends into 2027. Credits intended for aviation demand cannot be confirmed as qualifying for EU-based operators until the act is adopted, which complicates pricing, contracting and offtake discussions in the interim.
The delay also shifts leverage toward the consultation phase. Because the criteria are not yet fixed, written feedback during the four week window can still alter what qualifies, making engagement a practical necessity rather than a formality.
What to Watch
Three markers stand out. First, the publication of the draft implementing act in the fourth quarter of 2026: the draft text will show how far the Commission intends to go on eligibility after scrapping the planned Phase 1 requirements.
Second, the consultation responses. The four week public feedback period will indicate whether airlines, registries and project developers converge on the criteria or push for further changes before adoption.
Third, the adoption itself in the first quarter of 2027. Any further slippage would narrow the gap between regulatory clarity and the 31 January 2028 compliance deadline, concentrating procurement decisions into a shorter window.
