Since first opposing the full implementation of the EU Emissions Trading System (EU ETS) in 2007, Airlines for America (A4A), Airlines for Europe (A4E),1 and the International Air Transport Association (IATA) appear to have collectively drawn on elements of a simple but highly effective playbook to stall the EU ETS. The central strategy consists of repeatedly pitting regional efforts to address aviation emissions against global measures with a series of circular arguments, leaving no regulatory body able to properly address rising aviation emissions. As the EU ETS review approaches, the industry is once again deploying this playbook.
The Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA) was developed by the United Nations International Civil Aviation Organization (ICAO) in 2016 to serve as a primary measure to regulate international aviation emissions. CORSIA requires airlines to offset emissions above a threshold, leaving emissions below that threshold unregulated. However, an October 2025 Climate Action Tracker assessment “estimates that without ambitious, additional policies and actions, emissions from international aviation will more than double between 2024 and 2050.”
Originally intended to cover all flights to and from the EU, the EU ETS scope has been “temporarily” restricted to intra-EEA flights since 2012. This followed over a decade of sustained industry opposition, starting with IATA calling for an international approach in 2007, amplified by geopolitical pressures. In 2025, the aviation industry reinforced this long-standing opposition to the EU ETS geographical extension, fitting into a broader advocacy strategy to oppose most strands of climate policy. This calls into question the integrity of the industry's decarbonization plans.
From CORSIA’s inception in 2016 to this day, aviation industry associations have claimed that only ICAO should regulate international aviation emissions, asserting that EU-level action, such as the EU ETS, would jeopardize ICAO negotiations. Associations also claimed on several occasions that the EU ETS is illegal under the Chicago Convention, the treaty that established ICAO.
However, InfluenceMap research revealed that ICAO’s climate negotiations have disproportionately represented industry interests, while opaque disclosure practices have allowed industry players to advance their interests without external scrutiny. The resulting 2016 ICAO Assembly Resolution—which outlined CORSIA as the “only global market-based measure”—closely resembles recommendations from the aviation industry's leading industry association, IATA. Analysis of this industry influence suggests that the scheme was strategically designed to counter additional climate ambition by states or regions.
Additionally, InfluenceMap revealed how IATA not only proposed and helped shape CORSIA’s design but later campaigned to weaken it. In the wake of COVID-19, the industry—led by IATA and supported by groups such as A4A and A4E—successfully pushed to dilute CORSIA’s emissions baseline from the original 2019–2020 average to 2019 levels alone. IATA continued to advocate for further weakening measures in a paper that was later withdrawn, and in 2022 a revised baseline set at 85% of 2019 emissions was ultimately adopted.
Since 2012, the EU Emissions Trading System (ETS) has been limited to intra-European Economic Area (EEA) flights, leaving most EU aviation emissions effectively unregulated. By July 2026, the European Commission is expected to publish an assessment of CORSIA's efficacy in achieving the Paris Agreement's objectives. If deemed insufficient, the Commission could present a legislative proposal to extend the scope of the EU ETS to all flights departing the EEA. As ICAO failed to meaningfully strengthen CORSIA at its 42nd Assembly in October 2025, the EU ETS review presents a crucial opportunity for the EU to regulate long-haul aviation emissions in line with the Paris Agreement. Please see this InfluenceMap January 2026 Briefing for a full explanation of CORSIA and the EU ETS.
Fact check: A report by the Tourism Panel on Climate Change highlighted that ICAO provisions are based on recommended standards and practices, and as such, are not legally binding. It further clarified that an ICAO Assembly resolution is not legally binding, as a State may “file a difference” with any ICAO standard under Article 38 of the Chicago Convention.
An August 2022 easyJet presentation to the Council of the EU suggested that ICAO discussions are “misused by some groups to stop governments regulating departing long-haul flights” and emphasized a “Risk that EU governments are being manipulated” by international airlines effectively “using ICAO talks as a hostage” to keep stalling the EU ETS extension.
Additionally, in December 2011, the European Court of Justice confirmed that a full-scope ETS would not breach the Chicago Convention as the policy does not impose obligations on other states. November 2025 legal analysis by Opportunity Green also found that the EU ETS can legally be applied to all international flights and does not contravene international law.
Since 2016, industry associations have asserted that CORSIA is the “only” global market-based mechanism, claiming that as “aviation is a global activity … a global framework is preferred.” To support this claim, they argue that “unilateral” measures such as the EU ETS would create a “patchwork” of regional market-based measures, while applying CORSIA alone would avoid regulatory inconsistencies and reduce economic damage by enabling a level playing field, while preventing potential trade conflicts. At times, the industry has even pushed for the repeal of the EU ETS on intra-EEA flights, arguing it conflicts with the CORSIA agreement.
Fact check: In its original EU ETS impact assessment, the Commission noted that covering all departing and arriving flights would deliver the biggest environmental benefits while being “neutral from a competition point of view, considering the alternative scope options,” and would be “the best option for tourism.” Opportunity Green further highlighted that including non-EEA flights under the ETS would strengthen the competitiveness of EU airlines by leveling the playing field between US and European airlines, subjecting them to the same regulation. An August 2025 Carbon Market Watch study also found that pricing emissions from all flights departing the EU could more than double the revenue generated from aviation emissions. CORSIA, meanwhile, has required airlines to make virtually no changes since its conception in 2016 and is set to expire in 2035.
Currently, CORSIA does not apply to all international flights. While an IATA policy paper presented at ICAO’s 42nd Assembly in 2025 stated that “the unified implementation of CORSIA by all Member States without regional or national derogations, is vital to uphold its exclusivity to address international air transport CO₂ emissions,” it remains unclear whether many large states like India, China, and Russia will comply. As EU Commission policymakers note, an international carbon market could be best achieved through a bottom-up process that links the EU ETS to other comparable systems to create an effective global carbon price.
This playbook illustrates industry associations’ long-term, systematic efforts to leverage support for an international initiative they designed —and weakened— to block ambitious regional climate policies. Its application is not limited to the EU ETS: A4A leveraged the same set of arguments to question the legality of applying the UK SAF mandate to US carriers and to oppose flight bans. Similarly, A4E used ICAO and CORSIA to oppose an EU kerosene tax, and IATA opposed the global environmental taxation of aviation, including the Global Solidarity Levies Task Force—a call echoed by the United States at the last ICAO assembly.
These industry associations have made strong public proclamations on the industry’s commitment to net-zero emissions from aviation by 2050, but they systematically oppose policies that enable binding emissions reduction, leveraging their commitment to CORSIA to do so. This contradiction persists despite IATA’s own assessment that climate change likely poses a severe risk to the aviation sector. Given aviation’s significant growth plans—including projections of record net profits in 2026—and the lack of binding regulation for the sector, continued delays in implementing ambitious regulation could jeopardize the EU’s climate goals and the Paris Agreement.
1 While A4E opposed the inclusion of extra-EEA flights under the EU ETS in June 2020 and January 2021 consultation responses, InfluenceMap did not find a public position from the association on the geographical scope of the EU ETS in 2023 and 2024. However, A4E’s response to the July 2025 call for evidence on the EU ETS opposed the application of the EU ETS to any extra-EEA flights.
