ESG Global Vision

Environment, corporate governance

Varies between participating states 

CORSIA applies to airline operators who fulfil the following criteria:

• their annual CO2 emissions from international flights using aeroplanes with a take-off mass greater than 5,700kg exceed 10,000 tonnes (all major carriers meet this relatively low threshold);
• they are responsible for international flights (flights by state aircraft and humanitarian, medical, and firefighting flights, as well as flights before or after such flights which are carried out by the same aeroplane and are needed for these activities, are not included); and
• they are registered in one of the participating states (see the list as of 1 January 2026 here; notable omissions include India and China).

In 2010, the International Civil Aviation Organisation (ICAO), a United Nations Agency that sets global standards and regulations for international civil aviation, adopted a sectoral aspirational goal for carbon neutral growth from 2020 onwards. Whilst operational and technological improvements are seen as a key part of achieving this goal, the ICAO took the view that a market based scheme was required to fill the remaining emissions gap and to achieve carbon neutral growth. Accordingly, the International Standards and Recommended Practices for the implementation of CORSIA were adopted as an Annex to the Chicago Convention in 2016, to apply to all of ICAO’s 193 member states from 1 January 2019.

CORSIA is being implemented in three phases:

• The Pilot Phase (2021-2023) and the First Phase (2024-2026). During these phases participation by ICAO member states was voluntary. 126 member states participated, with flights between participating states subject to reporting and offsetting requirements.
• The Second Phase (2027-2035). During this phase, with some exemptions, such as for Least Developed Countries and Small Island Developing States, participation will become mandatory for all ICAO member states and all international flights will be subject to offsetting requirements. The Second Phase will be split into three-year compliance periods.

In scope airline operators are under the following obligations:

• To monitor and report emissions from international flights on an annual basis.
  • At the beginning of each 3-year compliance period, an operator is required to submit an Emissions Monitoring Plan to its administering state which, once approved, the operator will use for the entire compliance period.
  • Under the plan, the operator is required to monitor and record its fuel use for international flights over the course of each calendar year. The operator must then estimate their annual CO2 emissions and report them to the national authority of their administering state by 30 April the following year. To guarantee the accuracy of the data reported, operators will need their annual emissions report to be verified by an impartial third-party verification body prior to submission.
  • Aggregated emissions are required to be reported by each administering state to ICAO, which will publish the total emissions from individual operators.
• To offset their emissions.
  • Under the scheme, the administering state calculates the annual offsetting requirements for each operator by multiplying the operator’s CO2 emissions by a ‘Growth Factor’, which is calculated by the ICAO and represents the percentage growth of the aviation sector’s international CO2 emissions covered by CORSIA’s offsetting requirements in a given year compared to the sector’s baseline emissions (being 85% of 2019 emissions levels).
  • Upon completion of each 3-year compliance period, the operator will have to show they have met their offsetting requirements by purchasing and cancelling the appropriate number of certified CORSIA Eligible Emissions Units (“CEEUs”) (each representing a tonne of CO2). The price of these units varies considerably depending on the type of project ($0.50 to $45/tCO2e during 2020-2021 with a weighted average of $3.08/tCO2eq in 2021).
  • Operators can also reduce their offsetting requirements by using CORSIA Eligible Fuels (“CEFs”) that meet the CORSIA sustainability criteria, which includes fuels with at least 10% lower CO2e emissions on a life-cycle basis compared to a reference fossil fuel value of 89.1 gCO2e/MJ. It is worth noting that as the baseline for calculating emissions reduction targets is 85% of 2019 emissions levels, offsetting requirements will only cover the growth in emissions since 2019 and therefore it is anticipated that the percentage of their total emissions that operators will have to offset will remain modest for the first few years of implementation of the scheme.

For more information, please follow the link here.

Penalties and enforcement:

National aviation authorities of participating states determine the sanctions for non-compliance, so these vary between countries. In the UK, for example, typical civil penalties can include a £20,000 penalty with a further daily penalty of £500 for failing to: (i) apply or revise an emissions monitoring plan; (ii) monitor emissions properly; or (iii) submit emissions reports. In recent consultations, the UK government has indicated that the penalties for failing to cancel CEEUs on time in line with an airline’s offsetting requirements would be £100 for each uncancelled unit.

Environmental decree

In force

All relevant persons

This law serves as the legal and normative framework and roadmap through which the Cameroonian Government controls, manages and decides on its national environmental policies.

Under this law, the national environmental policy of Cameroon is defined as covering all biogeochemical matters as well as the economic, social and cultural factors which affect the development of the environment, living organisms and human activities.

It includes the right of access to environmental information and a “Polluter Pays Principle” (Section 9(c)). The Polluter Pays Principle provides that one who pollutes must pay for the mitigating costs associated with their conduct, including measures aimed at preventing, reducing and combating pollution, and costs associated with rehabilitating polluted areas. Section 9(d) of the Forest Code (see below) also imposes liability for causing environmental harm, stating that “any person who through his actions creates conditions likely to endanger human health and the environment shall eliminate or cause the said condition to be eliminated in such a way as to avoid the said effects.”

Environmental decree

In force

All relevant persons

The Forest Code is the pre-eminent law regulating forests, fauna and fisheries in Cameroon. It permits the zoning of all of Cameroon’s forest lands as planned by the 1993 zoning system. It also introduces the concept of community by allowing certain forests outside the public domain that are less than 5,000 hectares to be divided and managed by “communities” or villages. Order No 2001/ 0518/MINEF/CAB of December 21, 2001 specifies additional community rights in acquiring community forests under the Forest Code.

Forest management units or FMUs (Unité forestière d’aménagement or UFA in French) can be allocated within the permanent domain for a 15-year period renewable twice. Forest management plans are prepared for FMUs during the interim period that the allocated party signs with the State for a (non-renewable) period of three years. The allocated party bears the cost of forming the plans and a governmental committee validates the plans.

Logging sales permit harvesting over a maximum of 2,500 hectares for up to three years outside the public domain in forests to be converted to non-forest use.

There are also provisions for small titles such as personal authorisations with a maximum of 30m3, cutting permits (permis de coupe) of up to 300m3, and authorisations to recover timber following land conversion or special authorisation (autorisation de récupération de bois or ARB).

Environmental decree

In force

Landlords/Employers/Polluting entities

Law No 98/015 of 14 July 1998 addresses establishments classified as dangerous, unhealthy or inconvenient. Sections 5, 7, 9 and 12 state that the person in charge of such establishments must carry out a risk assessment before commencing such establishments. The law also stipulates that a safety zone must be set up around such establishments prohibiting dwellings and any activity incompatible with this operation. Polluting establishments are subjected to an annual pollution tax, and those who take actions to protect the environment profit from a deduction on their taxable profit according to the methods stated by the finance law (see below).

Environmental decree

In force

Persons involved in forestry

Law No 94/01 of 20 January 1994 aims to increase local transformation of timber to increase added value. It does so by stipulating a set of tax incentives favouring processed timber, but also by imposing a partial logging ban through the establishment of quotas on certain species and a tax surcharge.

For communities to extract timber, they must obtain an Annual Exploitation Certificate (AEC) from the Ministry of Forests (MINFOF). Communities must follow these steps to legally harvest timber from their concessions:

• verify the boundary of the annual logging unit;
• verify the logging inventory carried out in the annual logging unit;
• write an Annual Activity Report for the previous exploitation year;
• write an Annual Plan of Operations for the current exploitation year;
• photocopy all waybills from the previous year;
• photocopy the Simple Management Plan approved by MINFOF, and
• write a request to obtain an AEC.

All these steps must be approved and verified by a departmental and regional forestry delegate.

Environmental decree

In force

Persons involved in forestry

Finance Law No 2002/003 of April 19, 2002 determines on an annual basis the rates for different taxes applicable to forestry activities (felling tax, annual royalties for forest concession areas, etc.). In collaboration with the Ministry of Finance, the Ministry of Forestry negotiates the terms of benefit sharing. The law also fixes the percentage paid to the local communities living around the  forest for development purposes. The Finance Law, however, also imposes fines on parties who are in breach of various forestry laws and regulations.

Environment, corporate governance

Varies between participating states 

CORSIA applies to airline operators who fulfil the following criteria:

• their annual CO2 emissions from international flights using aeroplanes with a take-off mass greater than 5,700kg exceed 10,000 tonnes (all major carriers meet this relatively low threshold);
• they are responsible for international flights (flights by state aircraft and humanitarian, medical, and firefighting flights, as well as flights before or after such flights which are carried out by the same aeroplane and are needed for these activities, are not included); and
• they are registered in one of the participating states (see the list as of 1 January 2026 here; notable omissions include India and China).

In 2010, the International Civil Aviation Organisation (ICAO), a United Nations Agency that sets global standards and regulations for international civil aviation, adopted a sectoral aspirational goal for carbon neutral growth from 2020 onwards. Whilst operational and technological improvements are seen as a key part of achieving this goal, the ICAO took the view that a market based scheme was required to fill the remaining emissions gap and to achieve carbon neutral growth. Accordingly, the International Standards and Recommended Practices for the implementation of CORSIA were adopted as an Annex to the Chicago Convention in 2016, to apply to all of ICAO’s 193 member states from 1 January 2019.

CORSIA is being implemented in three phases:

• The Pilot Phase (2021-2023) and the First Phase (2024-2026). During these phases participation by ICAO member states was voluntary. 126 member states participated, with flights between participating states subject to reporting and offsetting requirements.
• The Second Phase (2027-2035). During this phase, with some exemptions, such as for Least Developed Countries and Small Island Developing States, participation will become mandatory for all ICAO member states and all international flights will be subject to offsetting requirements. The Second Phase will be split into three-year compliance periods.

In scope airline operators are under the following obligations:

• To monitor and report emissions from international flights on an annual basis.
  • At the beginning of each 3-year compliance period, an operator is required to submit an Emissions Monitoring Plan to its administering state which, once approved, the operator will use for the entire compliance period.
  • Under the plan, the operator is required to monitor and record its fuel use for international flights over the course of each calendar year. The operator must then estimate their annual CO2 emissions and report them to the national authority of their administering state by 30 April the following year. To guarantee the accuracy of the data reported, operators will need their annual emissions report to be verified by an impartial third-party verification body prior to submission.
  • Aggregated emissions are required to be reported by each administering state to ICAO, which will publish the total emissions from individual operators.
• To offset their emissions.
  • Under the scheme, the administering state calculates the annual offsetting requirements for each operator by multiplying the operator’s CO2 emissions by a ‘Growth Factor’, which is calculated by the ICAO and represents the percentage growth of the aviation sector’s international CO2 emissions covered by CORSIA’s offsetting requirements in a given year compared to the sector’s baseline emissions (being 85% of 2019 emissions levels).
  • Upon completion of each 3-year compliance period, the operator will have to show they have met their offsetting requirements by purchasing and cancelling the appropriate number of certified CORSIA Eligible Emissions Units (“CEEUs”) (each representing a tonne of CO2). The price of these units varies considerably depending on the type of project ($0.50 to $45/tCO2e during 2020-2021 with a weighted average of $3.08/tCO2eq in 2021).
  • Operators can also reduce their offsetting requirements by using CORSIA Eligible Fuels (“CEFs”) that meet the CORSIA sustainability criteria, which includes fuels with at least 10% lower CO2e emissions on a life-cycle basis compared to a reference fossil fuel value of 89.1 gCO2e/MJ. It is worth noting that as the baseline for calculating emissions reduction targets is 85% of 2019 emissions levels, offsetting requirements will only cover the growth in emissions since 2019 and therefore it is anticipated that the percentage of their total emissions that operators will have to offset will remain modest for the first few years of implementation of the scheme.

For more information, please follow the link here.

Penalties and enforcement:

National aviation authorities of participating states determine the sanctions for non-compliance, so these vary between countries. In the UK, for example, typical civil penalties can include a £20,000 penalty with a further daily penalty of £500 for failing to: (i) apply or revise an emissions monitoring plan; (ii) monitor emissions properly; or (iii) submit emissions reports. In recent consultations, the UK government has indicated that the penalties for failing to cancel CEEUs on time in line with an airline’s offsetting requirements would be £100 for each uncancelled unit.