Private-Sector Perspectives on Article 6 and CORSIA Implementation
Private-sector Engagement with Article 6: Progress and Persistent Barriers
The implementation of Article 6 depends on various actors outside the negotiating rooms: the private-sector stakeholders who turn strategies, frameworks, and policies into operational carbon markets. These organizations interface directly with host parties on authorization procedures, corresponding adjustment accounting, credit quality standards, and market demand signals, giving them early, practical insight into where implementation is working and where it is not.
The A6IP Center conducted its private-sector survey from June to July 2026, distributed to A6IP Center private-sector partners with distribution support from the IETA; the IATA reviewed and provided feedback specifically on the CORSIA-related questions and section of the survey, along with feedback from other partner organizations. Of 64 raw submissions received, four duplicate entries were identified and removed, for a final total of 60 responses across 13 distinct organizational types, consultants, companies, project developers, NGOs, research organizations, independent carbon-standards bodies, banks, associations, and other respondent types, including universities, regional organizations, initiatives/partnerships, and UN agencies, representing 27 countries, with the largest single country concentrations from India (seven respondents) and the United States (six respondents). For the first time, the survey included a dedicated CORSIA section, routing the 20 of 60 respondents who reported engaging with CORSIA to a separate set of questions, enabling focused analysis of private-sector engagement with CORSIA linked to Article 6.
This survey relied on a partner-based sample rather than a random or comprehensive sampling frame, and a distribution list count was not retained for this survey cycle, so a formal response rate cannot be reported. Organization size (staff count or annual revenue) was not captured in this survey cycle. Given the sample’s size, composition, and distribution method, the findings presented in this chapter should be read as indicative perceptions among private-sector actors engaged with A6IP’s and IETA’s networks, rather than as representative of the global carbon market as a whole.
Challenges and Barriers to Article 6 Implementation
Survey responses revealed a diverse set of barriers and challenges private-sector encounters when engaging with host Parties for Article 6 implementation.
Fifty percent of respondents reported limited government capacity as a challenge/barrier, followed closely by incomplete authorization frameworks (48%) and uncertainty regarding corresponding adjustments (45%).
Lack of national Article 6 strategies or positive lists (42%), delays in LoAs issuance (37%), and absence of national registries or tracking systems (37%) also rank among the most pressing challenges.
Information Gaps and Support Needs: Insights from Open-ended Responses
Beyond the closed-ended survey questions, respondents were invited to describe in their own words the information gaps they face, followed by the practical support that would most help advance their Article 6 engagement.
Respondents highlighted harmonization of standards, capacity building, dedicated project-preparation facilities, risk mitigation instruments, and greater transparency as the support most likely to catalyze demand and supply-side engagement, seen as critical to scaling participation, strengthening demand signals, and building trust in Article 6 as a high-integrity framework for international carbon markets.
Information and Documentation Gaps Common themes from open-ended responses on information struggles
Requested Areas for Practical Support from Respondents Common themes from open-ended responses on practical support needs
Communication between Private Sector and Host Party Governments
Effective private-sector engagement requires structured, transparent communication and dialogue between market actors and host governments. Respondents were asked to rate the current level of structured dialogue between their organization and host government and the results point to significant challenges.
Only 32% of respondents rate current dialogue with host Party governments as “Good” or “Excellent”. “Moderate” is the most frequently reported dialogue quality at 37%. Eighteen percent of respondents report “poor” or “very poor” dialogue quality.
Authorization Condition Changes
A related concern emerges regarding the authorization conditions: whether host Party requirements remain consistent once a project is already underway.
When asked whether their organization has experienced situations where government authorization conditions changed after a project had begun, 32% of respondents answered affirmatively (19 of 60).
Twelve-Month Implementation Trends
To assess recent momentum in Article 6 implementation, respondents evaluated whether conditions in six key areas have improved, remained unchanged, or declined over the past 12 months. The percentages shown here are rounded and reflect the full sample of 60 respondents unless otherwise noted.
The clearest gains are in government institutional capacity and legal clarity. Institutional capacity improved for 55% of respondents with only 8% reporting decline. Legal and regulatory clarity followed closely, improving for 50% of respondents, with just 3% reporting decline.
Demand signals from governments, by contrast, remain largely stalled. Only 38% of respondents report improvement, while a slightly larger share (42%) report no change at all, indicating that private-sector interest has not yet been consistently matched by clearer government demand signals.
Progress on corresponding adjustment applications remains the most stalled area overall: 47% report no change over the past 12 months, with only 25% reporting improvement. This reflects technical complexity and continued uncertainty about host country interpretation of accounting requirements. While a growing number of Parties have established authorization arrangements (see Chapter 2.2), corresponding adjustment application is a distinct, downstream accounting process that continues to lag behind authorization framework development. Transparency of Article 6 reporting shows similarly mixed results, 42% report improvement, but an equal share report no change. Legal guarantees and insurance options show the most modest improvement of all six areas, with only 30% reporting gains and 43% indicating no change.
Market Development Priorities
When asked which developments in the next 12 to 18 months would most improve confidence in scaling Article 6 engagement, respondents could identify up to three developments.
Acceleration of the PACM emerges as the top priority for 45% of respondents. Integration into additional compliance schemes, most notably CORSIA, is expected by 42% of respondents, indicating recognition that Article 6 credits may satisfy requirements under multiple regulatory frameworks simultaneously. Bilateral cooperation acceleration is anticipated by 40% of respondents, suggesting continued confidence in bilateral pathways despite current implementation delays. Growth in sovereign (government) demand for internationally transferred mitigation outcomes is expected by 37% of respondents, while 30% anticipate growth in CORSIA credit unit demand. Notably, 30% also emphasize the importance of more host countries publishing authorization frameworks, a prerequisite to private-sector project development.
CORSIA
The following three sections (5.8–5.10) examine private-sector engagement with CORSIA specifically, a mechanism closely linked to Article 6.
CORSIA Engagement
Targeted Support to Unlock CORSIA Supply
The 2026 private-sector survey included questions specific to CORSIA engagement, recognizing CORSIA as an emerging implementation pathway linked to Article 6. CORSIA, which requires international aviation operators to offset emissions growth above a shared 2019 baseline (currently set at 85% of 2019 levels for the 2024–2035 period), has created demand for high-quality international credits that qualify under CORSIA eligibility requirements, expanding the opportunity for private-sector actors to be involved in the implementation of Article 6 through the use of ITMOs that are authorized for OIMPs and eligible for use under CORSIA.
Host Party support seen as key to unlocking CORSIA supply and strengthening Article 6.2 readiness
To assess private-sector engagement with this opportunity, respondents were asked whether their organization engages with CORSIA; the 20 who answered “Yes” were then routed to a dedicated set of CORSIA-specific questions (Sections 5.9–5.10), while the remaining 40 skipped ahead past those questions.
CORSIA Engagement: The Single Most Significant Barrier
When asked to identify the single most significant barrier their organization faces in engaging with CORSIA, 10 of the 20 CORSIA engaged respondents provided an open-ended response.
Barriers to CORSIA engagement, as described by respondents
CORSIA Specific Barriers and Support Priorities
For the 20 CORSIA engaged respondents, this section examines the specific barriers they encounter in engaging with CORSIA, followed by the direct assistance to host Parties they identify as most critical for unlocking CORSIA supply.
Host party capacity gaps related to CORSIA-specific authorization emerge as the most challenging barrier, with 55% rating this as “Very Challenging”. Uncertainty regarding future airline demand adds market risk, with 45% rating this as “Very Challenging”. Regulatory uncertainty, lack of clarity regarding Article 6 and CORSIA interactions follow, each cited by 30% as “Very Challenging”, while limited availability of eligible credits was least frequently rated as “Very Challenging” at 25%.
When asked which forms of direct assistance to host Parties would most effectively unlock CORSIA supply, CORSIA-engaged respondents prioritized Article 6.2, CORSIA consistency templates and tools and national inventory availability/NDC tracking readiness (55% each), followed by refining existing LoAs and timely Article 6.2 reporting (45% each).
Conclusion
The private sector is actively navigating the evolving Article 6 and CORSIA landscape as implementation progresses unevenly among Parties. The recurring thread across barriers, dialogue quality, twelve-month trends, and open-ended feedback alike highlights the importance of institutional development, capacity building, procedural clarity, and regulatory stability to build confident engagement and accelerate potential projects. Engagement with CORSIA reflects the same pattern at a smaller scale: real engagement (one-third of respondents) paired with similar underlying barriers related to authorization capacity and demand side uncertainty. As Article 6 markets mature and increasingly interlink with CORSIA, closing these capacity and information gaps, through embedded technical assistance, accessible platforms, and greater regulatory certainty, can contribute to accelerating and scaling the private capital needed to meet collective climate goals.
Endnotes
- Host Party Readiness Factors and Barriers to Article 6 Implementation: Respondents could select up to three of seven options, including “Other (please specify).” Percentages sum to more than 100%. n=60.
- Communication between Private Sector and Host Party Governments: Respondents selected one of six options, including “Not applicable to my organization.” n=60.
- Authorization Condition Changes: Respondents selected one of three options: “Yes,” “No,” or “Not applicable to my organization.” Twenty-five respondents (42%) selected “Not applicable to my organization.” n=60.
- Twelve-Month Implementation Trends: For each of six areas, respondents selected one response: “Improved,” “No change,” “Declined,” or “Not applicable/Unable to assess.” Percentages are calculated separately for each area and may not sum to 100% due to rounding. n=60.
- Future Improvements for Article 6 Scaling: Respondents could select up to three of ten options, including “Other (please specify).” n=60.
- CORSIA-Specific Challenges: Shown only to respondents who reported engaging with CORSIA. For each of five issues, respondents selected one rating: “Not challenging,” “Moderately challenging,” “Very challenging,” or “Not applicable/Unable to assess.” “Not applicable/Unable to assess” is not shown in the chart because no respondent selected it. n=20.
- Most Effective Direct Assistance to Host Parties to Unlock CORSIA Supply: Shown only to respondents who reported engaging with CORSIA. Respondents could select up to three of seven options, including “Other (please specify).” n=20.