India’s 90% Carbon Reporting Mandate: Legal Compliance Gauntlet for Airlines

For legal and compliance professionals in aviation, the DGCA's likely 90% emissions reporting mandate is not just an environmental rule—it's a new legal frontier. The requirement, aligned with CORSIA's mandatory phase from January 1, 2027, creates a binding reporting framework that exposes airlines to enforcement actions, audit requirements, and potential disputes over data accuracy. With both Indian and foreign carriers affected, the 'level playing field' clause raises questions about equitable application and the legal recourse available to operators facing disproportionate compliance costs.

India's Directorate General of Civil Aviation (DGCA) is poised to introduce a significant regulatory shift for international aviation by mandating carbon emissions reporting from aircraft operators. The move, which emerged from a high-level stakeholder consultation chaired by Union Civil Aviation Minister Ram Mohan Naidu, requires both Indian and foreign carriers to submit data covering at least 90% of their annual emissions from all international flights operating to and from Indian airports. This development aligns with India's preparations for the mandatory phase of the Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA), which begins on January 1, 2027, under the International Civil Aviation Organization (ICAO).

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Minister Naidu confirmed that India has committed to blending SAF with conventional jet fuel at 1% by 2027, 2% by 2028, and 5% by 2030 for all international flights.

The reporting mandate is designed to create a level playing field and prevent economic distortions among operators, according to sources familiar with the discussions. By capturing 90% of emissions, the DGCA aims to ensure comprehensive coverage that meets global standards while giving airlines sufficient lead time to establish robust monitoring, reporting, and verification (MRV) systems. For many carriers, especially smaller regional players, this will entail significant operational adjustments, including the deployment of digital tools for real-time emissions tracking and the hiring of sustainability officers. The 90% threshold also mirrors similar requirements under CORSIA, where countries are expected to cover substantial portions of international aviation emissions.

Central to the policy thrust is the accelerated adoption of Sustainable Aviation Fuel (SAF). Minister Naidu confirmed that India has committed to blending SAF with conventional jet fuel at 1% by 2027, 2% by 2028, and 5% by 2030 for all international flights. These targets are ambitious, as the global SAF market remains nascent, with production volumes a fraction of conventional jet fuel. India is proactively addressing the supply side: state-owned Oil Marketing Companies (OMCs) are collaborating to scale up domestic manufacturing, with the Panipat and Mumbai refineries reportedly in the final stages of SAF readiness. The government also intends to bring private industry into SAF production, signaling a broader public-private partnership approach. However, challenges persist, including high production costs, feedstock availability, and certification of new fuel pathways. The phased blending targets give industry time to scale, but the 5% target by 2030 will require a massive ramp-up in both capacity and distribution logistics.