ReFuelEU Aviation
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ReFuelEU Aviation Compliance in 2024: Verification Coverage, Challenges, and Upcoming Requirements From The Operators
ReFuelEU Aviation (Regulation 2023/2405) is the EU’s bold initiative to decarbonise air travel by facilitating greater use of Sustainable Aviation Fuels (SAF) and reducing inefficient economic tankering. In 2024, 358 operators were subject to the ReFuelEU requirements, and Normec Verifavia independently verified 128 of them—capturing a 35.8% market share. However, only 14 of the verified operators complied with the critical Article 5(1) requirement—achieving at least 90% of their fuel uplift at Union airports. This gap highlights widespread challenges in data monitoring and operational planning. As there will be penalties for non-compliance in the upcoming year, early action, accurate reporting, and effective verification practices will be essential for meaningful compliance and progress towards greater use of sustainable aviation fuels.
In 2024, a total of 358 operators were subject to the ReFuelEU Aviation (RFEUA) requirements. As a verifier, Normec Verifavia conducted independent verifications for 128 of these operators, ensuring that the data reported aligns with the regulatory standards outlined in the RFEUA framework. However, among the 128 operators verified, only 14 operators successfully met the key requirement set out in Article 5(1) (Operators must uplift at least 90% of the aviation fuel required for their flights at Union airports during the reporting period) of the regulation. The low compliance rate among verified operators indicates that there are many cases with operational constraints, fuel availability issues, or routing limitations preventing aircraft operators from uplifting 90% of their required fuel at Union airports. This highlights the importance of accurately monitoring flight data and related documentation. Since ReFuelEU Aviation will have penalties starting next year, early action on data accuracy will be important to ensure successful compliance with the regulation.
This chart shows that while 358 operators were subject to ReFuelEU requirements, 128 were verified by Normec Verifavia, representing a 35.8% market share for ReFuelEU
Unclear Guidance on Data Gaps: A key challenge for operators was the unclear guidance on managing data gaps in their flight records. The lack of standardised procedures led to a variety of approaches being implemented by different operators. Verifiers then had to navigate these inconsistencies during the verification process, which affected the consistency of the reported data.
Delayed Data Submission: Many operators submitted their data at the last minute, significantly delaying the verification process. These delays were often due to misunderstandings about the specific data points and methodologies required under ReFuelEU Aviation. Furthermore, difficulties in sourcing critical documents by the operator —such as the final operational flight plans, fuel slips, tech logs, ACARS messages, etc. —added to the challenge and hindered timely submission.
Incomplete Fuel Data Reporting: In several cases, key fuel-related data points necessary for accurate calculations were missing. The lack of data regarding contingency fuel, alternate fuel, and block fuel hindered operators’ ability to justify their safety fuel levels, which in turn limited the scope of the operator’s reporting.
Comprehensive Data Collection: Operators must systematically collect and monitor all essential fuel-related data, including trip fuel, taxi fuel, fuel uplift, block off and block on fuel, and all additional safety fuels (e.g., contingency fuel, final reserve fuel, alternate fuel, discretionary fuel, etc.). Data for the preceding flight must also be available to justify cases where the 90% yearly monitoring requirement is not met at a particular Union airport.
Exemption Requirements: The ReFuelEU Aviation regulation acknowledges that strict adherence to the 90% fuel uplift mandate may not always be feasible due to legitimate operational and safety considerations. To address this, the regulation provides for various exemptions and justifications, all managed through the EASA Sustainability Portal. These include route-based exemptions, based on serious and recurrent operational difficulties, such as limited ramp space impacting the turnaround time, and structural fuel supply difficulty due to geographical constraints. For any instance where the 90% uplift threshold is not met due to compliance with fuel safety rules, aircraft operators must provide detailed justification to their competent authority and EASA.
Timely Reporting and Verification: To ensure sufficient time for verification, fuel data should be submitted to the verifier by 15th January of the reporting year at the earliest. This ensures that the verification process is completed well ahead of the annual reporting deadline of 31st March, which operators are required to meet.
The EASA’s ReFuelEU Aviation Sustainability Portal serves as a central platform for aircraft operators and competent authorities. Aircraft operators can utilise the portal to manage the exempted flight approvals and report data related to their RefuelEU obligations at Union airports. The Competent Authorities of the EU Member States can review the exemption requests submitted by the aircraft operators through the ReFuelEU Aviation Sustainability Portal. When logged in, it is possible to access the manuals and frequently asked questions (FAQs) available in the portal itself.
The first year of ReFuelEU Aviation has shown that while the regulation sets a strong direction towards the use of sustainable aviation fuels and cracks down on economic tankering, many operators are still facing challenges with data accuracy, fuel planning, and timely reporting. With only a few operators currently meeting the key fuel uplift requirement, it’s clear that better data management and early action will be essential. As penalties for non-compliance begin next year, operators should work closely with verifiers to ensure smooth and successful reporting in future.
