ReFuelEU Aviation: Aircraft operator obligations and best practices for monitoring and reporting

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ReFuelEU Aviation: Aircraft operator obligations and best practices for monitoring and reporting

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30 September 2025

Introduction

ReFuelEU Aviation (Regulation 2023/2405), adopted in October 2023 as part of the EU’s “Fit for 55” package, marks a significant step in reducing aviation’s carbon footprint. The regulation introduces mandatory SAF targets from 2025 and aims to curb tankering practices that drive unnecessary emissions. As the regulation moves into the next monitoring cycle, much will depend on how effectively aircraft operators prepare. While the first year revealed challenges such as data gaps and late submissions, these are expected to ease as operators gain experience and clearer guidance, paving the way for smoother compliance ahead.

Key Aircraft Operator Obligations Under ReFuelEU Aviation

Aircraft Operators subject to ReFuelEU Aviation are mainly those conducting over 500 commercial passenger flights or more than 52 commercial cargo flights departing from Union airports annually. Here are the main obligations for the aircraft operator:

Fuel Uplift Obligation: Aircraft Operators must ensure that at least 90% of the aviation fuel required for their flights is uplifted at Union airports. This requirement is designed to curb tankering – the practice of loading more fuel in an aircraft than needed at airports outside the EU.

SAF Blending Targets: ReFuelEU Aviation introduces progressive blending mandates for Sustainable Aviation Fuels (SAF), beginning with 2% in 2025, rising to 6% by 2030, and reaching 70% by 2050. The responsibility for meeting these targets lies with fuel suppliers, who must ensure the required SAF share is supplied at Union airports. Within these targets, specific quotas for synthetic fuels such as e-kerosene aim to drive a deeper transition toward renewable energy sources. Fuel suppliers must provide all necessary documents to aircraft operators by February 14th each year, and it is the responsibility of the aircraft operator to compile and store them as supporting evidence.

Annual Verified Reporting: Operators must submit verified annual ReFuelEU Aviation reports by March 31st for the previous calendar year. These reports must be submitted via EASA’s sustainability portal to the assigned Competent Authority and must be verified by independent third-party verifiers in accordance with EU ETS verification standards.

Penalties for Non-compliance: To ensure compliance with uplift obligations, the European Commission has established criteria for non-compliance penalties. Member State authorities will set penalties which will be at least twice the yearly average price of conventional jet fuel per tonne, multiplied by the total yearly non-tanked quantity. Aircraft operators not complying with the fuel uplift obligation must undertake these penalties.

Best Practices for Smooth Reporting under ReFuelEU Aviation

1. Early Data Preparation and Engagement with Verifier

Engage with the verifier as early as possible to avoid any last-minute delays and provide sufficient time for verifiers to carry out verification activities in the best way possible.

Operators must work on their data and documents actively throughout the year and submit the documents and data to the verifier at the beginning of the reporting year, ideally by the 2nd week of January.

Check with the respective Competent Authorities for Member-State-specific variations to the regulation, such as deadlines, guidance, and other procedural requirements.

Operators must ensure that they submit verified ReFuelEU Aviation reports along with the verification opinion statement to their respective Competent Authority by 31st March of the reporting year.

2. Comprehensive and Accurate Flight and Fuel Data Management

Operators must ensure that the sequence of flights for each aircraft registration is accurately maintained when recording or finalising flight data. This will help the accurate calculation of the yearly tanked quantity for fuel safety rules (Column H) values since it relies on input from the preceding flight.

Track data for wet-leased-out or wet-leased-in flights accurately, as this may be necessary to justify non-tanked quantities.

Clearly define the categorisation and definition of planned fuel values in the internal manuals or operations manual (Refer to EASA Accepted Means of Compliance (AMC), or ICAO Annex 6 “Operation of Aircraft”).

Ensure consistent use of fuel terminology across Operational Flight Plan (OFP), manuals, and flight and fuel data to enable accurate monitoring of required and safety fuels.

Identify valid secondary sources of data when primary data is not available, and in the absence of both, establish a procedure for addressing data gaps and erroneous entries.

In line with the EASA ReFuelEU Aviation Manual for Aircraft Operators and Verification Bodies, when the data gap threshold of 5% is exceeded, operators should connect with the Competent Authority to address the issue.

3. Identification for Exempted and Excluded Flights

Maintain Operational Flight Plans as evidence to claim exclusions.

Ensure that comprehensive records are maintained documenting all instances of serious and recurrent operational difficulties, which should be used for the purpose of supporting exemption requests. Submit exemption requests at least 3 months before the expected date of application of the exemption, supported by a detailed and adequate justification.

4. Implementation of the control activities

Operators are recommended to conduct weekly or monthly data quality checks within departments involved in ReFuelEU Aviation to ensure that there are no implausible values.

Conduct internal audits/pre-verification on procedures, systems, data quality, and storage.

Perform risk assessments and gap analysis to ensure efficient data monitoring and reporting.

5. Retention of Records and Supporting Evidence

Operators are required to store all Operational Flight Plans, which include NOTAMs, weather forecasts, etc., especially for flights departing and arriving in Union Airports for 4 years.

Store evidence of airports where flights have faced serious and recurrent operational difficulties for exemption applications.

Store all additional justifying documents, in case the 90% fuel uplift obligation, as specified in Article 5(1) of the ReFuelEU Aviation regulation (EU) 2023/2405, is not met.

Conclusion

ReFuelEU Aviation sets clear rules for airlines, wherein they should comply with the 90% fuel uplift requirement, a phased increase in SAF blending targets, and submit verified ReFuelEU Aviation reports annually. To reduce the challenges faced in the first monitoring period, operators should take early and proactive measures by enhancing internal awareness, seeking timely regulatory guidance, and maintaining efficient, high-quality data by prioritising early data preparation, accurate flight and fuel records, thorough documentation, and close collaboration with verifiers throughout the reporting process.