Aviation & SAF
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Navigating SAF documentation: Common challenges and best practices
As Sustainable Aviation Fuel (SAF) adoption continues to grow under Aviation Regulations, documentation quality and traceability have become key areas of focus during reporting of SAF and verification activities. While SAF offers significant environmental benefits, demonstrating compliance requires operators to maintain accurate, complete, and verifiable records throughout the reporting period.
Based on our experience supporting aviation stakeholders with compliance and verification activities, several recurring challenges have emerged. Fortunately, many of these issues can be addressed through early planning and proactive engagement with fuel suppliers and competent authorities.
Several issues have been observed in Sustainable Aviation Fuel (SAF) documentation, including inconsistencies in documents issued by different fuel suppliers, lack of harmonization in document formats, Proof of Compliance (POC) documents issued after the expiry of certificates and instances where POCs have been issued, cancelled, and subsequently reissued. Highlighting these common documentation issues aims to raise awareness among operators and encourage them to engage with their fuel suppliers well in advance to clarify and resolve any potential concerns. Proactive coordination can help streamline the verification process, reduce delays, and save valuable time during verification activities.
One of the most effective ways to reduce SAF reporting and verification challenges is to establish communication with fuel suppliers well before the reporting deadline.
Operators should seek clarity on:
As mentioned already, addressing these points early can help avoid getting large number of documents at last-minute and reduce delays during SAF emissions reduction reporting.
As regulatory guidance continues to evolve, operators should proactively engage with their respective competent authorities to understand specific authorities’ expectations, if any.
Attention should be given to:
Obtaining clarification before reporting begins can provide greater certainty and reduce the risk of non-compliance.
The absence of a standardised approach across the supply chain continues to create challenges for operators, fuel suppliers, verifiers, and competent authorities. Inconsistencies in documentation formats, sustainability certificate requirements, and reporting practices can increase the burden on all parties involved. Greater harmonisation across the industry would improve transparency, reduce administrative complexity, and facilitate more efficient reporting and verification.
As SAF volumes increase, maintaining a dedicated SAF tracking file is becoming essential for efficient reporting and verification. A structured tracking system enables airlines to record SAF quantities, supplier information, sustainability certificates, and supporting documentation in a single location. This improves traceability, helps identify discrepancies early, and provides a clear audit trail throughout the reporting cycle.
From a verification perspective, effective SAF tracking reduces information requests, supports data consistency, and facilitates a more efficient assessment of SAF claims — ultimately strengthening compliance and reporting accuracy.
The Union Database (UDB) is expected to play an increasingly important role in SAF traceability and reporting. By providing a centralised system for tracking SAF transactions, the UDB has the potential to improve transparency, reduce documentation inconsistencies, and strengthen confidence in sustainability claims.
As the industry continues to mature, a robust UDB framework will be instrumental in supporting accurate reporting and long-term compliance.
The success of SAF reporting depends not only on fuel procurement but also on the traceability of supporting documentation. Operators that engage early with fuel suppliers, seek clarification from competent authorities, and implement robust document management practices will be better positioned to navigate verification requirements efficiently.
Preparation today can significantly reduce verification challenges tomorrow — helping operators achieve compliance while supporting the industry’s broader sustainability objectives.
