SAF Mandate Complicates European Bizav’s Green Intentions

The European business aviation sector continues to insist that the European Commission’s ReFuel EU mandate for increased SAF usage is a blunt instrument that is not fit for purpose. At the same time, Europe’s airlines agree with the Airlines for Europe and European Regions Airline Association calling for changes to the rules in mid-March.

From January 2025, ReFuel EU mandated the use of 2% blended SAF at EU airports, rising to at least 6% by 2030 (of which 0.7% must be e-fuel). However, the physical unavailability of SAF at many smaller airports serving business aviation—along with a lack of recognition for book-and-claim options—is only part of the problem.

Operators flying into and within Europe are also mandated to refuel at least 90% of their annual fuel requirements from EU airports. According to EBAA EU affairs manager Federico Ricci Buffetti, this has “created a huge administrative burden for business aviation…which, in a way, endangers the business model of our sector.”

Compliance tensions are underpinned by what Buffetti perceives as “inconsistent application of this regulation by civil authorities,” with different compliance schemes—including CORSIA and the EU Emissions Trading Scheme (EU ETS)—requiring conflicting data and calculation methodologies.

“Operators are really struggling with consolidating the data that they need and putting that into the required templates for the different reports,” stated Puja Mahajan, CEO and co-founder of climate tech software provider Azzera. The company’s proprietary aviation-specific Celeste software platform provides what the company terms an “all-in-one solution for emissions measurement, compliance management, and reporting.”

When Azzera launched in 2021, “the real genesis was voluntary action for sustainable sustainability,” Mahajan explained. “Almost 50% of [business aviation] operators now have some sort of SAF solution or voluntary carbon credit solution, whereas maybe two years ago, that was 15% of the market.”

Another aviation sustainability support provider, 4Air, leverages its expertise to support large and small operators navigate and manage compliance. The company believes that while regulation has “really pushed the industry in the right direction,” the regulatory landscape has become increasingly complex since around 2020.

The fast pace of evolving regulation means it’s imperative for operators to stay informed of ongoing compliance responsibilities, with 4Air European program manager Maureen Gautier stressing that “it’s more important to be proactive than reactive.”

That task, according to EBAA’s Buffetti, is easier said than done. He told AIN that the European Commission was very late in presenting guidelines regarding what was accepted for the justifications, and exemptions are also complicating compliance efforts.

“ICAO is trying to simplify [regulation] on the international level, but we still have the specifics and politics of each region that are very important,” continued Gautier, who described the potential recognition of a SAF book-and-claim system as a “win-win.” This would help combat the ongoing shortfall in SAF supply by allowing climate benefits to be purchased independently from the physical fuel.

However, Gautier believes regulatory reticence to do so comes from a worry over fraudulent certificates and concerns of erroneous double-counting. Nonetheless, with workable solutions in place, she hopes the 2027 review of ReFuelEU and ETS will open up the discussion once more.

The European Commission’s sustainable transport investment plan, published in late 2025, included “the willingness to assess the feasibility of a book and claim system…but most importantly, the opportunity to simplify review reporting requirements,” explained Buffetti. Alongside the EBAA’s work to inform operators via its own compliance guide, the association’s ReFuelEU working group sees an “important opportunity to influence this simplification.”

More than 300 EBAA members signed an open letter to the EU commissioner for sustainable transport and tourism, Apostolos Tzitzikostas, calling for changes to the rules. Buffetti said this represented a strong starting point for what the group hopes will be more constructive dialogue on this important topic.