As the use of sustainable aviation fuel (SAF) continues to grow under aviation regulations, the quality of documentation and traceability have become key considerations in SAF reporting and verification activities. Although SAF offers significant environmental benefits, operators must maintain accurate, complete, and verifiable data throughout the entire reporting period to demonstrate compliance with regulations. Based on our experience supporting aviation stakeholders in compliance and verification activities, several recurring challenges have emerged. Fortunately, many of these issues can be addressed through early planning and proactive collaboration with fuel suppliers and competent authorities.
Several issues have been identified in the documentation for sustainable aviation fuel (SAF), including inconsistencies in documents issued by different fuel suppliers, a lack of harmonization in document formats, Proof of Compliance (POC) documents issued after certificates had expired, and instances where POCs were issued, canceled, and then reissued. By highlighting these common documentation issues, we aim to raise awareness among operators and encourage them to contact their fuel suppliers well in advance to clarify and resolve any 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 mitigate the challenges associated with SAF reporting and verification is to contact fuel suppliers well in advance of the reporting deadline.
Operators should seek clarity on:
As previously mentioned, addressing these issues early can help prevent a last-minute influx of documents and reduce delays in reporting SAF-related emission reductions.
Since regulatory guidelines are constantly evolving, operators should proactively contact their respective competent authorities to gain insight into those authorities’ specific expectations, if applicable.
Attention should be paid to:
Gaining clarity before reporting begins can provide greater certainty and reduce the risk of non-compliance.
The lack of a standardized approach across the entire supply chain continues to pose 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 harmonization within the sector would improve transparency, reduce administrative complexity, and enable more efficient reporting and verification.
As SAF volumes increase, maintaining a dedicated SAF traceability record becomes essential for efficient reporting and verification. A structured traceability system enables airlines to record SAF quantities, supplier information, sustainability certificates, and supporting documentation in one place. This improves traceability, helps detect discrepancies early on, and provides a clear audit trail throughout the entire reporting cycle.
From a verification perspective, effective SAF tracking reduces the number of information requests, promotes data consistency, and enables 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 centralized system for tracking SAF transactions, the UDB can improve transparency, reduce inconsistencies in documentation, and strengthen confidence in sustainability claims.
As the sector continues to mature, a robust UDB framework will be crucial for 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 who engage with fuel suppliers early on, seek clarification from competent authorities, and implement robust document management practices will be better positioned to efficiently meet verification requirements.
Preparing today can significantly reduce the challenges of verification tomorrow—enabling operators to comply with regulations while supporting the sector’s broader sustainability goals.
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The implementation of ReFuelEU imposes obligations on fuel suppliers, Union airports and aircraft operators, which are discussed in the following subsections.
ReFuelEU Aviation (Regulation (EU) 2023/2405) is one of the European Union’s key measures to reduce aviation emissions by increasing the use of sustainable aviation fuels and discouraging economic refueling. For aircraft operators, Article 5(1) stipulates that at least 90% of the annual aviation fuel required for flights departing from an airport in the Union must be refueled at that airport in the Union. If this threshold is not met, Article 5(2) is invoked as justification, and EASA’s guidelines and monitoring tool support the monitoring and reporting process. The 2025 reporting year is also the first year in which competent authorities may impose penalties for non-compliance with Article 5(1) of the ReFuelEU Aviation Regulation 2023/2405. In 2024, the first reporting year, the biggest challenge was setting up the monitoring and reporting process itself. By 2025, the picture has become clearer. The question is no longer just whether operators are reporting, but what the reports reveal about compliance behavior and the quality of the justifications provided. That is where this year’s verified information comes in handy.
The UK Emissions Trading System (UK ETS) authority has launched a consultation to gather stakeholders’ views on the future treatment of SAF within the UK ETS framework, particularly in light of the introduction of the UK SAF mandate. The consultation examines potential changes to SAF eligibility criteria, sustainability requirements, greenhouse gas (GHG) reduction thresholds, and accounting methodologies, with the aim of strengthening policy alignment and supporting the decarbonization of the aviation sector.
The first phase of CORSIA is entering its final months. For most operators, the 2025 reporting cycle—which will be verified by independent bodies by April 30, 2026—represented the most demanding data processing operation since the program’s inception. However, a verified report is merely the “input” for a larger financial calculation. As 2026 progresses, the sector is operating in a two-track reality: Retrospective reconciliation: finalizing financial obligations for 2025. Forward-looking monitoring: Ensuring that the 2026 emissions year—the final year of the first phase—is tracked with absolute precision in the run-up to the April 2027 verification deadline.
Aviation Carbon 2024, co-organized by Normec Verifavia, successfully concluded on November 26, 2024, further solidifying its status as the longest-running “must-attend” sustainability event for the aviation industry. Thank you to all participants for making this possible! The conference brought together various stakeholders, including airlines, fuel suppliers, carbon market experts, policymakers, and environmental organizations, to discuss the latest developments in sustainability, compliance, and implications for the industry.
Freight transport contributes significantly to greenhouse gas emissions. Reducing these emissions is a challenging task due to the complexity and scale of freight networks. Although the financial burden often falls on freight carriers, shippers and logistics service providers (LSPs) can play a crucial role in alleviating this challenge. By collaborating with carriers, they can share the burden and demonstrate their commitment to a low-carbon economy. A promising approach to achieving this is through low-carbon fuel programs.
The European Union has taken a significant step toward achieving climate neutrality with the adoption of Regulation (EU) 2024/3012, establishing the Carbon Removal Certification Framework (CRCF).
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