Compliance with the ReFuelEU Aviation Regulation in 2025: Verification Scope and Compliance Patterns

Verification Scope and Compliance Patterns

A total of 165 airlines were verified by Normec Verifavia under the ReFuelEU Aviation Regulation for the 2025 reporting year, representing approximately 42% of all operators covered by the regulation. Together, these operators accounted for 22.54 million metric tons of aviation fuel required per year, 22.88 million metric tons of fuel refueled at airports within the Union, and 0.152 million metric tons of annual refueling volumes under fuel security rules.

Before delving deeper into the figures and compliance patterns, it is important to revisit how compliance with the ReFuelEU Aviation Regulation works.

• Article 5(1) stipulates that an aircraft operator must refuel at least 90% of the required fuel at a Union airport. If this requirement is not met, Article 5(2) of the Regulation allows aircraft operators to justify the corresponding “unrefueled quantities” reported in Column H (Annual unfueled quantity under fuel safety rules). This provision acknowledges that an operator may not always be able to meet the 90% requirement due to operational constraints or other legitimate operational reasons.

The compliance results reveal several clear compliance patterns that go beyond a simple assessment of “compliant” or “non-compliant.” Of the audited group, 16% of operators complied with Article 5(1) by meeting the 90% refueling requirement. 20% of the operators did not meet the 90% threshold but were able to account for all unreplenished quantities. 60% of operators could justify only a portion of the reported refueling shortfall, while 4% of operators could not justify the refueling shortfall at all.

This provides a more realistic picture of how ReFuelEU Aviation functions in practice. The verified figures show that full compliance remains difficult for many operators, but they also demonstrate that non-compliance does not always indicate a weak case. In many cases, the issue is not the existence of unfueled quantities per se, but whether those quantities are justified in light of the “annual fueling quantities for fuel safety regulations” and are supported by accurate data recording and supporting evidence.

The key message from this initial layer of analysis is simple: compliance is not just about how much fuel has been dispensed, but also whether the operator can account for the difference when there are shortfalls.

We also note that the largest number of operators fall into the “partially justified” category, which implies that most operators had difficulty justifying all the unfueled quantities they encountered. This is where the quality of reporting becomes just as important as the operational result itself.

The Role of Justification Under Article 5(2)

One of the clearest patterns in the 2025 reporting year is that the quality of justification now makes the difference between operators with manageable non-compliance and operators at risk. Operators with a complete justification were generally able to demonstrate that the untanked volumes were related to operational or safety-related considerations and that the supporting evidence was available and traceable. In those cases, the verification process largely revolved around confirming that the explanation corresponded to the reported data. The more challenging cases involved partial justifications (where operators could justify unfueled quantities at some airports but not at all of them). These were the reports in which sufficient evidence was provided for some airports but not for others. In several cases, these usually point to gaps in record-keeping or inconsistent data collection, rather than a complete lack of an operational reason.

The smallest but most vulnerable group is the one that could not justify the unfueled quantities at all. In those cases, the report may still contain a reason for the refueling behavior, but without the evidence needed to substantiate it, the outcome remains weak from a compliance perspective.

Conclusion

This year’s ReFuelEU Aviation report provides valuable insights into how aircraft operators are implementing the regulation and demonstrating compliance. Although some operators at all relevant airports in the Union complied with the refueling obligation under Article 5(1), many invoked justifications under Article 5(2) to account for the fuel quantities that were not refueled. The results underscore the importance of sound record-keeping, accurate fuel data, and well-documented supporting evidence in demonstrating compliance.