Navigating SAF documentation: Common challenges and best practices

Challenges faced

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. 

Engage with fuel suppliers early 

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: 

• The SAF documentation that will be provided 
• Sustainability certificates supporting the SAF volume 
• The expected timeline for certificate delivery, including whether certificates will be issued monthly, quarterly, or at year-end 

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. 

Clarify regulatory expectations 

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: 

• Acceptance of sustainability documents (For e.g. some authorities accepted Product Transfer Documents) 
• Eligibility of specific feedstocks not listed in the Renewable Energy Directive (EU) 2018/2001 for e.g.  Animal Fat Cat 3 
• Additional reporting instructions for future compliance years 
• Expectations related to supporting evidence and SAF claims 

Obtaining clarification before reporting begins can provide greater certainty and reduce the risk of non-compliance. 

The challenge of harmonisation 

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. 

The importance of SAF tracking 

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. 

Looking ahead: The role of the Union Database 

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.

Conclusion 

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.