What ReFuelEU simplification could mean for operators

By Federico Ricci Buffetti, EU Affairs Manager EBAA 

When the European Commission announced in November 2025, through the Sustainable Transport Investment Plan (STIP), that it intended to simplify the anti-tankering provisions of ReFuelEU Aviation, it sent an important signal. Brussels had finally acknowledged that the current compliance framework is creating real operational friction for operators.

The anti-tankering rule in Article 5 was introduced with a legitimate objective, namely to prevent operators from avoiding SAF-related obligations by carrying fuel from outside the EU. Yet, in practice, its implementation has proven far more complex than anticipated. What was designed as an environmental safeguard has, for many operators, turned into a demanding compliance exercise requiring extensive documentation, multiple justifications and significant internal resources.

Business aviation feels the burden particularly strongly

This is especially true for business aviation. Unlike scheduled airlines, business aviation operates on demand, across a highly fragmented airport network, with frequent short-notice changes and a strong presence of SMEs. Applying a framework largely built around scheduled traffic patterns to this operating model has inevitably created mismatches.

That is why EBAA has continued to push for a more proportionate and workable approach. In recent months, the association has consulted closely with its dedicated ReFuelEU Working Group, bringing together operators and regulatory experts from across the sector. That work is now feeding into a new EBAA position paper, which is about to be published and will serve as the association’s reference point for calling on the Commission to simplify the compliance framework in an operationally realistic way.

A new position paper is about to be published

The paper focuses on several areas where operators have clearly identified disproportionate burdens. These include: 

• the need for a de minimis threshold for low-frequency operations;
• more workable exemption arrangements
• staggered reporting deadlines;
• improvements to the handling of Proofs of Compliance;
• greater legal certainty around the Union airport list, and practical fixes to the EASA reporting template and portal.

The underlying message is straightforward. Simplification should not mean weakening the environmental objective of the Regulation, but making it work better in the real world.

At this stage, the Commission is expected to publish its proposal for the fast-track simplification of ReFuelEU Aviation in September 2026. That makes the coming months particularly important for operators and representative associations seeking to ensure that the practical realities of implementation are properly reflected.

The 2027 review will bring a broader debate

At the same time, the fast-track simplification exercise is only one part of the wider picture. A more comprehensive review of ReFuelEU Aviation is due in 2027, and one of the most closely watched questions in that context is the possible introduction of a book-and-claim system for SAF.

On this file, the Commission has tasked EASA, supported by consultancy ICF, with exploring the feasibility of such a system. Early indications suggest that the design currently being considered would rest on three main pillars.

The first is the extension of the Union Database to all actors across the value chain, including aircraft operators, in order to ensure full traceability and transparency of SAF-related transactions. The second is the issuance of SAF certificates linked to a corresponding batch of fuel when fuel is supplied to a Union airport. The third is that these certificates could then be traded among fuel suppliers and aircraft operators, but only at Union airports and only within the borders of a Member State, with the associated environmental benefits being claimable under ETS and CORSIA.

A narrow design would be a problem for business aviation

At first glance, this may appear to be progress. But for business aviation, there is a major concern: the exclusion of non-Union airports from the scope of such a future system.

This would be highly problematic for the sector, given that around 50 to 60% of business aviation flights depart from non-Union airports. In other words, a large part of the business aviation operating model would remain outside the practical reach of book and claim. That would significantly reduce the value of the system for operators whose networks are geographically dispersed and whose access to physical SAF uplift is already structurally more limited than that of airlines concentrated at large Union hubs.

The rationale currently being put forward for excluding non-Union airports is that these airports may have insufficient resources to oversee a book-and-claim process effectively, and that national aviation authorities have limited visibility over the operations taking place there. While these concerns should not be dismissed, the consequence of such a narrow design would be to make access to SAF even more difficult for a sector that is already under close scrutiny for its environmental footprint.

EBAA is working on alternatives

This is why EBAA, together with GAMA, is exploring alternative solutions that could allow non-Union airports to be meaningfully reflected in a future system, while preserving traceability and regulatory integrity. The objective is clear: if book and claim is to become a serious decarbonisation tool for business aviation, it cannot be designed only around the operating realities of scheduled airline networks.

The coming months will be important

The months ahead will therefore matter on two fronts. In the short term, the fast-track simplification process offers an opportunity to make ReFuelEU more workable for operators already struggling with its day-to-day implementation. In the medium term, the debate on book and claim will shape whether the Regulation can genuinely support SAF uptake across all parts of aviation, including those, like business aviation, that operate far beyond the major Union airport system.