Infrastructure Briefing — January 11, 2026
ReFuelEU Aviation’s 2% sustainable aviation fuel blend applies from 2025, with 2026 audits focusing on fuel tracing, tank-farm readiness, and airline disclosure duties.
Executive briefing: Regulation (EU) 2023/2405 (ReFuelEU Aviation) began applying on January 1, 2025, mandating a minimum 2% sustainable aviation fuel (SAF) share by energy at EU airports and yearly greenhouse-gas reporting. The 2026 operating year brings the first full audit cycle of airport tank-farm upgrades, fuel certification records, and airline claims under the EU-wide book-and-claim system. Airlines and fuel suppliers must demonstrate traceability of SAF batches, lifecycle emissions values, and contractual penalties for short deliveries as verifiers review 2025 uplift data.
Compliance checkpoints
- Fuel procurement contracts. Verify that SAF supply agreements specify ASTM D7566 or equivalent certification, lifecycle greenhouse gas values, and remedies for non-delivery to avoid early shortfall penalties.
- Data collection. Align fuel receipt logs, blending certificates, and emission factors with the ReFuelEU templates that feed annual reports to the European Union Aviation Safety Agency and Member State authorities.
- Book-and-claim governance. Document any off-airport SAF purchases applied via book-and-claim, including registry identifiers, chain-of-custody attestations, and reconciliation with actual uplift at Union airports.
Operational readiness
- Tank-farm modifications. Confirm segregation, labeling, and filtration steps for blended fuel storage, including water detection and temperature monitoring to prevent microbial growth in higher-SAF blends.
- Quality assurance. Ensure refueler crews, airline maintenance teams, and third-party handlers follow joint inspection checklists for SAF batches, capturing density, aromatics, and additive limits.
- Passenger and crew disclosures. Prepare communications explaining SAF usage and any surcharge rationale, reducing the risk of mis-selling claims under consumer protection rules.
Evidence for 2026 audits
- Maintain reconciled monthly uplift statements that tie to SAF batch certificates, supplier invoices, and airport operator confirmations.
- Store deviation and incident reports for any fuel-quality events, remediation actions, and lessons learned from the initial 2025 operating year.
- Track Member State guidance on sustainability criteria validation to pre-empt findings during joint inspections with national aviation authorities.
Sources
Zeph Tech benchmarks SAF supply readiness, book-and-claim attestations, and airport infrastructure upgrades so airlines can withstand ReFuelEU Aviation compliance testing.