ReFuelEU Aviation: Compliance Obligations and Regulatory Reporting

Fuel suppliers, aircraft operators and airport managers

Secure your ReFuelEU Aviation compliance and reporting with FISCALEAD.

Regulation (EU) 2023/2405, known as ReFuelEU Aviation, is part of the EU Fit for 55 package and introduces mandatory and progressively increasing Sustainable Aviation Fuel (SAF) blending quotas from 2025 for aviation fuel supplied at EU airports.

The regulation applies across the aviation value chain, covering fuel suppliers, aircraft operators and airport managers. In France, compliance is supervised by the Directorate General of Customs and Indirect Taxes (DGDDI) for fuel suppliers and by the French Civil Aviation Authority (DGAC) for aircraft operators and airport managers.

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What is the ReFuelEU Aviation Regulation?

ReFuelEU Aviation is a key pillar of the EU Fit for 55 legislative package, designed to decarbonise air transport by ensuring the progressive and traceable incorporation of Sustainable Aviation Fuels (SAF) at EU airports.

It establishes a harmonised EU-wide framework requiring aviation fuel suppliers to gradually increase the share of SAF blended into conventional jet fuel, while setting compliance and reporting obligations across the aviation value chain.

The regulation entered into force on 1 January 2024. Mandatory blending requirements and reporting obligations fully apply as of 1 January 2025.

Fuel suppliers: your ReFuelEU Aviation obligations

Under ReFuelEU Aviation, fuel suppliers play a central role in the decarbonisation of air transport, as they are responsible for ensuring the availability and compliant blending of Sustainable Aviation Fuels (SAF) at Union airports.

 

Implementation timeline

  • Regulation in force since 1 January 2024
  • Mandatory quotas and reporting obligations applicable from 1 January 2025

 

Minimum SAF / CAD blending quotas

  • 2025: 2% SAF
  • 2030: 6% SAF, including a minimum of 0.7% synthetic aviation fuels (annual average of 1.2% over 2020–2031)
  • 2050: 70% SAF, including 35% synthetic fuels

These obligations apply to aviation turbine fuel, excluding aviation gasoline at this stage.

Key interim target: achieving 1.2% synthetic aviation fuels across all EU airports by 2030.

 

Reporting obligations

Fuel suppliers must submit an annual declaration covering volumes supplied during the previous calendar year.

Deadline: 14 February 2026 for fuels supplied in 2025.

The information to be reported includes in particular:

  • volumes of aviation fuel and SAF supplied;
  • fuel types and technical characteristics;
  • origin of raw materials;
  • lifecycle emission factors and energy content;
  • aromatic and sulphur content.

Fuel suppliers must also provide aircraft operators with all data required for their own ReFuelEU Aviation reporting.

 

Penalties

In the event of non-compliance, penalties may include:

  • a fine of at least 2 × (average SAF / JET price differential × non-compliant volume);
  • an obligation to compensate any blending shortfall in the following year.

A French implementing decree is currently under preparation.

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ReFuelEU Aviation obligations for aircraft operators

Aircraft operators are subject to specific requirements primarily aimed at preventing economic fuel tankering practices and ensuring transparency of fuel and emissions data. These obligations apply to operators operating flights departing from Union airports and exceeding the applicable activity thresholds during the reporting year.

Key obligations include : 

  • uplifting at least 90% of annual fuel needs at EU airports;
  • submitting an annual ReFuelEU Aviation declaration by 31 March;
  • reporting uplifted fuel quantities, SAF purchases, fuel characteristics and associated lifecycle emissions.

While SAF blending mandates apply to fuel suppliers, aircraft operators remain responsible for complying with the uplift rule and for providing accurate, verifiable data as part of the ReFuelEU Aviation reporting framework.

 

ReFuelEU Aviation obligations for airport managers

Airport managers must:

  • ensure effective access to fuels that comply with ReFuelEU Aviation quotas;
  • cooperate with fuel suppliers to resolve any supply difficulties;
  • be able to demonstrate compliance in the event of an inspection, as liability may be incurred in case of failure.

Why is ReFuelEU Aviation compliance complex?

The ReFuelEU Aviation regulation intersects multiple regulatory and operational dimensions:

  • sustainable fuel sourcing;
  • mass balance monitoring;
  • supply chain traceability;
  • energy taxation and excise duties;
  • customs and ESG-related data requirements.

Stakeholders must consolidate data from multiple sources (ERP systems, ISCC+ / RED II certificates, flight logs, airport inventories) and report them through various channels: Union Database, DGDDI declarations, internal audits and ESG reporting frameworks.

 

Without a robust and secure process, financial, regulatory and reputational risks can be significant.

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How FISCALEAD supports your ReFuelEU Aviation compliance

Active at major French airports (CDG, Orly, Le Bourget, Lyon…), FISCALEAD supports aviation industry stakeholders in the operational implementation of ReFuelEU Aviation requirements, with a strong focus on customs, excise duties and data reliability.

Our services

  • Compliance diagnostics: mapping of fuel flows, contracts and data sources against ReFuelEU Aviation and DGDDI requirements.
  • Integrated excise & ReFuelEU support: preparation, alignment, electronic filing and follow-up of formalities (energy excise duties / ReFuelEU), and liaison with customs authorities during audits.
  • ReFuelEU planning: regulatory monitoring, alerts and anticipation of critical thresholds to mitigate compliance risks.

Your benefits

  • 360° compliance: alignment of excise and ReFuelEU Aviation reporting.
  • Time savings and risk mitigation through combined regulatory, customs and data expertise.
  • Audit-ready traceability: full documentation supporting declarations.
  • Dedicated human support: customs & excise experts and data analysts with a pragmatic, operational approach.

 

FISCALEAD holds and operates its own energy excise authorisations and files petroleum tax declarations on its own behalf or on behalf of its clients with the main French customs offices (Le Havre, Dunkirk, Roissy, Marseille, Tours, among others).

We also have extensive experience across multiple TIRUERT compliance campaigns, now articulated with the ReFuelEU Aviation framework.

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Need to secure your ReFuelEU Aviation compliance?

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FISCALEAD

Founded by Marcie REYNO-DALLE and Alexandra LOUYOT, FISCALEAD provides operational assistance in indirect taxation: Customs, Excise and VAT. With many years’ experiences in both big 4 law firms and in-house, our team is experienced in a wide range of international business models, industries, and supply chains.

Committed to listening to your operational needs, we put our technical expertise at the service of your logistical, IT and HR realities.

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