Obligations for aircraft operators

The ReFuelEU Aviation regulation is a part of the European ‘fit for 55’ package aimed at reducing net greenhouse gas emissions by at least 55 % by 2030 compared to 1990 levels. The regulation came into effect on January 1, 2024. The Dutch Emissions Authority (NEa) is the competent authority for aircraft operators falling under administration of the Netherlands for the ReFuelEU Aviation regulation. The NEa is responsible for enforcing the regulation and imposing fines for aircraft operators if found non-compliant.

Below is an overview of the first compliance cycle:

Timeline ReFuelEU Aviation

Timeline ReFuelEU Aviation
1 January 2014ReFuelEU Aviation regulation in effect
1 January - 31 December 2024Keep track of fuel reporting data and SAF purchases and claims
31 March 2025Submit a verified ReFuelEU Aviation report  
Nea Source table as .csv (229 bytes)

When do I have obligations under the ReFuelEU Aviation regulation?

The regulation applies to commercial air transport flights. Aircraft operators are obligated when the following criteria apply:

  • Aircraft Operator operates at least 500 commercial passenger air transport flights, or 52 commercial all-cargo air transport flights from Union airports in the previous reporting period or,
  • Where it is not possible for that person to be identified, the owner of the aircraft.

Union airport is defined as airports where passenger traffic was higher than 800 000 passengers or where the freight traffic was higher than 100 000 tonnes in the previous reporting period, and is not situated in an outermost region.

The European Commission will publish a list of obligated aircraft operators yearly. The list is compiled based on Eurocontrol data in the respective reporting year minus 2 years. That means that the initial list of obligated operators is based on 2022 flight data from Eurocontrol. The first list is expected to be published by the European Commission in Q1 of 2024.


For aircraft operators not fulfilling the definition of an aircraft operator, it is possible to opt-in for the purposes of ReFuelEU aviation. If you wish to opt-in please notify the NEa.

What are my obligations as an aircraft operator?

The obligations of aircraft operators under the ReFuelEU Aviation regulation are defined in articles 5, 8 and 9:

  • Article 5 Refuelling obligation for aircraft operators
  • Article 8 Reporting obligations for aircraft operators
  • Article 9 Aircraft operator claiming of use of SAF

Obligations of aircraft operators are further explained below:

Refuelling obligation

The yearly quantity of aviation fuel uplifted per obligated aircraft operator at Union airports shall be at least 90 % of the yearly aviation fuel required.

The yearly aviation fuel required refers to the amount of fuel in tonnes that is required to operate all flights covered by the RefuelEU Aviation regulation. These are flights departing from union airports over the course of the reporting period. It includes ‘trip fuel’ and ‘taxi fuel’ defined by Annex IV to commission regulation 965/2012 (14).

In order to determine if you have achieved uplifting 90% of the yearly aviation fuel required for flights in scope of the ReFuelEU Aviation regulation, you need to keep track of and report the following per union airport:

  1. Total number of flights operated departing from the Union Airport;
  2. Total flight hours operated departing from the Union Airport;
  3. Yearly aviation fuel required;
  4. Yearly actual aviation fuel uplifted;
  5. Yearly non-tanked quantity;
  6. Yearly tanked quantity for fuel safety rules.
Image: ©Nea
Figure 1 Fuel Reporting ReFuelEU Aviation

Reporting obligations and claiming use of SAF

By march 31st each year, obligated aircraft operators report on the quantities of uplifted fuel per union airport. The first reporting deadline is march 31st 2025 on fuel uplifted between January 1st – December 31st 2024.

In addition, information on sustainable aviation fuel (SAF) purchases and where claimed must be reported. The report also includes a declaration that sustainable aviation fuel has not been double claimed in multiple greenhouse gas (GHG) schemes. Required information on SAF purchases includes:

  • Details of the fuel supplier, specific batch number and amount SAF purchased in tonnes.
  • For each batch: feedstock and lifecycle emissions, and amount claimed per GHG scheme (e.g. EU ETS, CH ETS)
Image: ©NEa / NEa
Figure 2 SAF Purchase Reporting ReFuelEU Aviation

The ReFuelEU Aviation reporting template for aircraft operators is available for download here.  EASA is working on a digital reporting tool for aircraft operators that will incorporate the reporting template. More details on the tool and practical reporting aspects will be shared at a later stage. To follow developments on the tool more information is available here.


Article 5 defines possible exemptions to meeting the 90% required refuelled quantity at a given union airport. More information about potential exemptions will be published at a later date as the European Commission is still working on developing further guidance on exemption rules.


The NEa is the competent authority responsible for enforcement of compliance with the refuelling obligations by aircraft operators. Aircraft operators failing to comply are liable to a fine.  More information about fines will be published at a later date, as implementation on this aspect in national Dutch legislation is still in development.