RefuelEU obligations for aviation operators

The ReFuelEU Aviation 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 Netherland. The NEa is responsible for enforcing the regulation and imposing fines for aircraft operators if found non-compliant.

When do I have obligations under the ReFuelEU Aviation regulation?

Aircraft operators are obligated when they operate at least 500 commercial passenger air transport flights, or 52 commercial all-cargo air transport flights from Union airports in the previous reporting period.

  • Where it is not possible to identify the aircraft operator, the owner of the aircraft bears the obligations
  • Union airports 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.
  • Privious period: 

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 list of aircraft operators and their administrative authorities is available here.


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 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.