What EASA’s Annual Report Establishes

Under ReFuelEU Aviation (Regulation EU 2023/2405), fuel suppliers serving EU airports must meet escalating SAF blending obligations starting at 2% in 2025, rising to 6% by 2030 and 70% by 2050. EASA’s 2026 Annual Report is the first statutory compliance snapshot under this framework. The confirmed 2.8% outturn — 0.8 percentage points above the floor — demonstrates that aggregate supply chains met the regulation’s first binding test, though sector analysts note that passing the 2025 threshold does not de-risk the far more demanding 2030 ramp, which requires tripling the blend share in five years and introduces a dedicated e-SAF sub-mandate of 1.2%.

For compliance officers, the report’s significance extends beyond the headline figure: it establishes EASA’s role as the central data collector and audit body, defining how fuel volumes are reported, attributed to airports, and verified against RFNBO and advanced-biofuel certification schemes under RED III. Operators and fuel suppliers that have invested in AI-assisted compliance platforms to automate ReFuelEU reporting workflows now have a concrete regulatory dataset against which to benchmark their tracking logic.

The e-SAF Sub-Mandate Integrity Fight

Timing the EASA report is a live regulatory dispute with direct bearing on how future compliance figures will be calculated. An industry coalition published an open letter to the European Commission on 16 September 2026 warning against a proposed interpretation that would allow electrolytic hydrogen used in biofuel hydrotreatment — rather than in full power-to-liquid synthesis — to count toward ReFuelEU’s e-SAF sub-mandates. The coalition characterises this as a ‘dangerous regulatory precedent’ that could allow the e-SAF obligation to be met with fuels that are biogenic in origin rather than genuinely electrofuel, diluting the additionality logic underpinning RFNBO certification and RED III’s renewable fuel of non-biological origin rules.

The Commission’s ruling on this question will materially affect which volumes qualify for the 2030 e-SAF sub-mandate and, by extension, how airlines and fuel suppliers account for their exposure. Legal teams advising aviation clients should treat this as an open certification-scope question that the 2026 Annual Report does not resolve.

What Overperformance Does and Does Not Prove

A 2.8% blend share is commercially significant: it shows that sufficient certified SAF — predominantly HEFA today — reached EU airports at the regulated scale without a market failure. It also generates a compliance surplus that some operators may seek to bank or trade, depending on how the Commission interprets ReFuelEU’s flexibility provisions. What it does not demonstrate is readiness for the post-2030 trajectory, which depends heavily on PtL e-SAF capacity that remains in early commercial deployment globally.

The 2025 result nonetheless strengthens the hand of ReFuelEU proponents in Brussels, offering concrete evidence that mandatory blending — rather than voluntary corporate commitments — drives supply. The EASA data will feed directly into the Commission’s 2026 review of the regulation’s trajectory, making this Annual Report one of the more consequential policy documents in EU aviation sustainability governance this year.

Sources

• EU sustainable aviation fuel supply exceeds 2025 ReFuelEU Aviation target | EASA

Featured image via Unsplash.