ReFuelEU Aviation requires sustainable aviation fuel at Union airports and stops tankering on routes out of them. This guide explains the obligations, the reporting deadlines, and how the Article 12 fine floors are computed from the EASA reference prices, with worked examples using synthetic inputs.
This guide is written for compliance officers at aircraft operators and aviation fuel suppliers, airport managing bodies, and analysts who need to estimate or explain ReFuelEU Aviation exposure. It quotes the governing clauses of Regulation (EU) 2023/2405 by article number so you can verify every statement against the primary text, and it names the price year and source table behind every euro figure. It is an explainer: the examples use synthetic inputs, and it is not legal advice.
Regulation (EU) 2023/2405 applies at Union airports, defined in Article 3(1) as airports with more than 800,000 passengers or more than 100,000 tonnes of freight in the previous reporting period, excluding outermost regions. Three groups carry duties.
Aviation fuel suppliers must ensure that all aviation fuel made available to aircraft operators at each Union airport contains the minimum shares of sustainable aviation fuel (SAF) set out in Annex I, rising over time. From 2030 a sub-target for synthetic aviation fuels applies alongside the overall SAF share.
The yearly quantity of aviation fuel an operator uplifts at a given Union airport must be at least 90 percent of the yearly aviation fuel required for its flights from that airport. The point is anti-tankering: carriers must refuel in the Union rather than arriving with fuel bought cheaply elsewhere.
Union airport managing bodies must take the necessary measures so that aircraft operators have adequate access to aviation fuels containing the minimum SAF shares. A body that fails to do so is liable to a fine under Article 12(3).
| From | Minimum SAF share | Of which synthetic aviation fuels | Clause |
|---|---|---|---|
| 1 January 2025 | 2% each year | none | Annex I(a) |
| 1 January 2030 | 6% each year | 1.2% average over 2030 to 2031 (0.7% minimum each year); 2.0% average over 2032 to 2034 with yearly minimums of 1.2% then 2.0% | Annex I(b) |
| 1 January 2035 | 20% each year | 5% | Annex I(c) |
| 1 January 2040 | 34% each year | 10% | Annex I(d) |
| 1 January 2045 | 42% each year | 15% | Annex I(e) |
| 1 January 2050 | 70% each year | 35% | Annex I(f) |
Two scope definitions matter for the arithmetic that follows. An aircraft operator is a person that operated at least 500 commercial passenger air transport flights, or 52 commercial all-cargo air transport flights, departing from Union airports in the previous reporting period (Article 3(3)). The yearly non-tanked quantity is the difference between the yearly aviation fuel required and the fuel actually uplifted before covered flights depart a given Union airport (Article 3(25)), and the total yearly non-tanked quantity sums that figure across all Union airports (Article 3(26)).
The Regulation entered into force in October 2023 and applies from 1 January 2024, while the operational duties in Articles 4, 5, 6, 8 and 10 apply from 1 January 2025 (Article 18). Enforcement is national: each Member State lays down its own penalties, which is why the fine formulas below are floors rather than a tariff.
Member States must lay down rules on penalties for infringements, keep them effective, proportionate and dissuasive, and notify them to the Commission, amending them without delay.
Suppliers must meet the Annex I shares and report supplied quantities, SAF types, feedstock characteristics and lifecycle emissions per Union airport in the Union database (Article 10).
Operators report uplifted and required fuel per Union airport, SAF purchases, and flight counts, verified by an independent verifier and presented per the Annex II templates (Article 8). Suppliers must hand operators SAF purchase information by 14 February of each reporting year (Article 9(2)).
Member States report publicly on the use of fine revenues, which should support SAF research, production, or mechanisms bridging the price gap between SAF and conventional fuel.
The Agency publishes the yearly technical report underlying the reference prices used in fine decisions. The 2026 briefing note pre-published the 2025 reference prices; the prices change with each annual report.
Article 17(1) obliges the Commission to present a report on the application of the Regulation, and Article 17(3) names the level of fines among the items the review must evaluate.
Obligation applicability and enforcement therefore differ: the duties bit on 1 January 2025, while the penalty regimes that price non-compliance were put in place nationally through 2024. Page information is current as of September 2026. Primary text: Regulation (EU) 2023/2405 on EUR-Lex.
Article 12 sets fine floors expressed in multiples of aviation fuel prices. Article 12(7) requires every fining decision to explain its fuel price methodology, based on verifiable and objective criteria including the latest technical report under Article 13. In practice Member States work from the reference prices EASA publishes each year.
The reference prices change with each annual cycle: EASA's annual technical report, due for publication in Q3 every year, carries the prices for that year, and its 2026 briefing note pre-published the same figures for the 2025 price year. Every euro figure on this page therefore names the 2025 price year and the EASA table it came from. For 2025, real index prices existed only for aviation biofuels, so the SAF reference price excludes synthetic aviation fuels for penalty purposes (EASA Table 1, footnote 15).
| Reference price, 2025 price year | EUR per tonne | Source table |
|---|---|---|
| Conventional aviation fuel (P_conv) | 640 | EASA Table 2 row i, from Table 1 real index price |
| Sustainable aviation fuel (P_SAF) | 1,925 | EASA Table 2 row ii, from Table 1 real index price for aviation biofuels |
| Synthetic aviation fuel (P_syn) | 7,520 | EASA Table 2 row iii, from Table 1 production cost estimation (weighted average) |
| Aviation fuels blend (P_af) | 666 | EASA Table 2 row iv, computed from the Annex I minimum shares |
The blend price follows the Annex I shares for the year in question. For 2025 the shares were 98% conventional fuel, 2% SAF and 0% synthetic fuel (EASA section 2.2):
Each floor is "not less than twice" a price-quantity product, so the formulas set minimums and national authorities may go higher, subject to the effective, proportionate and dissuasive standard in Article 12(1). An operator can be exempted where failure was caused by exceptional and unforeseeable circumstances outside its control (Article 12(2)).
A shortfall is not settled by the fine alone: a supplier that accumulates a shortfall must supply the missing quantity in a subsequent reporting period on top of that period's obligation, and paying the fine does not remove that duty (Article 12(8)). On the operator side, the reporting template trims small positives: a yearly non-tanked quantity that is negative, or at most 10 percent of the yearly aviation fuel required at that airport, is reported as zero (Article 8(1)(c)).
Both examples use invented operators and quantities. Only the prices are real, and they are pinned to the 2025 price year.
Synthetic input: an airline covered by Article 3(3) ends a reporting year with a total yearly non-tanked quantity of 1,200 tonnes, meaning it systematically departed Union airports on less fuel than the 90 percent duty required (Article 5(1)).
Applying the Article 12(2) floor at the 2025 blend price of 666 EUR/t (EASA Table 2 row iv): 2 × 666 × 1,200.
fine floor = EUR 1,598,400 (2025 price year)Synthetic input: a fuel supplier leaves 40 tonnes of its 2025 supply at Union airports below the 2% minimum SAF share of Annex I(a).
Applying the Article 12(4) floor with the 2025 prices of 1,925 EUR/t for SAF and 640 EUR/t for conventional fuel (EASA Table 2 rows ii and i): 2 × (1,925 − 640) × 40.
fine floor = EUR 102,800 (2025 price year)The same quantities price very differently in later years, because both the blend share and the reference prices move: the Annex I SAF share rises to 6% in 2030, and the price set refreshes with each Q3 technical report.
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Guide · September 2026 · Regulation (EU) 2023/2405 · ReFuelEU Aviation