ReFuelEU Aviation — First Reporting Obligations in 2026

Although ReFuelEU Aviation obligations apply as from 1 January 2025, the year 2026 constitutes the first effective reporting and compliance milestone, based on data relating to the 2025 reference year.

At this stage, it is essential to clearly distinguish:

• Operators subject to formal reporting obligations under the regulation, and

• Operators required to generate, retain or make available data, without being directly responsible for submitting regulatory reports.

Misunderstanding this distinction may lead to inappropriate compliance strategies or gaps in data readiness.

Declarative and Data Obligations in 2026 by Category of Operators

Aviation Fuel Suppliers – Core Reporting Obligations for 2025 Volumes

Under ReFuelEU Aviation, aviation fuel suppliers are the primary entities subject to formal reporting obligations.

In 2026, fuel suppliers must submit their first annual declarations covering aviation fuel supplied during the 2025 calendar year, including in particular:

• Total volumes of aviation fuel supplied at EU airports,

• Volumes and shares of Sustainable Aviation Fuels (SAF),

• Compliance with the applicable minimum SAF blending mandates,

• Sustainability characteristics and traceability elements of eligible fuels.

These declarations form the basis for verifying compliance with EU-wide blending obligations.
As a result, fuel suppliers must ensure that all relevant fuel and sustainability data are captured, structured and auditable throughout 2025.

Aircraft Operators – Operational Obligations and Supporting Data, Not Primary Reporting

Aircraft operators are not subject to standalone SAF blending or supply reporting obligations under ReFuelEU Aviation.

However, from 1 January 2025, they are subject to operational obligations, notably aimed at preventing fuel tankering practices that could undermine the regulation’s objectives.

In this context:

• Aircraft operators must comply with refuelling requirements defined at EU level,

• They must be able to justify and document their fuel uplift practices,

• Operational and fuel-related data must be retained and made available upon request to competent authorities.

While aircraft operators are not the primary reporting entities, their ability to produce reliable, traceable and consistent operational data for 2025 is critical, particularly in the event of controls or cross-checks with fuel supplier declarations.

EU Airports – Enabling Role and Data Availability, Not Declarative Responsibility

EU airports covered by ReFuelEU Aviation do not have direct annual reporting obligations equivalent to those imposed on fuel suppliers.

Their role is primarily an enabling and facilitating one, including:

• Ensuring the availability of infrastructure and logistics for SAF supply,

• Cooperating with fuel suppliers and aircraft operators,

• Supporting the availability, consistency and verification of fuel-related data at airport level.

In practice, airports may be required to provide data or operational information to competent authorities or other operators, but they are not the addressees of the core 2026 declarations for 2025 volumes.

Legal Implication: 2025 as the First Fully Auditable Reference Year

From a compliance and risk perspective, the key takeaway is that 2025 already constitutes a full reference year for future controls and declarations, even though the first formal submissions occur in 2026.

For fuel suppliers in particular, any deficiency in data capture during 2025:

• Cannot be remedied ex post without significant legal and operational risk,

• May directly impact the assessment of compliance with SAF mandates.

For aircraft operators and airports, insufficient data structuring may:

• Weaken their ability to demonstrate compliance with their respective obligations,

• Create inconsistencies during regulatory checks or investigations.

A Compliance-Driven Need for Early Data Readiness

ReFuelEU Aviation is not limited to policy objectives; it is a binding regulatory framework with enforceable obligations.

From a legal standpoint, anticipation is therefore essential:

• Fuel suppliers must secure end-to-end reporting and auditability,

• Aircraft operators must align operational systems with compliance requirements,

• Airports must ensure data reliability and cooperation mechanisms.

Early preparation in 2025 is not a best practice — it is a de facto legal necessity.