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What changed

Competent Authorities have set clearer expectations for how they will check aircraft operator reports for the 2025 reporting period submitted in 2026. Since 2025 is the first year where penalties may apply for missing the refuelling threshold under Article 5.2, documentation quality will matter more than it did before.

What authorities are likely to check

Submission and verification essentials

Authorities are expected to confirm that the operator report and the verification report are both submitted, that the verifier is properly accredited, and that the verification conclusion is clearly stated and supported.

Mandatory fields and template integrity

They may check whether all required fuel reporting fields are completed and consistent, including units and totals. Where sustainable aviation fuel is purchased at a Union Airport, they may also verify that the relevant purchase information is complete and that claim related fields are used correctly.

A non-obvious opportunity

Turn audit checks into routine data health checks

The guidance highlights plausibility checks such as reasonableness of yearly fuel required and typical ranges for average fuel per flight. If these checks are built into monthly reporting routines, teams can catch data mapping issues and uplift anomalies early, long before verification, saving time and avoiding late stage corrections.

Where questions often start

Managing data gaps

Higher levels of missing information may trigger follow ups and requests for corrective actions.

Positive fuel tanking values

If fuel tanked for safety rules is reported as positive, reviewers may request raw flight records and supporting evidence, often through sampling.

Conclusion

This guidance is a helpful roadmap for smoother compliance. A single traceable line from flight activity to fuel uplift data and sustainable aviation fuel evidence can reduce rework, speed up verification, and strengthen confidence in reported outcomes. Our aviation sustainability team can support a short readiness review to help streamline your evidence pack and align internal checks with expected audit screens.

Download Document File Here: ReFuelEU Aviation Competent Authority Guidance (Version 1.0)

What has been updated

EASA has issued a verification report template for aircraft operators under Regulation (EU) 2023/2405. The template brings the key checks into one place so a verifier can confirm fuel reporting, SAF purchase reporting, and the supporting monitoring plan. It also captures the percentage of data gaps and missing information, which makes the outcome easier to compare year to year.

The non obvious opportunity

This update is not only about meeting Article 8 reporting duties. It can also improve business decisions. When fuel uplift data, tanking for safety rules, and SAF purchase evidence are structured the same way every cycle, finance and sustainability teams can spot anomalies earlier and reduce rework. Strong verification files also protect credible SAF use claims, which matters as customers and regulators ask for clearer proof.

How to use it with less effort

Start with one source of truth

Align flight and fuel data sources, then map them to the monitoring plan and reporting template fields.

Treat data gaps as a risk register

Record why gaps occur, set owners, and close them before year end where possible.

Keep exemptions evidence ready

If exempted routes apply, keep the route list and portal acceptance evidence together with the report file.

Conclusion

A consistent verification pack can turn compliance into stronger data quality and smoother audits. If you want a quick readiness review of your monitoring plan and fuel and SAF reporting workflow, a specialist transport sustainability team can help you get there with minimal disruption.

Why this structure works

It stays positive, avoids legal sounding language, and turns the update into a practical data quality advantage with simple actions.

Alternative approach

If you want a more thought leadership tone, the post can focus on how verification readiness strengthens stakeholder trust in SAF claims, with one short real-world example and a clear next step for an internal readiness workshop.

Download Document File Here: ReFuelEU Aviation Verification Report Template (Version 1.0)

What the update signals

The updated Monitoring Plan template for Regulation EU 2023 2405 ReFuelEU Aviation highlights a shift: fuel data is now a regulated asset. The template supports Article 8 reporting and helps operators document how data is collected, checked, stored, and improved.

A clearer map of responsibilities

Sections on identification, management, fleet and flight operations, and fuel monitoring create one narrative from process ownership to each calculation. This reduces friction because finance, operations, and procurement can work from definitions.

Closer to the EU ETS way of working

The design follows EU ETS style MRV logic, making it easier to align teams familiar with emissions reporting.

A non obvious opportunity

The upside is not only compliance. When fuel uplift, supplier details, and sustainable aviation fuel purchases are captured consistently, the same dataset can guide decisions on routing, contracting, and risk. Done well, it improves stakeholder confidence because numbers can be traced from invoice to flight record quickly.

Better data supports better buying

Consistent monitoring helps compare suppliers and airports on reliable metrics and highlights where documentation is strongest.

Verification readiness becomes routine

A maintained monitoring plan turns audits into a repeatable check instead of a fire drill, freeing time for efficiency work.

Practical next steps

Fill the core sheets with one month of flights. Validate inputs with a review so gaps are fixed early. If time is limited, start from procurement invoices, then link each uplift to flights once controls settle. If you want a review of your monitoring plan and data controls, our team can help you keep it simple while meeting regulator expectations.

Conclusion

This update is a chance to treat compliance as a foundation for smarter fuel strategy and stronger sustainability outcomes overall.

Download Document File Here: ReFuelEU Aviation Monitoring Plan Template (Version 1.1)

A clearer playbook for reporting

EASA has released version 2.1 of its manual for aircraft operators and verification bodies, adding detail to the verification section and consolidating guidance for monitoring, reporting and verification via the Sustainability Portal.

The non-obvious insight

This update is not just a compliance refresh. It pushes teams to treat fuel and SAF data as one operational asset. When flight operations, finance and sustainability share one consistent dataset, reporting becomes faster, verifier questions drop, and decisions improve.

What operators should do now

Build a monitoring plan that works

The manual recommends an internal monitoring plan and a master monitoring table that can automate checks, highlight gaps, and feed the official template. Starting during the reporting period reduces end of year firefighting.

Get ahead of data gaps

If primary and secondary data sources fail, alternative calculation methods may be used, but only within defined thresholds. The manual recommends submitting the methodology early, ideally by end of January, so it can be confirmed before the 31 March submission deadline.

Treat SAF reporting like traceability

Operators are not required to buy SAF, but they must report SAF purchased and delivered at Union airports, backed by evidence such as proof of sustainability or proof of compliance. Only neat SAF quantities are accepted, so procurement should be aligned to documentation and batch traceability.

Conclusion

Version 2.1 makes compliance more predictable and turns good data governance into a real advantage. A practical next step is a short readiness review across flight ops, fuel procurement and reporting owners, then a monitoring plan and evidence checklist. An alternative approach is to start with SAF documentation controls first, then expand into fuel uplift and justification workflows, calmer audits and smoother cycles.

Download Document File Here: ReFuelEU Aviation Manual for Aircraft Operators and Verification Bodies (Version 2.1)

What changed in version 2.1

The Aircraft Operator reporting template for ReFuelEU Aviation was updated on 9 December 2025. The key change is practical. Column H in the Fuel Reporting sheet now accepts negative values, supporting corrections when fuel safety tanking data needs adjustment after reconciliation.

What changed in version 2.0

In November 2025, the template added new fields in the SAF Purchase Reporting sheet. Purchases of eligible fuels can now be allocated across different market based measures, including EU ETS, Swiss ETS, UK ETS, CORSIA, and other schemes. This improves transparency and reduces the risk of double claiming.

The non obvious upside

Better data quality without extra paperwork

Allowing negative entries is not a loophole. It recognises that operational data arrives in waves. By enabling reversals in a controlled column, the template helps teams correct earlier submissions without parallel spreadsheets.

Stronger proof of unique claims

The expanded purchase section nudges the industry toward a single source of truth. When each tonne of eligible fuel is linked to a specific scheme claim or left unclaimed, auditors and regulators can follow the trail quickly, shortening review cycles.

How to prepare

Build a monthly close process

Treat airport uplift, non tanked quantities, and fuel safety tanking as a monthly close. Lock assumptions, record adjustments, and keep evidence for each change.

Get ahead of 2026 reporting pressure

Set up templates, responsibilities, and checks now so your 2026 reporting is routine rather than reactive. An independent sustainability advisory can align fuel data, procurement evidence, and scheme claims into one audit ready workflow.

Conclusion

These template updates are small on paper but meaningful in practice. They reward operators who invest in data governance and traceable SAF claims, and they make compliance a pathway to credibility in the market.

Why this angle works: it frames the update as an operational advantage that improves audit clarity and reduces rework, which keeps the tone positive without sounding promotional.

Alternative approach: write the post as a short case style story showing how a reporting team uses negative entries to correct fuel safety tanking and uses the new claim fields to prevent double claiming during an internal audit.

Download Document File Here: ReFuelEU Aviation Template for Aircraft Operators (Version 2.1)

Why this update matters

A quiet change in a compliance toolkit can have an outsized impact on day to day operations. The latest update to the ReFuelEU Aviation fuel monitoring workflow strengthens the link between flight level data, scope checks, and the final reporting template. That means fewer last minute fixes, clearer audit trails, and more confidence when reporting season arrives.

What is new in version 2.1

The most recent release includes a correction to the Name Manager, which reduces the risk of broken references across tabs. In practice, this helps formulas and dropdown logic behave consistently when operators refresh the file or copy in new flight blocks.

How the tool supports the regulation

The structure aligns operational planning with regulatory needs by bringing planned required fuel, uplift, and actual consumption into one monitoring view. It also keeps room for key regulatory nuances, including accepted exemptions for routes under Article 5(3) and yearly tanked fuel that may be justified under Article 5(2). When exemptions apply, the dedicated export tab helps ensure only approved routes are counted, while the data gaps view highlights where records need attention before submission.

A non obvious opportunity

Many teams treat monitoring as a box ticking exercise. When flight data is complete and sequenced, the same dataset can reveal patterns in uplift practices and tankering decisions that influence both cost and emissions. Turning compliance into insight is often the fastest path to measurable improvements.

Conclusion

A small technical correction can remove friction across an entire reporting cycle. If you want to use ReFuelEU Aviation reporting to unlock operational clarity, work with a specialist sustainability partner to set up clean data flows, pragmatic assumptions, and a review routine that stands up to scrutiny.

Download Document File Here: ReFuelEU Aviation Fuel Monitoring Tool (Version 2.1)