ReFuelEU Aviation: Best Practices for Aircraft Operators to Stay Ahead of Compliance

ReFuelEU Aviation: Best Practices for Aircraft Operators to Stay Ahead of Compliance

ReFuelEU Aviation is now a live compliance requirement for aircraft operators operating within the scope of the regulation. While much attention is placed on the 90% fuel uplift requirement, the practical challenge for operators is broader: building a reliable monitoring, reporting, and verification process that captures the right flights, the right fuel data, the right SAF documentation, and the right evidence for any justified shortfall.

The EASA ReFuelEU Aviation Manual for Aircraft Operators and Verification Bodies provides detailed operational guidance on how aircraft operators should approach these obligations. In particular, the manual’s Section 2.1 sets out the core obligations for aircraft operators, Section 3 explains the monitoring, reporting and verification process, Section 4 explains the reporting template, and Annex A provides detailed guidance on the calculation and justification of fuel tanked for safety reasons.

At VURDHAAN, we believe ReFuelEU Aviation compliance should be managed throughout the year, not treated as a last-minute reporting exercise before the 31 March submission deadline. Below are key best practices aircraft operators should implement.

1. Run monthly checks for missing data and uplift thresholds

Aircraft operators should conduct monthly checks for missing data and fuel uplift performance at each Union airport. This aligns with Section 3.1 of the EASA manual, which expects operators to monitor flights and associated fuel information throughout the reporting period.

A monthly ReFuelEU review should include:

• Flights departing from Union airports
• Planned taxi and trip fuel from the final signed operational flight plan
• Actual fuel uplifted at each Union airport
• Fuel density assumptions used for uplift calculations
• Block time
• Missing OFPs, fuel invoices, fuel slips, technical logs, or onboard system records
• Year-to-date uplift performance against the 90% threshold
• Any Union airport where the operator may be trending below the required uplift level

This is particularly important because Section 3.4 of the manual addresses data gaps and missing information. If primary and secondary data sources are unavailable, operators may need to rely on alternative calculation methods, which should be managed carefully and, where relevant, agreed with the competent authority.

Monthly monitoring reduces the risk of discovering missing data only during verification. It also helps operators identify early whether a Union airport may require a Column H justification for safety-fuel-related shortfalls.

2. Keep the Union airport list up to date

ReFuelEU Aviation reporting depends on whether flights depart from Union airports. Section 4.1.1 of the EASA manual explains that aircraft operators should use the Union airport names reflected in the list of Union airports published by the Commission and updated on a yearly basis. Section 4.1.2 also links the airport reporting requirement to the relevant ICAO code.

Operators should therefore review the Union airport list at least annually and whenever an updated list is published. The updated list should be reflected in:

• Flight filtering logic
• Reporting templates
• Monitoring plans
• Internal dashboards
• Manual checks by compliance teams

This is especially important for operators with seasonal networks, ACMI activity, charter operations, or operations involving smaller airports that may move in or out of scope over time.

3. Apply for route exemptions early

Section 2.1 of the EASA manual notes that aircraft operators may request refuelling exemptions on certain routes where the criteria under Article 5.3 of ReFuelEU Aviation are met. Section 2.3 further explains how flights on routes with granted exemptions are treated for reporting purposes.

Operators should not assume that route exemptions are automatic. Exemption requests require supporting evidence and must be planned well in advance. Because a three-month notice period may apply, operators should treat September as an internal deadline for reviewing whether exemptions are needed for the following year.

A practical exemption process should include:

• Identifying potentially eligible routes
• Assessing operational or structural refuelling constraints
• Collecting supporting evidence
• Engaging with the competent authority
• Tracking exemption status in the monitoring system
• Ensuring exempted routes are correctly excluded where applicable

Late exemption planning can create unnecessary compliance risk. If an exemption is not granted in time, the operator may still need to monitor and report the relevant flights under the standard ReFuelEU process.

4. Do not overlook ACMI and wet-leased operations

ACMI and wet-leased operations can create significant data challenges. Section 2.3 of the EASA manual explains that the ICAO designator used as a call sign in the flight plan is the determining factor for assessing which flights fall under the responsibility of the aircraft operator, regardless of whether the aircraft is leased, owned, or wet-leased.

Section 3.1 also expects operators to ensure the accuracy of wet-leased operations, including the inclusion of leased aircraft and traceability of their fuel and flight data.

Operators should therefore ask:

• Which party is responsible for the flight under the ICAO designator or aircraft registration used in the flight plan?
• Are leased-in aircraft captured in the ReFuelEU monitoring process?
• Are leased-out aircraft correctly excluded where applicable?
• Does the operator receive OFPs, fuel slips, uplift records, and technical logs for ACMI flights?
• Do ACMI and wet-lease contracts require timely provision of ReFuelEU-relevant data?

Strong contractual clauses are essential. Operators should ensure ACMI and wet-lease agreements require counterparties to provide the data needed for ReFuelEU reporting, verification, and any Column H safety-fuel justification.

5. Track safety-fuel justifications from day one

Operators may fall below the 90% uplift threshold where necessary for compliance with applicable fuel safety rules. However, this must be supported by evidence. Section 4.1.8 and Annex A of the EASA manual explain Column H, which is used to report the yearly tanked quantity for fuel safety rules.

This is why safety-fuel data should be collected from the first day of the reporting period, even where the operator currently appears to meet the 90% threshold. A Union airport that looks compliant in June may fall below the threshold by December due to network changes, diversions, aircraft rotations, operational constraints, or fuel availability.

The Column H calculation may require data from both arriving and departing flights. Annex A explains that the calculation considers fuel previously tanked for safety reasons and operational fuel divergence. Section 5.4 further explains the need to account for all relevant flights departing from and arriving at a Union airport when calculating Column H.

Operators should therefore monitor:

• Contingency fuel
• Alternate fuel
• Final reserve fuel
• Additional fuel
• Discretionary fuel
• Extra fuel linked to predictable operational constraints
• Actual fuel consumption
• Previous-flight data
• Arriving and departing aircraft rotations at Union airports

The best practice is simple: collect the evidence before you know whether you will need it.

6. Create a ReFuelEU monitoring plan

Section 3.1.1 of the EASA manual recommends the development of a monitoring process and notes that an aircraft operator may establish a written Monitoring Plan. Section 3.1.1.1 explains the EASA ReFuelEU Monitoring Plan Template and the types of information it should include.

A strong ReFuelEU monitoring plan should document:

• The operator’s scope assessment
• Procedures for identifying reportable flights
• Union airport mapping
• Data sources for fuel required and fuel uplifted
• Fuel density methodology
• Treatment of missing data and data gaps
• Alternative calculation methods
• ACMI and wet-lease data procedures
• SAF purchase data collection
• Record retention and verification support

The monitoring plan should be a working document for operations, finance, fuel, sustainability, and compliance teams. It should also help competent authorities and verification bodies understand the operator’s data sources, controls, and methodology.

7. Update fuel supplier contracts for SAF documentation

Section 4.2 of the EASA manual covers SAF purchase reporting. Aircraft operators are not required under ReFuelEU to demonstrate a minimum SAF purchase, but they must report SAF purchases where applicable.

Section 4.2 explains that SAF purchase reporting may require information such as:

• Union airport of delivery
• ICAO airport code
• Fuel supplier
• VAT number of the supplier
• Batch number
• Amount purchased in tonnes
• Eligible fuel category
• Fuel conversion process
• Feedstock name
• Feedstock origin
• Lifecycle emissions
• Claims under EU ETS, UK ETS, CH ETS, CORSIA, or other market-based measures

Section 4.2 also highlights the importance of supporting evidence such as Proof of Sustainability, Proof of Compliance, Product Transfer Documents, delivery notes, and invoices. The manual further notes that aviation fuel suppliers must provide aircraft operators with relevant and accurate information relating to the reporting period by 14 February of each reporting year.

As a best practice, operators should update fuel supply contracts to require all SAF documentation well before the reporting deadline. VURDHAAN recommends using 28 February as an internal escalation cut-off to close any remaining supplier documentation gaps. This allows time to reconcile SAF records, resolve mismatches, support verification, and complete the final report before the 31 March deadline.

ReFuelEU compliance is an operational process, not a March exercise

The operators best prepared for ReFuelEU Aviation will be those that treat compliance as a monthly operational control. The EASA manual makes clear that aircraft operators need accurate, complete, consistent, and traceable data across flight activity, fuel uplift, safety-fuel justifications, SAF purchases, and verification.

At any point in the year, an operator should be able to answer:

• Are all reportable flights captured?
• Are all Union airports correctly identified?
• Are we above or below the 90% uplift threshold at each Union airport?
• Do we have the documentation to justify any shortfall?
• Are ACMI and wet-lease operations correctly reflected?
• Are SAF purchases supported by the required evidence?
• Are our data gaps controlled and documented?
• Are we ready for verification?

VURDHAAN can support aircraft operators across the full ReFuelEU Aviation compliance cycle, including monitoring plan preparation, monthly data checks, Union airport updates, exemption assessment and applications, ACMI data review, safety-fuel justification, SAF documentation review, supplier contract clauses, reporting template completion, and verifier support.

As ReFuelEU Aviation matures, proactive operators will have a clear advantage: fewer reporting gaps, stronger audit trails, better SAF documentation, and greater confidence in their annual compliance position.

Contact Us today if you are looking for support in ReFuelEU