How Aircraft Operators Can Calculate Their ReFuelEU Penalties
A practical guide to understanding the 90% uplift rule, justified shortfalls, and the role of EASA reference prices
ReFuelEU Aviation has introduced a new compliance discipline for aircraft operators departing from Union airports: operators must, on a yearly basis, uplift at least 90% of the aviation fuel required for their covered flights at each relevant Union airport. In practice, this means operators now need a robust airport-by-airport view of required fuel, actual uplift, and any defensible shortfalls.
For many operators, the challenge is not just reporting, but understanding when a shortfall becomes a penalty risk, and how that penalty may be quantified by competent authorities. EASA’s latest operator manual and its 2026 briefing note on 2025 aviation fuel reference prices make that calculation much clearer. Taken together, they show that penalty exposure depends on three things: the extent of the shortfall below the 90% threshold, the extent to which that shortfall can be justified for fuel safety reasons, and the reference fuel prices used by Member States under Article 12.
1. Start with the rule that actually matters
Under Article 5 ReFuelEU Aviation, aircraft operators are required to uplift at least 90% of the aviation fuel required at Union airports. That fuel required is the yearly total of trip fuel plus taxi fuel for all flights covered by the Regulation departing from that airport. The obligation is not a SAF purchase mandate for aircraft operators; it is an uplift obligation tied to reporting and compliance.
This point is important because many operators instinctively compare actual uplift to 100% of required fuel. That is not the correct compliance test. ReFuelEU allows a 10% buffer. Only the amount falling below the 90% threshold becomes the relevant non-tanked quantity for compliance purposes. The EASA manual is explicit that only quantities below that threshold should be reported as yearly non-tanked quantity in Column G of the reporting template.
2. The first calculation: identify the yearly non-tanked quantity
EASA explains that the yearly non-tanked quantity is calculated in the reporting template as:
If fuel uplifted is at least 90% of fuel required, Column G = 0
If fuel uplifted is below 90% of fuel required, Column G = 90% × Fuel Required – Fuel Uplifted
So, at each Union airport:
- Fuel Required (FR) = yearly sum of taxi fuel + trip fuel for covered departing flights
- Fuel Uplifted (FU) = yearly actual uplifted fuel for those flights
- Yearly Non-Tanked Quantity (YNT / Column G) = max[0, (0.9 × FR) – FU]
Example 1: basic shortfall calculation
Assume at Airport A an operator reports:
- Yearly fuel required: 10,000 tonnes
- Yearly fuel uplifted: 8,700 tonnes
The 90% threshold is:
0.9 × 10,000 = 9,000 tonnes
The non-tanked quantity is therefore:
9,000 – 8,700 = 300 tonnes
That 300 tonnes is the initial exposure point. It does not automatically equal the penalised quantity, because the operator may still justify part of it under Article 5(2).
3. The second calculation: determine how much of the shortfall is justifiable
ReFuelEU recognises that not all under-uplift is economic tankering. Sometimes fuel has already been carried into the airport for legitimate safety or operational reasons. EASA therefore allows operators to justify part of the shortfall through Column H, the yearly tanked quantity for fuel safety rules.
The manual explains the formula as:
Column H = YTFJ(n−1) − YTFJ(n) + OFD(n−1)
Where:
- YTFJ(n−1) = justified tanked fuel on the arriving flight
- YTFJ(n) = justified tanked fuel on the departing flight
- OFD(n−1) = operational fuel divergence from the arriving flight
- OFD(n−1) = YFR(n−1) − AFC(n−1)
- YFR = yearly fuel required
- AFC = actual fuel consumption
EASA also clarifies what counts as justified tanked fuel. In broad terms, it includes safety-related fuel categories such as contingency fuel, destination alternate fuel, final reserve fuel, additional fuel, commander’s discretionary fuel, and certain extra fuel, provided they are properly documented. By contrast, fuel that does not belong to those justified categories is considered economic tankering.
Just as importantly, Column H must reflect the full operational picture. Operators must include not only the in-scope flights departing from the Union airport where Column G is positive, but also the relevant preceding flights arriving at that airport. EASA stresses that flights should not be selectively excluded based on uplift percentage on an individual flight basis.
Example 2: netting justified quantities against the shortfall
Continuing the Airport A example:
- Column G shortfall: 300 tonnes
- Valid, documented Column H justification: 180 tonnes
Then the unjustified shortfall becomes:
300 – 180 = 120 tonnes
That 120-tonne balance is the quantity most likely to drive penalty exposure, subject to the competent authority’s acceptance of the justification. The manual notes that the CA ultimately decides how positive and negative values in Column H are treated for penalty purposes.
4. The third calculation: apply the EASA reference prices
Once the remaining non-compliant quantity has been determined, the next step is to apply the reference prices that EASA publishes for Article 12 penalty purposes. The 2026 EASA briefing note states that its 2025 reference prices are specifically intended to support Member States in determining penalties for non-compliance.
For 2025, EASA provides the following headline reference prices:
- Conventional aviation fuel (Pconv): €640/tonne
- SAF (PSAF): €1,925/tonne
- Synthetic aviation fuels (Psyn): €7,520/tonne
- Aviation fuels (Paf): €666/tonne
EASA also explains how Paf is derived. It is the weighted average of conventional aviation fuel, SAF, and synthetic aviation fuels using the minimum shares set out in Annex I of ReFuelEU Aviation. For 2025, EASA uses 98% conventional fuel, 2% SAF, and 0% synthetic aviation fuels, which gives:
Paf_2025 = (640 × 98%) + (1,925 × 2%) + (7,520 × 0%) = 666 €/tonne
That makes €666/tonne the key benchmark for 2025 aviation fuel price calculations linked to penalty determination.
5. A practical working method for estimating penalty exposure
The EASA note provided here does not itself set out the full legal penalty equation from the Regulation, but it clearly identifies the reference prices that Member States are expected to use for Article 12 determinations. A practical operator-side approach, therefore, is to calculate an internal penalty exposure estimate in three steps:
Step 1: Calculate the airport-level shortfall
Shortfall before justification = max[0, (0.9 × FR) – FU]
Step 2: Calculate accepted justification
Justified quantity = Column H, to the extent accepted by the CA
Step 3: Estimate exposure on the remaining quantity
Indicative exposure = remaining unjustified quantity × relevant reference price
For most 2025 under-uplift exposure assessments, the most relevant benchmark is likely to be Paf = €666/tonne, because EASA presents this as the 2025 reference price of aviation fuels for Article 12 support.
Example 3: indicative penalty exposure estimate
Using the earlier figures:
- Fuel required = 10,000 tonnes
- Actual uplift = 8,700 tonnes
- Shortfall below 90% threshold = 300 tonnes
- Accepted fuel safety justification = 180 tonnes
- Remaining unjustified quantity = 120 tonnes
Indicative exposure using 2025 aviation fuels reference price:
120 × €666 = €79,920
This does not replace the formal determination by the administering Member State, but it is a practical, decision-useful internal estimate grounded in the EASA reference prices supplied for Article 12 purposes.
6. Why monthly monitoring matters more than year-end reconstruction
The biggest operational mistake under ReFuelEU is to treat this as a March reporting exercise rather than a year-round compliance exercise.
EASA’s operator manual strongly points in the opposite direction. It says operators are expected to monitor flights and associated fuel information throughout the full reporting period and to implement a management system with defined procedures, controls, and traceable data. It also recommends monitoring not just flights departing from Union airports, but also relevant previous flights, because fuel carried into a Union airport may be central to justifying why the 90% uplift threshold was not met there.
That is why monthly monitoring is essential.
A monthly airport-level dashboard allows operators to:
- track the cumulative ratio of actual uplift vs. 90% of required fuel at each Union airport;
- identify airports drifting below the threshold before the deficit becomes material;
- collect justification evidence while records are still fresh;
- test whether recurring shortfalls are truly safety-driven or are likely to be viewed as economic tankering;
- spot data gaps early enough to agree alternative methods with the CA before year-end; and
- avoid a year-end scramble in which missing OFPs, incomplete uplift records, or weak support for Column H reduce the portion of the shortfall that can be defended.
In practical terms, operators should not wait until March to discover they finished the year at 87% uplift at a major Union airport. By then, commercial, operational, and evidentiary options are limited. A monthly review lets compliance, fuel procurement, dispatch, and operations teams intervene early—especially at airports where network patterns, turnarounds, or recurrent inbound fuel carriage make the 90% threshold harder to meet.
EASA also recommends that operators ideally create automated queries and a master monitoring table drawing from internal fuel and flight management systems, then feed that into the official reporting template. This is exactly the sort of structure that makes monthly threshold control realistic.
7. What data operators need in order to calculate and defend the numbers
A credible penalty calculation begins with credible data.
The EASA manual identifies the main sources operators should rely on:
- Fuel required (Column E): planned taxi + trip fuel from the final OFP signed by the captain;
- Actual fuel uplifted (Column F): supplier delivery notes, invoices, technical logs, fuel slips, or onboard systems;
- Justification (Column H): OFPs for arriving and departing flights, plus actual fuel consumption evidence such as block-off minus block-on fuel from technical logs, flight logs, ACARS, electronic flight bags, or other relevant documentation.
Where primary and secondary data are unavailable, EASA allows alternative calculations within defined thresholds, but it also makes clear that the absence of data does not exempt an operator from reporting obligations, and failures may still lead to penalties.
That makes documentation discipline just as important as the formula itself.
8. A simple compliance formula operators can use internally
For internal management purposes, operators can use the following structure at each Union airport:
Airport Penalty Exposure Estimate
= max[0, (0.9 × Fuel Required – Fuel Uplifted) – Accepted Justification] × Applicable Reference Price
For 2025, an operator estimating exposure using the EASA Article 12 reference benchmark could use:
Indicative 2025 Exposure
= max[0, Column G – accepted Column H] × €666/tonne
This is a useful management formula because it is easy to operationalise, easy to explain internally, and directly linked to the two EASA documents operators are already expected to use.
9. Final takeaway
ReFuelEU penalty exposure is not just a legal issue; it is a data and operations issue.
Aircraft operators that understand the structure can manage it proactively:
- calculate required fuel and actual uplift by Union airport;
- test compliance against the 90% threshold, not 100%;
- calculate any shortfall through Column G;
- build and substantiate legitimate fuel safety justifications through Column H;
- apply EASA’s Article 12 reference prices to estimate exposure; and
- monitor performance monthly so that under-uplift risks are identified early, not after the reporting year closes.
For operators, the practical lesson is straightforward: the cheapest penalty is the one avoided through better monthly visibility. And where exposure cannot be avoided, a well-structured monitoring and evidence framework can materially improve the defensibility of the final position. Teams with experience in aviation MRV, fuel compliance workflows, and regulator-ready evidence management can make that process much smoother an area where firms such as VURDHAAN support clients in translating ReFuelEU obligations into workable compliance systems.
Download ReFuelEU Manual by EASA