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)