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)