4AIR PolicyWatch
Providing business aviation with visibility into upcoming environmental legislation
4AIR PolicyWatch
Stay ahead of emerging legislation that may affect your operations or impact your clients and their reporting.
*Last updated 11/14/2024
| Title | Effective Date | Last & Next Update | Summary – What is it? | Applicability – Who Does it Impact? | Status | Link |
|---|---|---|---|---|---|---|
| Securities & Exchange Commission (SEC) Environmental Footprint Reporting | The first disclosures will be due in 2026 for Fiscal Year 2025 reporting (depending on entity size). | Last Update: The rule was adopted by the SEC on March 6, 2024. By April 4, 2024, the rule was stayed in federal court and by the SEC administratively. Next Update: The stay will remain in place until the completion of litigation filed in the federal courts that challenges the agency’s authority to adopt the Final Rule. | The Securities & Exchange Commission (SEC) passed a rule mandating that public companies report elements of their environmental footprint, including Scope 1 and 2 emissions, if material. Additionally, some companies will have to disclose the financial impacts of severe weather, carbon offsets, and other climate factors. | The rule applies to all public companies, including non-US firms with shares traded in the US. Within the realm of aviation, this would directly affect corporate flight departments and managed aircraft that serve as direct assets for large public companies. Indirectly, it may also impact any aviation company serving a customer that opts into supply chain reporting requirements. | ENACTED; STAYED | Final rule: The Enhancement and Standardization of Climate-Related Disclosures for Investors AGENCY: Securities and Exchange Commission |
| California SB 219, Greenhouse Gases: Climate Corporate Accountability & Climate-Related Financial Risk (previously two separate laws, SB253 and SB261) | 1-Jan-2026 | Last Update: Following legal challenges and a widely held desire to push back the clock on previous laws SB253 and SB261, SB219 was passed in September 2024 to (slightly) amend the timeline of implementation. Next Update: The future impact of this bill remains uncertain. SB253 and SB261 are currently the subject of litigation in the U.S. District Court for the Central District of California with hearings scheduled for mid-October 2024. | California passed rules imposing climate reporting requirements on large companies doing business within the state. This would include the disclosure of Scope 1, 2, and 3 emissions and require climate risk disclosures. | The bill applies to businesses, including aircraft operators, with total annual revenues more than $500 million, and that do business in California. Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | ENACTED | Today's Law As Amended - SB-219 Greenhouse gases: climate corporate accountability: climate-related financial risk. (ca.gov) |
| California AB1305, The Voluntary Carbon Market Disclosures Act | Although the law doesn't specify when initial disclosures are required, it is now widely understood to have an effective date of January 1, 2025 | Last Update: The authoring assembly member clarified his intent that the first disclosures should be posted by January 1, 2025, though that is not written in the bill text. Next Update: California legislature may further clarify the timeline and additional details in a future legislative session with a superseding bill. | AB1305 imposes multiple disclosure requirements on companies making claims related to net-zero, carbon neutrality, or similar assertions, even when utilizing voluntary carbon offsets. There are more stringent disclosure requirements for carbon offset sellers. | These disclosure requirements would impact business aircraft operators that make net-zero or carbon neutrality claims through the use of voluntary carbon offsets. The text as currently written would impact any company doing business within the state, or that sells to California customers. | ENACTED | Bill Text - AB-1305 Voluntary carbon market disclosures. |
| EU Corporate Sustainability Reporting Directive (CSRD) | 2025 (For earliest compliance) | Last Update: January 5, 2023 | Like the SEC, the EU Corporate Sustainability Reporting Directive (CSRD) is a legislation that requires all large companies and listed SMEs in the European Economic Area to publish regular reports on their environmental and social impact activities. This includes disclosure of Scope 1, 2, and 3 emissions and climate risks if deemed material. | Public companies with more than 500 employees as well as private organizations that meet 2 of the following 3 criteria: a) > 250 employees, b) >€40M in revenue, c) or >€20M in assets.Companies with prior reporting requirements under NFRD will be required to report FY2024 in 2025, with smaller or new companies having reporting obligations in later years.Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | ENACTED; The CSRD came into effect in January 2023. Reports must adhere to the European Sustainability Reporting Standards (ESRS), which were officially adopted on July 31, 2023. | Corporate sustainability reporting (europa.eu) |
| UK SECR – Streamlined Energy and Carbon Reporting | Beginning on April 1st, 2019, and continuing each subsequent financial year. | Last Update: April 01, 2019 | Similar to the SEC, the United Kingdom (UK) Streamlined Energy and Carbon Reporting (SECR), will be refining rules for a new reporting mechanism for certain public and private companies to report Scope 1 and 2 emissions of their operations. | All publicly listed companies and private organizations that meet 2 of the following 3 criteria: a) > 250 employees, b) >£36M in revenue, c) or >£18M in assets; and are also registered in the UK. Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | ENACTED 4/1/2019 | The Companies (Directors’ Report) and Limited Liability Partnerships (Energy and Carbon Report) Regulations 2018 (legislation.gov.uk) |
| ReFuelEU Aviation Regulation | March 31, 2025, for the reporting period of the year 2024. | Last Update: Enacted on October 9, 2023 ReFuelEU Aviation website was released in May 2024, including a list of aircraft operators and union airports covered by the regulation. | 1. The regulation mandates that fuel suppliers distribute a progressively higher minimum proportion of SAF to major EU airports over time, aiming to boost its adoption by airlines and consequently mitigate emissions from aviation. Additionally, it prohibits tankering as a mechanism to avoid uplifting SAF and imposes reporting requirements on operators to report regular fuel and SAF uplifts at major “Union” airports. 2. The environmental labeling scheme, as part of the ReFuelEU Regulation, will enable aircraft operators to request the issuance of a label for flights departing from EU airports. The label will certify the environmental performance of the flight based on the expected carbon footprint per passenger and the expected CO2 efficiency per kilometer. | All aircraft operators (including those based outside of the EU) conducting over 500 flights per year from Union airports (larger EU airports) must report information related to fuel uplifted. From 2025, aircraft operators may voluntarily apply to EASA for an environmental label for their flights. EASA will then provide the expected CO2 footprints for those flights. | ENACTED; The RefuelEU Aviation Regulation was adopted by the Council of the EU on October 9, 2023 | ReFuelEU Aviation (europa.eu) |
| EU ETS Aviation Revision | 1-Jan-2024 | Last Update: Enacted on May 16, 2023 | 1.From 2024: Free emission allowances will be reduced by 25% in 2024, 50% in 2025 and 100% from 2026, with all allowances fully auctioned from 2026. 2. From 2025, aircraft operators included in the EU ETS scheme will be able to apply for free SAF allowances that will cover all or part of the SAF price premium for uplifted SAF in the previous reporting year. Twenty million allowances will be set aside exclusively for the utilization of sustainable aviation fuels (SAF) between 2024 and 2030. 3. From 2024: The yearly Emissions Allowances surrender deadline is changed from 30 April to 30 September. 4. From 2025: Aircraft operators are required to submit annual reports on non-CO2 aviation effects, including oxides of nitrogen (NOx), soot particles, oxidized sulfur species, and effects resulting from water vapor, such as contrails. 5. From 2025: Flights from the Outermost Region of one Member State to a different Member State will be subject to reporting requirements. | All aircraft operators included in the EU ETS reporting scheme. | ENACTED; The EU Directive 2023/958 and 959 was enacted on May 10, 2023. | EU ETS revised legislation |
| UK ETS Aviation reform | Proposed for 2024 | Last Update: July 3, 2023 | UK ETS Authority has announced the phasing out of aviation free allocations by 2026. Free allocation entitlement will be retained until 2026, with a gradual transition period starting in 2024 and 2025 to assist aircraft operators in preparation. | All aircraft operators included in the UK ETS reporting scheme. | PROPOSED; The package of UK ETS reforms was announced by the UK Emissions Trading Scheme Authority in July 2023. | Tighter limit on industrial, power and aviation emissions, as UK leads the way to net zero - GOV.UK (www.gov.uk) |
| UK ETS Reporting Service | 31-Jul-2023 | Last Update: July 31, 2023 | The UK METS portal, also known as the “Manage your UK Emissions Trading Scheme Reporting Service”, is a new system for managing the UK Emissions Trading Scheme (UK ETS). | Aircraft operators included in the UK ETS reporting have been invited to create their accounts with METS and undergo the onboarding process as users. | Non-legislative modification of the reporting procedure, shifting from ETSWAP to the METS system. | EUETS - Logon (environment-agency.gov.uk) |
| US Federal Acquisition Regulation: Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk | One year after publication of a final rule. | Last Update: Originally proposed in November 2022, the final FAR rule is being drafted with consideration of public comments received. Next Update: A report on this is due by September 25, 2024. | DoD, GSA, and NASA are proposing to amend the Federal Acquisition Regulation (FAR) to implement a requirement to ensure certain Federal contractors disclose their greenhouse gas emissions and climate-related financial risk and set science-based targets to reduce their greenhouse gas emissions. | Certain federal contractors, including aircraft operators, will be required to disclose their greenhouse gas emissions and climate-related financial risks, as well as set science-based targets to reduce their greenhouse gas emissions. | PROPOSED | Federal Register: Federal Acquisition Regulation: Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk |
| Illinois State SAF Tax Credit | July 1, 2023, through December 31, 2032. | Last Update: The Illinois State SAF Tax Credit was enacted as part of the Invest in Illinois Act, signed into law in February 2023. The Illinois Department of Revenue has released specific forms and instructions for claiming credits on their website. Next Update: TBD | The Illinois State Sustainable Aviation Fuel (SAF) Tax Credit is a program that provides a tax credit of $1.50 per gallon for SAF used by aircraft in the state. The credit applies to every gallon of SAF sold to or used by an “air common carrier” in Illinois from June 1, 2023, to June 1, 2033. The SAF must reduce carbon emissions by at least 50% throughout its life to qualify for the credit. The credit applies to all SAF used in Illinois, regardless of where it is produced. | Sustainable Aviation Fuel Purchase Credits (SAFPC) are available to “air common carriers” that purchase or use sustainable aviation fuel (SAF) within Illinois, provided that the SAF meets specific criteria. | ENACTED | Aviation Fuel Sales and Use Tax (illinois.gov) |
| CORSIA | 1-Jan-2024 | Last Update: In October 2022, the 41st ICAO Assembly approved changes to the CORSIA program. | With a resolution A41-22 countries agreed on a new CORSIA baseline from 2024 onwards, defined as 85% of CO2 emissions in 2019, and on revised percentages for the sectoral and individual growth factors to be used for the calculation of offsetting requirements from 2030. | All aircraft operators subject to CORSIA reporting obligations must offset emissions from international flights between participating states. With an updated baseline established at 85% of 2019 CO2 emissions, operators will have offsetting requirements from the First Phase (2024-2026) onwards. | ENACTED; ICAO members approved changes to the CORSIA program at the 41st ICAO Assembly in October 2022. | https://www.icao.int/environmental-protection/CORSIA/Documents/Resolution_A41-22_CORSIA.pdf |
| EU Green Claims Directive | After enactment, member states have 36 months to adopt the new rules, likely taking effect around 2027. | Last Update: On March 12, 2024, the European Parliament adopted the Council's position at first reading. The negotiating position (General Approach) was adopted on June 17, 2024. The legislation is now ready to enter negotiations (known as “trilogues”) to reach a final agreement on the text, expected at the end of 2024 or the beginning of 2025 at the earliest. | The EU directive on the verifiability and communication of environmental product claims (Green Claims Directive) is intended to create transparency and give consumers the certainty that something advertised as environmentally friendly is. Consumers should be able to make informed purchasing decisions on the basis of comprehensible information. The Council's position introduces specific requirements for claims based on carbon credits and sets criteria for third-party verification, allowing for a simplified procedure in certain cases. It also permits new national or regional environmental labeling schemes subject to Commission approval. | The proposed requirements cover the majority of EU companies and non-EU companies targeting EU consumers, including aircraft operators. However, micro-SMEs, defined as companies with fewer than 10 employees or generating less than €2 million in annual turnover, will be exempt from these rules. Aircraft operators will need to substantiate and present their environmental claims in accordance with regulated guidelines. The directive prohibits broad environmental assertions such as 'environmentally friendly' or 'climate neutral' unless supported by evidence demonstrating outstanding environmental performance specific to the claim. Furthermore, it prohibits claims based on emissions offsetting schemes that suggest a product or service has a neutral, reduced, or positive environmental impact without sufficient evidence to support such claims. | PROPOSED; The Directive is set for the vote in the joint committee in February 2024. The file would then go to plenary in March 2024. However, these dates are yet to be confirmed. After enactment, EU member states have 24 months to implement these rules. | Proposal for a EU Green Claims Directive |
| California Low Carbon Fuel Standard Regulation (LCFS) 2024 Amendment | Proposed for 2024 | Last Update: The LCFS rulemaking process has been delayed and will extend through 2024. Next Update: The public hearing for this amendment is scheduled for Nov 8, 2024. The amendments, if approved by the Board, are expected to take effect in early 2025. | CARB has put forth amendments to the California low-carbon fuel standard with the goal of additional reductions in greenhouse gas emissions within the transportation sector. Essential aspects of the amendments involve monitoring the origin of biofuel feedstocks and mandating independent certification to mitigate impacts on carbon stocks. Additionally, the proposal eliminates the LCFS exemption for intrastate fossil jet fuel starting in 2028. | The proposed amendments to the LCFS program are set to affect the entire aviation industry, but particularly those operating intrastate CA flights. Approximately 10% of California's jet fuel consumption, which is attributed to intrastate flights, would generate deficits under the LCFS program, increasing costs starting in 2028. However, the addition of new deficit-generators should increase the value of the LCFS credits, decreasing the cost of SAF. | PROPOSED | https://ww2.arb.ca.gov/rulemaking/2024/lcfs2024 |
| Rotterdam The Hague Airport SAF Mandate | 1-Jan-2024 | Last Update: On November 16th, 2023, Shell and Rotterdam The Hague Airport (RTHA) signed a long-term agreement to blend SAF on all aircraft fuelled at the airport, starting in 2024. | In addition to the European ReFuelEU blending mandate of 6% by 2030, Rotterdam The Hague Airport (RTHA) is intensifying its efforts to achieve the Dutch aviation sector's more ambitious goal of 14% sustainable aviation fuel (SAF) by 2030. While the ReFuelEU regulation mandates Union airports to reach a 2% SAF blend by 2025 and 6% by 2030, RTHA aims to surpass these requirements by establishing a minimum extra target of 2% starting in 2024. The airport plans to incrementally increase this target by at least one percentage point each year until 2030, ensuring a total additional increase of at least 8 percentage points beyond the mandatory 6%. | Commencing with the 2024 2% Sustainable Aviation Fuel (SAF) mandate, this initiative is relevant to all aircraft operators refuelling at the airport. Business operators are reportedly subject to higher mandates than commecial aviation. | CONFIRMED | https://www.rotterdamthehagueairport.nl/en/rotterdam-the-hague-airport-accelerates-sustainable-fuel-blending/ |
| Hawaii Clean Fuel Standard (SB2768 SD1 HD1) | Proposed for 2026 | Last Update: March 14, 2024. The bill was passed by the Hawaii State Senate but did not make it through the House of Representatives. Next Update: We could possibly see this CFS become law in a future legislative session, but TBD. | Hawaii state Senate passed a bill mandating the creation of a clean fuel standard, which would set decreasing carbon intensity targets for certain covered transportation fuels against a set baseline, coupled with a credit market. | The credits market allows businesses from any sector that measurably reduces greenhouse gas emissions in the transportation fuel supply chain to generate valuable credits that can be sold. However, details of the clean fuel standard have yet to be clarified and approved by the Hawaii House of Representatives. If this standard follows suit with others (California, Washington, Oregon), it is expected that sustainable aviation fuel would qualify to generate credits, lowering the green premium there. | PROPOSED | Measure Status (hawaii.gov) |
| New Mexico Clean Transportation Fuel Standard (HB41) | 1-Jul-2026 | Last Update: This CFS became law in March 2024. The New Mexico Environmental Department regularly hosts committee working sessions as part of the Clean Transportation Fuel Advisory Committee’s implementation of the program. Next Update: Committee meetings are scheduled through September 2024, and program rules are expected to be proposed and released in late 2024. | New Mexico passed a law establishing a clean fuel standard, setting annually decreasing carbon intensity targets for certain covered transportation fuels against a set baseline coupled with a credit market. The New Mexico Environmental Improvement Board (NMIB) will be tasked with creating program rules and implementation. | The credits market allows businesses from any sector that measurably reduces greenhouse gas emissions in the transportation fuel supply chain to generate valuable credits that can be sold, but the details of the clean fuel standard have yet to be set in stone by the NMIB. It is expected that sustainable aviation fuel would qualify to generate credits, potentially stimulating production in New Mexico and lowering the green premium there. | ENACTED | NMED Clean Transportation Fuel Standard |
| Portuguese Carbon Tax | June, 2023 | Last Update: The tax was initially launched on July 1, 2021, impacting passengers on commercial flights. The order revision on July 1, 2023, expanded the tax scheme to include business jet flights. | The Portugal Carbon Tax is levied on all commercial and non-commercial flights departing from Portuguese territories. Exemptions include emergency diversions, fully electric aircraft, Public Service Obligation (PSO) flights on government-subsidized routes, state-owned aircraft, and search-and-rescue and medical evacuation flights. The Portuguese ANAC Agency oversees tax administration, ensuring compliance through flight data verification and inspections. | For flights on aircraft with a seating capacity of 19 or below, the tax is calculated using a formula based on the pollution coefficient, seating capacity, and distance travelled. | ENACTED | Ordinance No. 110/2023 (in Portuguese) |
| UK SAF Mandate | 1-Jan-2025 | Published on April 25, 2024, with legislation planned for parliamentary approval in 2024. | The UK SAF Mandate requires the increase of Sustainable Aviation Fuel (SAF) use at UK airports, targeting a rise from 2% in 2025 to 10% by 2030 and 22% by 2040. The mandate operates on a system of tradable SAF certificates, awarded to fuel suppliers based on the carbon reductions achieved compared to conventional jet fuel. It includes a power-to-liquid obligation and specific buy-out prices if sufficient supply does not exist, which also effectively sets a cap on the cost of SAF. Unlike ReFuel EU, there is no reporting requirement for aviation operators nor any minimum threshold for airport size meaning all UK airports would be included in the mandate. | Impacts UK Aviation Fuel suppliers required to supply SAF to UK airports. Should improve the availability of SAF at all UK airports. | PROPOSED | Pathway to net zero aviation: developing the UK sustainable aviation fuel mandate - GOV.UK (www.gov.uk) |
| Minnesota State SAF Tax Credit (S.F. No. 2753) | Available for SAF sold after June 30, 2024, and before July 1, 2030, for tax years beginning after December 31, 2023. | Last Update: Credit became law in August 2023 and became available for SAF on June 30, 2024. Next Update: TBD | The Minnesota State SAF Tax Credit created a $1.50/gallon incentive for SAF produced or blended in Minnesota with a 50% reduction in lifecycle greenhouse gas emissions compared to traditional jet fuel and is sold in-state to be used in aircraft departing from MN airports. | This incentive can be claimed by blenders and producers meeting specific criteria, which should reduce the cost of SAF delivered into MN for business aviation operators. | ENACTED | Sustainable Aviation Fuel Credit Minnesota Department of Revenue (state.mn.us) |
| Washington State SAF Tax Credit (SB 5447) | The first day of the first calendar quarter following the month in which the Department of Ecology receives notice that there is at least one Washington facility with a cumulative production capacity of 20 million gallons of SAF each year. Once it goes into effect, it will be active for 10 years. | Last Update: Credit became law in May 2023. Next Update: Once a Washington facility is capable of meeting the threshold, the credit will go into effect. | The Washington State SAF Tax Credit is aimed at promoting production in-state, creating a $1.00/gallon incentive for SAF that has a minimum 50% reduction in lifecycle greenhouse gas emissions compared to traditional jet fuel. The credit increases by 2 cents for each additional 1% reduction in carbon dioxide equivalent emissions beyond 50%, up to $2.00/gallon. | The incentive can be claimed by fuel producers or consumers (like airlines), but only once on any gallon. | ENACTED | Washington Senate Bill 5447-S.PL Text.pdf (wa.gov) |
| Washington State SAF Mandate (SB 6114) | If passed as currently written, the mandate would go into effect July 1, 2028. Similar to the Washington SAF Tax Credit passed in 2023, the Bill currently stipulates that the mandate will not go into effect until a local facility can produce at least 20 million gallons annually. | Last Update: Proposed January 2024, and the most recent amendment was made Feb 15, 2024. Next Update: This bill has been stalled in State Senate Committee since early 2024. There could be movement on a bill like this in a future legislative session. | As currently written, this Bill would mandate local airport operators to supply SAF with a minimum 10% blend for Part 91 aircraft operators. This Bill supports the Port of Seattle’s goal to use a 10% blend of SAF from local sources. | As currently written, the mandate would require local airport operators to provide SAF for use in private jets. | PROPOSED | Washington State Legislature |
| Nebraska SAF Tax Credit (LB937) | For taxable years beginning or deemed to begin on or after January 1, 2027, through January 1, 2035. But, a producer can only claim the credit for a total of five taxable years. | Last Update: Credit became law in April 2024. Next Update: TBD; Credit goes into effect in 2027. | The Nebraska State SAF Tax Credit created a $0.75/gallon incentive for SAF produced with a 50% reduction in lifecycle greenhouse gas emissions compared to traditional jet fuel. A supplemental $0.01 for every 1% carbon intensity improvement over 50% can be earned up to a maximum of $0.50 per gallon ($1.25/gallon total maximum). Credits can be claimed against NE income tax. | This incentive can be claimed by producers meeting specific criteria, which should reduce the cost of SAF delivered into NE for business aviation operators. | ENACTED | Nebraska Legislative Bill 937.pdf (nebraskalegislature.gov) |
| New York Clean Fuel Standard of 2024 (S1292A) | If passed as currently written, the act would take effect immediately. However, the standard’s rules and objectives would have 12 months after passing to be determined. | Last Update: Passed NY State Senate on June 7, 2024, but did not pass the NY Assembly. Next Update: We could possibly see this LCFS become law in a future legislative session, but unlikely before the November 2024 election. | If passed as written, this bill would have established a low carbon fuel standard (LCFS) intended to reduce transportation greenhouse gas emissions in NY. A LCFS sets annually decreasing carbon intensity targets for certain transportation fuels against a set baseline coupled with a credit market. While traditional aviation fuels would be exempt from the standard, SAF would be eligible to generate credits on an opt-in basis (similar to LCFS in California and Washington). Unlike other states' LCFS, NY would have some complexities to address in this standard around life cycle accounting, as NY state already has its own carbon accounting method in statute. | The credits market allows businesses that measurably reduce greenhouse gas emissions in the transportation fuel supply chain to generate valuable credits that can be sold, but the details of the clean fuel standard have yet to be set in stone. Including SAF to generate credits on an opt-in basis would help encourage the development of a viable SAF market, ushering in a highly desired SAF supply to the Northeastern US. | DID NOT PASS | New York Senate Bill S1292A |
| UK SAF Revenue Certainty Mechanism | The mechanism is planned to be delivered by the end of 2026. | The consultation, which closed on June 20th, 2024, is followed by the analysis of consultation responses and reporting to Parliament. The final mechanism delivery preparation with the industry, through the UK Jet Zero Council, is planned for completion by Q4 2026. | The mechanism aims to mitigate the risks of uncertain revenues for emerging SAF production. It should help attract investment into UK SAF projects and boost domestic UK SAF production. This growth will support meeting the demand from the upcoming UK SAF mandate. | It impacts various stakeholders in the aviation industry by reducing financial risks for SAF producers and encouraging investment in SAF projects. This will provide the business aviation industry, along with other aviation sectors, greater access to sustainable aviation fuels, potentially stabilizing fuel prices and ensuring a consistent supply. | PROPOSED | Revenue Certainty Mechanism for SAF: Delivery Plan |
| Singapore SAF Target, Mandate and Levy | 1-Jan-2026 | Last update: Rule announced by CAAS in February 2024. Next update: Further details on the SAF levy will be announced in 2025. CAAS will monitor SAF availability and developments before deciding the uplift target for beyond 2026. | The Civil Aviation Authority of Singapore (CAAS) announced plans to kickstart the adoption of SAF nationally, including: 1. A 1% uplift target, with a goal of raising the target to 3-5% in 2026. 2. A mandate that flights departing Singapore will be required to uplift SAF starting in 2026. 3. A SAF levy to achieve the uplift target and provide cost certainty to airlines/travelers. | The rule will apply to all operators departing Singapore, which is expected to include business aviation. Commercial travelers can expect to experience increased ticket prices due to the levy. | ANNOUNCED | Civil Aviation Authority of Singapore - Annex 1 Blueprint-Report-Exec-Summary.pdf (caas.gov.sg) |
| South Korea SAF Mandate | 1-Jan-2027 | Last Update: The rule was announced by the South Korean government on August 30, 2024. Next Update: TBD. The government should provide additional details (and potentially policy incentives) before 2027. | The announced South Korea SAF Expansion Strategy aims to increase SAF production and usage in the country. From 2024 to 2026, SAF use will be voluntary, with government support for domestic production of CORSIA-eligible SAF and its adoption on international flights by domestic airlines. Starting in 2027, when CORSIA becomes mandatory for all ICAO member states, the use of CORSIA-eligible SAF will be required for all international flights operated by domestic airlines, with a minimum 1% SAF blend, which may increase over time. | The rule will apply to all departing international flights from South Korea, which is expected to include business aviation. Commercial travelers may experience higher prices, though the South Korean government plans to support airlines with policy incentives to prevent higher airfares and encourage demand for flights using SAF. | ANNOUNCED | Ministry of Trade, Industry and Energy - SAF Diffusion Strategy Press Release (motie.go.kr) |
| China SAF Mandate | 1-Jan-2025 | Last Update: Introduced in 2024. Next Update: TBD | The Civil Aviation Administration of China (CAAC) has introduced a phased SAF blending mandate, starting with a 2% blend requirement by 2025, and gradually increasing to 15% by 2030. | This applies to domestic and international flights operated by Chinese aircraft operators, including business aviation. | PROPOSED | Modern Diplomacy: China’s New Policy on Sustainable Aviation Fuel |
| Turkey SAF Mandate | 1-Jan-2026 | Last Update: Public consultation launched in 2023. Next Update: TBD | Turkey is developing a regulation to promote SAF supply in the country and has launched a public consultation for the establishment of SAF blending mandate of 5% in 2030. | The regulation mandates fuel suppliers and applies to international flights operated by Turkish aircraft operators, including business aviation. | PROPOSED | SHT-SAF taslağı hazırlanmış olup sektör görüşüne açılmıştır | Sivil Havacılık Genel Müdürlüğü (shgm.gov.tr) |
| India SAF Targets | 1-Jan-2027 | Last Update: Announced November 25, 2023. Next Update: TBD | The India National Biofuel Coordination Committee (NBCC) has set the initial indicative SAF blending targets of 1% by 2027 and increasing to 5% by 2030 for international flights. | This applies to international flights operated by Indian aircraft operators, including business aviation. | PROPOSED | Press Release: Press Information Bureau (pib.gov.in) |
| Brazil SAF Mandate | 1-Jan-2027 | Last Update: The bill was approved by the Brazilian Chamber of Deputies on March 13, 2024. Next Update: TBD. The bill must be adopted by the Senate to be enacted. | The Brazilian Chamber of Deputies has approved the national SAF program, which is set to take effect in January 2027. The mandate aims to reduce aviation sector emissions by increasing SAF use by 1% annually, reaching 10% by 2037. | The proposed mandate requires Brazil's domestic operators to use SAF blends to reduce emissions, with flexibility for operators lacking SAF access or below a certain emission threshold. International operators may be included under reciprocal agreements. | PROPOSED | SAVi Five: Brazil SAF targets head for approval, new WEF report, and more… | Ishka (ishkaglobal.com) |
| Malaysia SAF Mandate | 1-Jan-2027 | Last Update: Announced in August 2023. Next Update: TBD | The Malaysian National Energy Transition Roadmap (NETR) proposes a 1% SAF blending mandate starting in 2027, alongside plans to incentivize investment in SAF production. The NETR also proposes a target of up to 47% SAF blending mandate 2050. | This would apply to SAF blenders, but the full details have not yet been made available. | PROPOSED | National Energy Roadmap: Energising the Nation, Powering Our Future |
| Indonesia SAF Mandate | 1-Jan-2027 | Last Update: Announced on September 18, 2024. Next Update: TBD | The Indonesia SAF Roadmap and Policy Action Plan aims to implement a phased SAF blending mandate, starting with a 1% SAF blend requirement by 2027 and gradually increasing to 50% by 2060. | This is intended to apply to international flights departing from Indonesia, including business flights. | PROPOSED | Indonesia to require SAF for flights from 2027 | Latest Market News (argusmedia.com) |
| Japan SAF Mandate | 1-Jan-2030 | Last Update: Announced May 26, 2023. Next Update: Additional information expected in 2024. | Japan’s Ministry of Economy, Trade, and Industry (METI) announced plans for a SAF-focused biofuel target, requiring volumes of 10% SAF by 2030. | The rule applies to all domestic fuel producers (required to produce 10% SAF) and operators flying internationally out of Japanese airports (required to uplift 10% SAF). This is expected to include business aviation operators. | PROPOSED | InfluenceMap Japan Sustainable Aviation Fuel (SAF) mandate |
| French Solidarity Tax (TSBA) | 1-Jan-2025 | Last Update: Proposed by the French government in October 2024. Next Update: TBD – however the regulation continues to evolve rapidly | The French Solidarity Tax, introduced in 2005, is levied on passengers departing from airports located in French territory. The tax is associated with the French Eco Tax from 2020. French government is proposing the significant increase of the tax rate from 2025. | The proposed 2025 French aviation tax rates include a substantial increase over the current tax, which ranges from €2.63 to €63.07 per passenger, depending on the destination and travel class. While still under review, the proposed rates vary by destination, service class, and aircraft engine type and are charged per passenger: European or Similar Destination: - Economy: €9.50 - Business & 1st Class: €30 - Business aircraft with turboprop engine: €300 - Business aircraft with turbojet engine: €600 Intermediate Destination: - Economy: €15 - Business & 1st Class: €80 - Business aircraft with turboprop engine: €1,000 - Business aircraft with turbojet engine: €1,500 Long-Distance Destination: - Economy: €40 - Business & 1st Class: €120 - Business aircraft with turboprop engine: €1,500 - Business aircraft with turbojet engine: €3,000 | PROPOSED | Finance Bill for 2025 (No. 324) Amendment No. I-3737 - National Assembly |
| Swedish Aviation Tax Abolishment | 1-Jul-2025 | Last Update: Announced in September 2024. Next Update: TBD | The aviation tax has been in effect in Sweden since 2018 and imposes a levy on each passenger departing from Swedish airports. The Swedish government has proposed abolishing this tax to boost economic activity and enhance the competitiveness of the Swedish air transport sector. | The tax ranges from SEK 76 to 504 (approximately US$7.4 – 49) depending on the destination, and is applied to each passenger departing from Swedish airports. There are exemptions for transit passengers and certain other categories. This tax is imposed on flights operated by aircraft with more than 10 seats. | PROPOSED | IATA - IATA Welcomes Abolition of Swedish Aviation Tax |
| UK Air Passenger Duty (APD) | 1-Apr-2026 | Last Update: Published with Finance Bill 2024-25 on November 7, 2024. Next Update: Expected to be enacted by March 31, 2025, with the public consultation on including all business aircraft above 5.7 tonnes in the Higher Rate concluding on January 22, 2025. | The UK Air Passenger Duty (APD), introduced in 1994, is a tax levied on passengers departing from UK airports on aircraft above 5.7 tonnes. It applies to flights based on distance bands and class of travel. | The 2026 UK Air Passenger Duty (APD) rates introduce notable increases, especially for passengers using business aircraft. Set to take effect from April 1, 2026, APD rates are charged per passenger and vary by distance band and travel class. The proposed APD rates per passenger are as follows: Domestic UK Band: - Reduced Rate: £8 - Standard Rate: £16 - Higher Rate: £142 Band A (0 to 2,000 miles): - Reduced Rate: £15 - Standard Rate: £32 - Higher Rate: £142 Band B (2,001 to 5,500 miles): - Reduced Rate: £102 - Standard Rate: £244 - Higher Rate: £1,097 Band C (over 5,500 miles): - Reduced Rate: £106 - Standard Rate: £253 - Higher Rate: £1,141 Notes: - Reduced Rate: Economy Class - Standard Rate: Premium Economy, Business, First Class, and Business Aircraft below 20 tonnes - Higher Rate: Business aircraft above 20 tonnes with fewer than 19 seats. A public consultation is open until January 22, 2025, regarding the inclusion of all business aircraft in the Higher Rate. | PROPOSED | Air Passenger Duty: rates from 1 April 2026 to 31 March 2027 - GOV.UK |
Note: This list of regulations here only reflects upcoming regulations that may affect business aviation operators; however, it is not exhaustive and should not be treated as legal guidance.
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