Flexibility options for the ReFuelEU review 2026

Sustainable Aviation Fuels (SAF) are considered – at least in the medium term – to be a key lever for decarbonising air transport. The EU's ReFuelEU Aviation Regulation sets binding targets for the aviation sector to increase the share of SAFs in the fuel mix supplied. To this end, SAF quotas and sub-quotas for e-SAF must be met, which will become more stringent after specified periods of time. A review is scheduled for 2026 under ReFuelEU Aviation. In the run-up to this, the regulation is under pressure (including debates on feasibility, competitiveness and carbon leakage risks), with a particular focus on the ramp-up of synthetic fuels and the associated sub-targets. The aim of the project is to identify and evaluate viable flexibility and protection mechanisms for the further development of the regulation and to classify them in such a way that legitimate implementation issues are addressed without weakening the climate protection ambition.

The project addresses the key question of how flexibility and safeguard mechanisms can be designed without undermining the regulatory ambition (especially with regard to the e-SAF sub-targets). It examines the expected quantitative and qualitative effects on e-SAF ramp-up, prices and stakeholder support, as well as the question of which mechanisms are viable in terms of industrial policy. In addition, options are considered to determine the extent to which alternative compliance approaches (e.g. via climate-friendly aviation technologies) or measures such as a HEFA cap or targeted multipliers influence the balance between SAF pathways. The options identified will be analysed along clear evaluation dimensions (including technical/administrative feasibility, political feasibility, expected acceptance, cost and market effects including competition aspects, socio-economic effects and environmental integrity including fraud/double counting risks).