- Regulation (EU) 2023/2405 has required EU fuel suppliers to blend a minimum 2% sustainable aviation fuel since 1 January 2025, rising to 6% in 2030 and 20% in 2035.
- Book-and-claim separates the environmental attribute from the physical uplift: the client's aircraft may burn no SAF at all. That distinction must be disclosed, not glossed.
- The mandate falls on fuel suppliers at qualifying Union airports, not on the broker — but the cost reaches the quote, and the client will ask who is paying for it.
- Only claim what a registry certificate substantiates. 'Carbon neutral' language on the back of an unverified attribute purchase is the single most likely source of a greenwashing complaint against a brokerage.
The rule that actually applies
The regulation brokers need to understand is ReFuelEU Aviation, Regulation (EU) 2023/2405. It places an obligation on aviation fuel suppliers, not on operators and certainly not on brokers, to blend a minimum share of sustainable aviation fuel into the jet fuel they supply at Union airports. That minimum has been 2% since 1 January 2025.
The trajectory is what matters commercially. EASA's summary of the policy actions sets out the step changes: 6% from 2030, 20% from 2035, and 70% by 2050, with a separate synthetic e-fuel sub-mandate starting at 0.7% in 2030 and reaching 35% by 2050. A brokerage writing multi-year corporate charter agreements today is writing them across at least one of those steps.
Scope is narrower than the headline suggests. The obligation attaches to Union airports above defined traffic thresholds — broadly, those handling more than 800,000 passengers or 100,000 tonnes of freight a year. A good deal of business-aviation activity departs from airfields below those thresholds, which is precisely why brokers should not assume that a departure from an EU state automatically carries blended fuel.
The European Commission published clarification of the market and of the compliance flexibility mechanism in February 2025, which allows suppliers to meet obligations across their network rather than airport by airport. The practical consequence for a broker is that blending is a network-level accounting outcome, not a guarantee about the fuel in a specific wing.
How book-and-claim works
Physical SAF is available at a limited number of airports. Book-and-claim exists to decouple the purchase of the fuel's environmental benefit from the geography of its uplift. A buyer pays for a defined quantity of SAF, the fuel is uplifted wherever it is physically available, and the associated environmental attribute is retired in a registry against the buyer's account.
This is a legitimate, audited mechanism when it runs through a recognised certification scheme, and it is the only realistic route for the majority of charter flights. Airbus and the Roundtable on Sustainable Biomaterials expanded access to a book-and-claim programme in March 2025, with business-aviation operators including Comlux and Luxaviation among the early participants, as reported by AIN. Consumer-facing routes exist too: Wheels Up, working with Chooose, offers charter and group-charter customers the ability to buy SAF attributes irrespective of the departure airport or the operator flown.
The critical honesty point is set out plainly by practitioners in the field, including Azzera's 2025 explainer: under book-and-claim, the SAF is not necessarily uplifted into the aircraft the client flies on. A broker who allows a client to believe otherwise has misrepresented the product, whatever the underlying certificate says.
Where charter sits in the system
Business aviation's position in the wider decarbonisation framework is contested. Full auctioning under the EU Emissions Trading System has arrived for aviation, and the Commission's Delegated Regulation (EU) 2025/927 of 20 May 2025 updated monitoring, reporting and verification rules to align the EU regime with ICAO's CORSIA scheme. Costs arising from both flow into operator pricing and, ultimately, into the broker's quote.
In July 2026 the Commission proposed a targeted revision of the ETS. The European Business Aviation Association warned publicly that the proposal risks unequal treatment of the sector by extending obligations while leaving business aviation outside parts of the SAF uptake support available to scheduled carriers. Whatever one's view of the merits, brokers should expect surcharges attributed to emissions compliance to become a standing line item in operator quotes.
For an operator-side benchmark on what genuine uptake looks like, Airbus reported that 18% of the fuel used on its own corporate flights in 2024 was SAF. That is a useful yardstick when an operator claims a materially higher figure without documentation.
Claims discipline
Environmental claims are consumer-protection territory. A charter brokerage that describes a flight as 'carbon neutral', 'SAF-powered' or 'net zero' is making a factual representation to a purchaser, and it must be able to evidence it from a document rather than an intention.
The workable discipline is a three-part test applied before any green language reaches a proposal. First, is there a certificate, from a recognised scheme, naming a retired quantity and a retirement date? Second, does the wording distinguish physical uplift from a book-and-claim attribute? Third, is the emissions baseline against which any percentage is stated identified and reproducible?
Where any of the three fails, the correct action is to describe the mechanism rather than assert the outcome: 'the operator has purchased and retired SAF attributes covering an estimated X tonnes of CO2e for this trip through [scheme]' is defensible. 'This flight is carbon neutral' generally is not.
Handling it at the desk
Corporate clients with their own reporting obligations increasingly need the underlying documentation, not a reassurance. Ask for the scheme name, the certificate or retirement reference, the quantity, and the date. Store them with the trip file; they are the only thing that will help if the client's sustainability team asks a question a year later.
Price transparency matters as much as the environmental substance. If a SAF premium is being passed through, show it as a separate line with the basis of calculation. Clients tolerate a premium they understand far better than a rounded-up all-in figure they cannot audit.
Finally, be candid about limits. No broker controls which molecules an operator uplifts. What a broker can control is the accuracy of the representation, the quality of the documentation trail, and the client's understanding of what they have actually bought.
Practical checklists
- Confirm whether the offer is physical uplift or book-and-claim, in writing
- Obtain the certification scheme name and registry reference
- Record the quantity purchased and the retirement date
- Identify the emissions baseline and methodology used for any percentage claim
- Show the SAF premium as a separate, explained line item
- No unqualified 'carbon neutral' or 'net zero' wording
- Any environmental claim traceable to a document in the trip file
- Book-and-claim disclosed in the client-facing text, not only in the annex
- Estimates labelled as estimates
Frequently asked questions
- If my client buys book-and-claim SAF, does their flight actually burn SAF?
- Not necessarily, and usually not. Book-and-claim decouples the environmental attribute from the physical uplift; the fuel is delivered wherever it is available and the attribute is retired against your client's account. Disclose this explicitly.
- Can I market a charter as carbon neutral if the client buys SAF certificates?
- Treat that phrase as unsafe unless you hold documentation supporting the full claim, including the baseline and the retired quantity. Describing the mechanism and the tonnage covered is defensible; asserting a neutral outcome generally is not.
- Does the 2% mandate apply to charter flights?
- The obligation sits with fuel suppliers at qualifying Union airports rather than with any particular flight category. Departures from smaller airfields below the traffic thresholds are outside the scope, so blending should never be assumed for a specific trip.
- How do I verify an operator's SAF claim before charging a premium?
- Ask for the certification scheme, the registry retirement reference, the quantity and the date. If an operator cannot produce those four items, do not pass a green premium on to the client.
- • The mandate binds fuel suppliers, not brokers — but its cost reaches your quote.
- • Book-and-claim is legitimate and must be disclosed as an attribute purchase.
- • No certificate, no claim: language must be traceable to a document.
- • Show SAF premiums as separate, explained line items.