Beyond Carbon and SAF: The Regulatory Themes Shaping Aviation's Compliance Picture

Most aviation policy roundups cover the same two themes: carbon pricing and SAF mandates. They're important, but they're not the whole picture.

When we mapped the regulatory obligations we see affecting airline sustainability, operations, and compliance teams most, we identified eight distinct policy themes across more than 25 jurisdictions — with over 40 obligations at various stages of implementation. Many of them are either already in force or arrive before the end of 2026.

This is what we found.

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What's already in force: H1 2026

EU ETS zero free allowances

The EU removed all remaining free aviation allowances at the start of 2026. Following a 50% cut in 2025, airlines on intra-EEA routes now face the full commercial cost of their emissions. CORSIA Phase 1 obligations run simultaneously, meaning European route operators face carbon pricing from two directions at once.

ReFuelEU and UK SAF Mandate

Both the EU's ReFuelEU Aviation regulation and the UK's Renewable Transport Fuel Obligation mandate a 2% SAF blend from 2025. The UK target rises to 10% by 2030 — a figure comprising a 9.5% main obligation and a 0.2% Power-to-Liquid sub-obligation from 2028 (rising to 0.5% PtL by 2030), rising further to 22% by 2040. Anti-tankering provisions are active under ReFuelEU.

CORSIA Phase 1 — first real offsetting costs

ICAO confirmed the 2024 sector growth factor at 0.154, triggering the first substantive offsetting obligations for airlines operating international routes. IATA projects $1.7 billion in industry compliance costs for 2026 alone.

nvPM limits in force

Non-volatile particulate matter limits have been active since 2023 for engines above 26.7 kN thrust. Fleet procurement decisions must now factor these into type certification requirements.

Dubai single-use plastics ban

Phased since 2024, the Dubai SUP ban covers plastic and non-plastic single-use items in airport and airside facilities, reaching full effect through 2026. Airlines operating into and through UAE airports face direct catering and service implications.

What's landing in H2 2026

EU Packaging and Packaging Waste Regulation (PPWR) — August 2026

This is the piece of legislation most aviation sustainability teams haven't modelled. The PPWR applies from August 2026 and directly affects in-flight catering: PFAS limits on food contact materials, extended producer responsibility obligations, and reuse targets. Combined with EUDR and single-use plastics directives, three separate regulatory threads now converge on airline catering supply chains.

Singapore SAF passenger levy — October 2026

Singapore introduces the world's first passenger-level SAF levy from October 2026, applying to tickets sold from April 2026. Rates range from S$1.00 to S$41.60 depending on cabin class and route distance. The rate is fixed while Singapore's 1% SAF target applies, with the target expected to rise to 3–5% by 2030. The levy model is likely to be studied closely by other Asian hub operators.

EUDR — large and medium operators — 30 December 2026

Under Regulation 2025/2650 (published December 2025), large and medium operators face a supply chain traceability deadline for deforestation-risk commodities including palm oil, soy, and timber. Airline catering procurement chains are in scope.

Australia mandatory climate disclosures

Australia's Group 1 entities (revenue >Australia's largest listed reporters begin mandatory climate disclosures from 2026. Carriers and aviation-adjacent businesses listed on the ASX face Scope 1–3 reporting requirements in line with Australian accounting standards.0m, assets >bn, or >500 employees) are required to report from financial years beginning 1 January 2025, with first reports due in H1 2026. Group 2 entities follow from July 2026, Group 3 from July 2027. Carriers and aviation-adjacent businesses in scope face Scope 1–3 reporting requirements aligned with Australian accounting standards.

Netherlands and Germany aviation departure taxes

Both remain active and are meaningfully additional to EU ETS. The Netherlands charges €30.25 per departing passenger (2026 rate; was €29.40 in 2024–25), with a tiered long-haul system planned from 2027. Germany's Luftverkehrsteuer was raised 19% in May 2024 and now stands at €15.53 (short-haul), €39.34 (medium-haul), and €70.83 (long-haul); the Merz government has confirmed a reduction back to pre-May 2024 rates from 1 July 2026 as part of the CDU/SPD coalition package agreed November 2025 (estimated cost to government: approximately €350m per year). These are separate from environmental charge mechanisms at individual airports such as Copenhagen's CO₂ surcharge and Prague's NOx-linked fees.

The planning horizon: 2027 and beyond

The regulatory obligations that take effect from 2027 onwards require decisions now. Fleet procurement, supply chain restructuring, and compliance architecture all carry lead times longer than the timelines suggest.

CORSIA Phase 2 — mandatory from 2027

CORSIA Phase 2 makes offsetting mandatory for all ICAO member states, with limited exemptions for Least Developed Countries, Small Island Developing States, Landlocked Developing Countries, and smaller aviation markets. China, India, and Brazil enter the scheme for the first time. Airlines operating global network routes face the most complex route-by-route compliance picture of any carrier type.

SAF mandates expanding across Asia and South America

Brazil's Future Fuel Law (enacted October 2024) mandates a 1% GHG reduction on domestic flights from 2027, rising to 10% by 2037. Crucially, this is expressed as a GHG emissions reduction target rather than a volumetric blending percentage — a structural difference from EU and UK mandates that matters for compliance planning. South Korea's 1% mandatory blend and India's 1% target both activate in 2027. Canada's blending provisions follow in 2028.

ICAO CO₂ production cut-off — 2028

All in-production aircraft must meet ICAO Annex 16 Vol III CO₂ standards by 2028. Aircraft type orders placed in 2025–26 determine which fleets remain commercially and regulatorily viable on medium and long-haul routes for the following decade.

UK Carbon Border Adjustment Mechanism — January 2027

The UK CBAM creates aviation exposure via energy inputs and upstream supply chain materials. Airlines with UK-based operations importing goods from higher-carbon manufacturing jurisdictions will face additional cost pressure.

EUDR micro and small operators — June 2027

The second EUDR deadline applies to micro and small primary operators. Downstream non-SME traders face lighter obligations under the revised regulation, but catering supply chains remain in scope.

CSDDD — scope finalised, application July 2029

The Corporate Sustainability Due Diligence Directive was finalised via the EU Omnibus I package in December 2025 (passed 428–218). The scope applies to companies with more than 5,000 employees and €1.5bn global turnover. The CSDDD transition plan implementation requirement was removed; the CSRD obligation to report on climate transition plans in the sustainability statement was retained. CSDDD application is deferred to July 2029, but due diligence programme development takes significant lead time.

Six regulatory blind spots

Standard aviation policy coverage focuses on carbon pricing and SAF. These six areas get far less attention — and they're where most compliance exposure is being missed.

1. In-flight catering packaging

PPWR, EUDR, and single-use plastics directives converge on airline catering procurement. Most sustainability teams have not modelled this triplepoint exposure.

2. Green Claims enforcement — happening now, not after 2027

The EU Green Claims Directive has been suspended since June 2025, following the Commission's announcement of its intent to withdraw the proposal. The Commission has since clarified it has not been formally withdrawn — but the legislative process is effectively halted with no confirmed timeline for resumption. However, the Empowering Consumers for the Green Transition Directive (ECGT) independently bans offset-based carbon neutral consumer claims from 27 September 2026. National consumer authorities across the EU are already enforcing against misleading environmental claims. Airlines using offset-based messaging face immediate legal exposure — not a future risk.

3. Airport-level charges as a new route cost layer

Copenhagen's CO₂ surcharge, Prague's NOx-linked fees, Warsaw's LTO cycle levies, Hungary's emissions-based departure tax — and Amsterdam and Heathrow both watching for new schemes post-2026. These charges don't appear in standard regulatory roundups, but they directly affect route P&L calculations.

4. Non-CO₂ warming effects and contrail MRV

The EU's mandatory monitoring, reporting, and verification framework for contrails and non-CO₂ warming effects is a precursor to pricing those effects. The methodology dispute is not resolved. It will define financial exposure for long-haul carriers — and it hasn't been fully priced in yet.

5. US federal deregulation risk

The IRA 45Z SAF tax credit was reduced by the OBBBA (signed 4 July 2025) from $1.75/gallon to $1.00/gallon for SAF produced after 31 December 2025, and extended to 2029. Federal rollback diverges from California Cap-and-Trade obligations and CORSIA commitments. Airlines serving US domestic and international routes simultaneously face asymmetric rule sets that standard compliance models do not handle well.

6. Fleet decisions with permanent regulatory consequences

ICAO's 2028 CO₂ production cut-off is not a future problem. Aircraft currently in the order pipeline will either meet the standard or not. Fleet decisions made in 2025–26 determine regulatory viability on major route categories for the next 15–20 years.

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