ConfidentialSAF/E-SAF: delays expected in the Commission’s implementation of the regulatory framework

Delays and overlaps in the assessment and review of RefuelEU Aviation

Originally scheduled for 1 January 2027, the evaluation of the RefuelEU Regulation (which, since 2024, has governed the timetable and procedures for incorporating SAF and e-SAF into aviation fuel) is currently running late and is not expected to be finalised before mid-2027: “The external consultants who will support this evaluation of RefuelEU had not yet been selected by DG MOVE as of June 2026,” says a source close to the matter.

Whilst it would be logical for this assessment to be published prior to any revision of RefuelEU, the Commission has already published, in August 2026, on its ‘Have Your Say’ public consultation portal, an announcement of a call for contributions in the second quarter of 2027 for a targeted review of RefuelEU in the fourth quarter of 2027. This announcement therefore appears to confirm the decision to carry out a review even before the results of the evaluation are known.

An ordinary legislative procedure under the co-decision process with the Council and Parliament, which is synonymous with uncertainty and prolonged delays

The Commission has announced that the forthcoming review will take the form of an ordinary legislative procedure under the co-decision process. It will therefore involve both the Parliament and the Council, who may broaden the scope of the review (currently limited to issues relating primarily to administrative simplification), and call into question the entire regulatory framework established to date by RefuelEU, particularly with regard to the mandates for the blending of SAF and e-SAF.

In addition to this further uncertainty, the choice of the co-decision procedure, rather than secondary legislation (an implementing act), will inevitably result in a longer legislative process, whilst the entry into force of the e-SAF blending mandates set out in the text remains scheduled for 2030.

With the publication of a Commission proposal due at the end of 2027, negotiations are expected to be concluded by the end of 2028, or possibly during 2029. This delay in the timetable correspondingly postpones the establishment of a stable regulatory framework, an essential condition for the conclusion of Final Investment Decisions (FIDs) for the various e-SAF production site projects in Europe. As announced by the Commission on 17 September 2026, there are 50 e-SAF projects awaiting FID in Europe, and only one industrial demonstrator has been built so far, constructed in 2025 by Ineratec in Frankfurt (Germany).

Initiatives in support of e-SAF from the Commission and Member States, but delays in the projected timetables

When asked about the various delays in publishing the regulations governing SAF and e-SAF, a Commission spokesperson told News Tank, on 16 September 2026, that “no, the regulatory framework for the production of e-SAF is not behind schedule. We already have the ‘ReFuelEU Aviation’ Regulation, which establishes a long-term framework for the deployment of sustainable aviation fuels (SAF) and synthetic sustainable aviation fuels (e-SAF) in the EU and beyond. It is important to maintain the level of ambition of these rules in order to safeguard the stability of investments in the SAF value chain, particularly in capital-intensive sectors such as e-SAFs. In this regard, the forthcoming review will focus primarily on targeted simplification and technical adjustments, whilst preserving the ambition and objectives of the ‘ReFuelEU Aviation’ Regulation.

Recalling that “most investment in sustainable fuels will have to come from the private sector, but also from Member States”, the Commission spokesperson highlighted two e-SAF funding mechanisms included in the Sustainable Transport Investment Plan (STIP), announced for the end of 2025:

• “The Commission has brought together eight Member States (Austria, Finland, France, Germany, Luxembourg, the Netherlands, Portugal and Spain) to launch the ‘eSAF Early Movers’ coalition. Three Member States have made €2.1 billion available for the organisation of double sided auctions for e-SAF. The aim is to set up these double sided auctions as soon as possible, in early 2027. The Commission is working with the Member States to facilitate their technical work.
• The Commission is currently considering the establishment of a European funding mechanism for e-SAF. A study is under way to examine various options for the design of a suitable auction system and governance framework; this will help the Commission to make this mechanism operational."

The Commission’s ambitions and genuine commitment to developing SAFs and e-SAFs are in no way questioned by the stakeholders involved, but there have been genuine delays in this area: for instance, the Commission’s website states that the first sale under the double sided auction system is scheduled for 2026.

"The Commission wishes to maintain the stability of the mandates, but there is a real risk that the scope of the review will be broadened by the Council or Parliament.

“The Commission wishes to preserve the stability of the mandates, but there is a real risk that the scope of the review will be broadened by the Council or Parliament. As regards e-SAF, project developers are calling for clarity on the regulatory framework so that they can unlock investment and launch industrial operations that will enable them - even now - to meet the 2030 deadline. At present, the uncertainty surrounding the scope of the review is worrying investors and providing critics of RefuelEU - which include virtually all airlines - the opportunity to criticise the delays incurred by European project leaders and thus call for flexibility, extensions, or even the cancellation of the mandates for e-SAF blending,” adds this expert on the matter.

And, if the 1.2 per cent e-SAF blending mandate is indeed maintained for 2030, in the absence of a ‘made in Europe’ e-SAF supply chain, the alternative for airlines will be to source from non-European producers.

With three of the four regulatory texts governing SAF and e-SAF still pending, delays are to be expected

In addition to the evaluation/revision of ReFuelEU mentioned above, three other regulations govern the development of SAFs; the Aviation Strategy, which is the policy counterpart to ReFuelEU, initially expected in the third quarter of 2026, and which is also falling behind schedule, as recently confirmed by a member of DG Move; and finally, the RFNBO (renewable fuels of non-biological origin) delegated act, originally expected in June 2026, and currently postponed until autumn 2026.

To date, only the support mechanism for SAFs, via free ETS allowances allocated to airlines, has remained on schedule, with the publication of a Commission proposal this summer, but the target of a first trilogue in January 2027 still seems uncertain, whilst work has not yet begun in Parliament.