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 06/03/2026
| 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 would have been due in 2026 for Fiscal Year 2025 reporting (depending on entity size). | Last Update: The rule was adopted by the SEC, but has been stayed since April 2024. The rule has been the subject of litigation in Federal Court, and in February 2025 the SEC Acting Chairman asked the Court not to schedule the case for argument, halting litigation. Next Update: The SEC Chairmen has stated that the Commission will deliberate to determine the appropriate next steps in these Court cases, though the timeline is TBD. | 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 | Acting Chairman Statement on Climate-Related Disclosure Rules |
| California SB 219, Greenhouse Gases: Climate Corporate Accountability & Climate-Related Financial Risk (previously two separate laws, SB253 and SB261) | 1-Jan-2026 | Last Update: On 24 June 2026, CARB deferred the deadline for reporting entities to report Scope 1 and Scope 2 greenhouse gas emissions under SB 253 from 10 August 2026 to 10 November 2026, to allow time for formal adoption of the regulation. CARB has approved regulations for SB253 and SB261, but the U.S. Ninth Circuit Court of Appeals temporarily halted SB261, and some qualifying entities have voluntarily submitted their SB261 disclosures. Next Update: CARB will propose limited clarifying changes to the regulation, released for a 15-day public comment period. The final regulatory package still requires approval by California's Office of Administrative Law. | 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. Following legal challenges and a widely held desire to push back the clock on SB253 and SB261, SB219 was passed to (slightly) amend the timeline of implementation. | The bill applies to businesses, including aircraft operators, with total annual revenues of 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. CARB’s 2024 Enforcement Notice indicated that no penalties will be enforced for incomplete reporting in 2026. | ENACTED | CARB approves climate transparency regulation for entities doing business in California |
| California Voluntary Carbon Market Disclosures Act (AB1305) | 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. The 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 2024: The yearly Emissions Allowances surrender deadline is changed from 30 April to 30 September. 3. From 2024: New emission factor for kerosene: 3.16 tCO2/t fuel. 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. | EUR-Lex - L:2023:130:TOC - EN - EUR-Lex (europa.eu) |
| UK ETS Aviation Reform | 1 January 2026 (aviation free allocation fully withdrawn) | Last Update: The phase-out completed on 1 January 2026. Aviation free allocation was withdrawn on the announced trajectory and UK ETS aircraft operators now receive zero free allocation. The UK ETS Authority also confirmed the 2027-2030 allocation period in November 2025. Next Update: A joint UK, Scottish, Welsh and Northern Ireland government consultation, 'UK Emissions Trading Scheme: Impact of End of Aviation Free Allocation on Regional Connectivity', closed on 19 December 2025. The Authority's response may lead to relief measures for regional routes. | 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. | ENACTED The phase-out of aviation free allocation announced by the UK ETS Authority in July 2023 completed on 1 January 2026. This record was previously carried as PROPOSED in error. | 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 | N/A - proposed rule withdrawn before finalisation | Last Update: DoD, GSA and NASA withdrew the proposed rule on 13 January 2025 and closed FAR Case 2021-015. The withdrawal notice cited insufficient time to finalise the proposal, the volume of public comments, and an evolving domestic and international regulatory landscape. Next Update: None scheduled. The FAR Council left open the possibility of a future rulemaking, noting anticipated movement toward more uniform use of GHG standards. | 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. | No obligation now exists. Following the withdrawal there is no uniform, government-wide requirement for federal contractors to disclose greenhouse gas emissions or set reduction targets in order to obtain federal contracts. Corporate flight departments and managed aircraft operators supporting federal contractors are unaffected by this rule. Operators may still face equivalent disclosure demands through state regimes such as California SB 219 or through customer supply-chain requirements. | WITHDRAWN The proposed rule published 14 November 2022 was withdrawn as of 13 January 2025 and the FAR case is closed. | Federal Register: Withdrawal - FAR 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 24 months to adopt the new rules, likely taking effect around 2026. | Last Update: On March 12, 2024, the European Parliament adopted its first-reading position on the Green Claims Directive. The Council's General Approach was adopted on June 17, 2024, setting the stage for the next phase of the legislative process. Next Update: Trilogue negotiations between the European Parliament, the Council, and the European Commission are expected to commence in late 2025, aiming to reach a final agreement on the text. | 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 that is advertised as environmentally friendly actually is. Consumers should be able to make informed purchasing decisions on the basis of comprehensible information. | 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 | 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 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 | CA Low Carbon Fuel Standard Amendments |
| 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 | Rotterdam The Hague Airport SAF |
| Hawaii Clean Fuel Standard (SB2999/HB1986) | 1-Jan-2029 | Last Update: The bill was introduced in Hawaii's Senate and House in January 2026. The bill passed the Hawaii legislature in Spring 2026 and is expected to be signed by the Governor. Next Update: Program rules will need to be adopted by January 1, 2028, and the program will be implemented by January 1, 2029. | This bill would mandate the creation of a clean fuel standard in Hawaii, 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. | PASSED LEGISLATURE | Measure Status Details for SB 1120 (hawaii.gov) |
| New Mexico Clean Fuel Transportation Standard (HB41) | 1-Apr-2026 | Last Update: This CFS became law in March 2024, and New Mexico formally adopted regulations to implement the program in January 2026. Next Update: New Mexico is targeting April 1 as its opening date. | New Mexico established a clean fuel standard, which sets annually 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. SAF can qualify to generate credits, potentially stimulating production in New Mexico and lowering the green premium there. However, this program sets a relatively low carbon intensity baseline value for conventional jet fuel, meaning it will be easier and more profitable to generate credits for renewable diesel instead of SAF. | 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 | Last Update: Published on April 25, 2024, and formally approved through the Renewable Transport Fuel Obligations (SAF) Order 2024, which was enacted on November 18, 2024, and came into force on January 1, 2025. | 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. | ENACTED | About the SAF Mandate - GOV.UK |
| Minnesota State SAF Tax Credit (SF2753, and extended under HF2438) | Applies to SAF sold July 1, 2024 through June 30, 2035; retroactive for tax years beginning after Dec. 31, 2024 | Last Update: Credit became law in August 2023 and became available for SAF on June 30, 2024. Next Update: Following an extension and credit expansion by the Minnesota legislature in May 2026, the credit is now available through 2035. | The original 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. The credit was later expanded, with the total incentive increasing by $0.02/gal for each additional percentage of carbon intensity reduction. Amongst other provisions, it was given a five-year extension to 2035 and now limits eligible fuels to those made from domestic feedstocks. | 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; AMENDMENT ENACTED | Sustainable Aviation Fuel Credit Minnesota Department of Revenue (state.mn.us) |
| Washington State SAF Tax Credit (SB 5447); Amendment Proposed (SB5932/HB2322) | 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: The credit became law in May 2023, and an amendment was introduced in January 2026. 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/gal incentive for SAF that has a minimum 50% reduction in lifecycle greenhouse gas emissions compared to traditional jet fuel. The credit increases by $0.02 for each additional 1% reduction in carbon dioxide equivalent emissions beyond 50%, up to $2/gal. The proposed amendment would: -Extend the tax credit to July 1, 2051, and allow claimants (producers or consumers) to earn credits for 10 years -Delay a reduced business tax rate for alternative jet fuel production until there is at least one WA facility with a cumulative production capacity of 20 million gallons of SAF each year, or July 1, 2031 - whichever comes first. Producers would be able to claim this reduced tax rate for 10 years. | 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. The increased amount available specifically incentivizes SAF with a lower carbon intensity score. | ENACTED; AMENDMENT PROPOSED | SB 5447 - Promoting the alternative jet fuel industry in Washington | Washington State Legislature |
| Washington State SAF Mandate (Senate Bill 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); Amendment Proposed (LB8) | For taxable years beginning January 1, 2027. But, a producer can only claim the credit for a total of five taxable years. Amendment: For taxable years beginning January 1, 2028, with no limit to the number of year a producer can claim the credit | Last Update: The credit became law in April 2024 and an amendment was proposed in January 2026. Next Update: The credit currently goes into effect in 2027, but if the amendment is passed, it will be effective in 2028. | The Nebraska State SAF Tax Credit created a $0.75/gal 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/gal ($1.25/gal total maximum). Credits can be claimed against NE income tax. The proposed amendment would delay the credit's effective date, allow the credits to be refundable, and remove the timeline limitation and annual dollar limitations on the total amount of credits that can be claimed. | 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; AMENDMENT PROPOSED | Nebraska Legislature - Legislative Document |
| New York Clean Fuel Standard (S1343A/A472A) | 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: A previous version of this bill passed the state Senate in 2024 but did not pass the state Assembly. This bill was re-introduced in NY's 2025-2026 Legislative Session. Next Update: The bill must pass New York's Senate and Assembly and be signed by the Governor to become state law. | 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. | PROPOSED | NY State Senate Bill 2025-S1343A |
| UK SAF Revenue Certainty Mechanism | Royal Assent 5 March 2026. Core operative provisions, including the power to direct revenue certainty contracts, in force 5 May 2026. | Last Update: The Sustainable Aviation Fuel Bill received Royal Assent on 5 March 2026 as the Sustainable Aviation Fuel Act 2026 (2026 c. 9). Sections covering notice of directions and registration and publication of contracts came into force at Royal Assent, and section 1 (the power to direct the designated counterparty to offer a revenue certainty contract) came into force on 5 May 2026. Next Update: The Act establishes the framework only. The detailed operation of the revenue certainty contract regime and the aviation fuel supplier levy must still be set out in secondary legislation, which the Government intends to have in place by the end of 2026. A designated counterparty must be named before any contract can be offered. | The Sustainable Aviation Fuel Act 2026 introduces a statutory Revenue Certainty Mechanism for UK-produced SAF. The Secretary of State may direct a government-owned designated counterparty to offer a revenue certainty contract to a SAF producer. The contract sets a strike price: where the market reference price falls below it, the counterparty pays the producer the difference; where the market reference price is higher, the producer pays the counterparty. Fuel is treated as UK-produced if any part of the process for converting feedstock into the fuel takes place in the United Kingdom. No direction may be given more than 10 years after the Act was passed, extendable by regulations in increments of up to 5 years. The scheme is to be funded by a variable levy on aviation fuel suppliers, with the levy mechanics left to secondary legislation. | UK aviation fuel suppliers are directly affected and will bear the levy once secondary legislation is made. Costs are expected to be passed through to airlines and operators, so business aviation operators uplifting fuel in the UK should anticipate a fuel surcharge or embedded price increase from the point the levy commences. SAF producers gain revenue certainty, and business aviation should benefit indirectly from improved domestic SAF supply and reduced price volatility. The mechanism supports UK-produced SAF only, so it does not directly lower the cost of imported SAF uplifted at UK airports. | ENACTED (framework); secondary legislation pending. Sustainable Aviation Fuel Act 2026 (2026 c. 9), Royal Assent 5 March 2026. Previously carried as PROPOSED in error. | Sustainable Aviation Fuel Act 2026 - Legislation.gov.uk |
| Singapore SAF Target, Mandate & “Green Fuel Levy” | SAF Mandate: January 1, 2027 Green Fuel Levy: tickets sold after October 1, 2026, and flights departing after January 1, 2027 | Last Update: On 25 March 2026 CAAS deferred the SAF Levy, citing the impact of the ongoing conflict in the Middle East on airlines and passengers. The levy now applies to tickets and services sold from 1 October 2026 for flights departing from 1 January 2027, instead of tickets sold from 1 April 2026 for flights departing from 1 October 2026. The 1% SAF target also moved from 2026 to 2027. In early September 2026 CAAS further deferred the levy for cargo while confirming the passenger levy proceeds in October 2026. Next Update: Passenger levy attaches to tickets sold from 1 October 2026; first SAF uplift is targeted for mid-2027. The 3-5% target by 2030 remains in place, subject to global developments and wider SAF availability. A revised timeline for the cargo levy is still to be published. | Singapore will require flights departing Singapore to use SAF from 2027, with an initial 1% uplift target, with a goal to raise to 3–5% by 2030. Singapore will also become the first country globally to introduce a mandatory levy on all departing flights to fund SAF, administered by the Civil Aviation Authority of Singapore. | The levy applies to all flight types, including business aviation and private jets, and varies by distance and travel class. It will apply to tickets sold from October 1, 2026, and it will be charged on flights departing from January 1, 2027, onwards. Levy rates range from S$1 to S$41.60 per passenger (≈ USD 0.77 to 32). Economy passengers pay the lowest rates, while premium cabins pay up to four times more. For business aviation, this introduces a new cost component on all departures from Singapore, regardless of aircraft size or configuration. | ENACTED; IMPLEMENTATION DEFERRED (levy 25 March 2026; cargo element further deferred September 2026) | Sustainable Aviation Fuel (SAF) Levy to be Deferred | Civil Aviation Authority of Singapore |
| South Korea SAF Mandate | Jan 1 2027 for Fuel Suppliers, 2028 for Aircraft Operators | Last Update: The rule was announced by the South Korean government on August 30, 2024 with a roadmap updated provided in Sept 2025. Next Update: The specific 2030 ratio is to be decided during 2026 alongside eligibility and quality standards. | A mandatory blending ratio starting at 1% in 2027, rising to 3–5% by 2030 and 7–10% by 2035. Fuel suppliers — refining companies and petroleum exporters and importers — carry the blending obligation from 2027, with compliance measured by the proportion of SAF supplied each year for jet fuel used on international flights departing South Korea. Shortfalls attract a penalty of 1.5 times the annual average price gap between SAF and fossil jet fuel multiplied by the shortfall — the same architecture as the EU mandate but at a lower multiplier than the EU's 2x. Penalty enforcement is deferred for a period, and flexibility mechanisms allow up to 20% of an annual obligation to be carried over for up to three years. From 2028 airlines must additionally ensure SAF-blended fuel makes up at least 90% of their annual uplift at Korean departure airports, after a refuelling obligation management system is built during 2026–27 and pilot-operated in the first half of 2028. New airlines are exempt for three years, exemptions apply for safety or operational constraints, and from 2030 SAF with higher carbon reduction scores may receive additional weighting. Qualifying SAF must meet ICAO-based carbon reduction levels. | The rule will apply to all departing international flights from South Korea, which is expected to include business aviation. Higher cost may be seen on compliance costs with the supply mandate and uplift restrictions and reporting could be anticipated post 2028. | ANNOUNCED | Updated Korean SAF Mandate |
| China SAF Mandate | TBD - no national mandate in force | Last Update: Reviewed July 2026. No nationwide CAAC blending mandate has been adopted, China is currently prioritising voluntary demand-building. Next Update: TBD. | The Civil Aviation Administration of China (CAAC) had introduced a phased SAF blending mandate, starting with a 2% blend requirement by 2025, and gradually increasing to 15% by 2030. However no formal adoption has yet been noted. | 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 | Directive issued June 2025; annual targets published before the end of Q3 each year | Last Update: Turkiye's Civil Aviation Directorate (SHGM) issued the SHT-SAF directive in June 2025, moving the measure from consultation to a binding instrument. Next Update: SHGM publishes the required SAF volume and the minimum emission reduction per litre before the end of the third quarter each year. | Türkiye's SAF directive is structured as an emissions-reduction target rather than a volumetric blend percentage, with a goal of reducing aviation emissions by 5% by 2030 in line with CORSIA becoming mandatory in 2027. Fuel suppliers must ensure SAF-blended fuel meets the emission reduction requirement, and air carriers are obliged to consume the specified amount. Domestic refiners are expected to begin SAF production. Air carriers must uplift 90% of the SAF they need for international flights within Turkiye. SHGM will penalise both air carriers and fuel suppliers for non-compliance. | Directly relevant to business aviation. The directive applies to all national and international air carriers operating international flights from Turkiye, to airport operators and to fuel suppliers licensed by the Energy Market Regulatory Authority, and it catches aircraft with a maximum take-off weight above 5,700 kg (12,566 lb). Humanitarian, medical, firefighting and state aircraft flights are excluded. Operators flying internationally out of Turkiye should expect both an uplift obligation and cost pass-through from suppliers, and should track the annual target published each Q3. | ENACTED SHT-SAF directive issued by SHGM in June 2025. | Turkiye SAF directive - Sivil Havacılık Genel Müdürlüğü (SHGM) |
| 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 mandate was enacted as part of Brazil Bill of Law No. 528/2020 ("Fuel of the Future Law") on October 8, 2024. Next Update: Brazil's National Civil Aviation Agency will be defining a method to inspect air carriers and verify whether the targeted reductions are reached. | 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. | Brazil's domestic operators will be required to use SAF blends to reduce emissions, with flexibility for operators lacking SAF access or below a certain emission threshold. The Brazil National Civil Aviation Agency (ANAC) and other agencies will be and responsible for regulating the logistics of the program, with more details expected for operators. The law also leaves open the possibility of including international operators under the mandate. | ENACTED | Brazil Energy Journal – Fuel Of The Future Law - Renewables - Brazil |
| 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 Supply Mandate (Energy Supply Structure Sophistication Act) | FY2030–31 (from 1 April 2030), phased through FY2034–35 | On 17 August 2026, Japan’s Ministry of Economy, Trade, and Industry (METI)'s Decarbonized Fuel Policy Subcommittee proposed a revised, substantially reduced set of supply mandates, superseding the FY2024–25 proposal. Next Update: METI must still amend the ordinance under the Sophistication Act to make the obligation binding; no adoption date announced. | A supply-side obligation requiring covered suppliers to provide at least 1% of domestic jet fuel supply volumes in FY2030–31, at least 3% in FY2031–32, and at least 5% in each year from FY2032–33 through FY2034–35, applying only to jet fuel for international flights. It captures companies supplying 3,000 kilolitres or more of jet fuel annually at the seven airports with the highest international refuelling volumes: Narita, Haneda, Kansai, Chubu Centrair, New Chitose, Fukuoka and Naha — together 68.3% of Japan's international jet fuel refuelling in FY2024–25. | The obligated parties are jet fuel suppliers, and compliance is measured on aggregate annual supply volumes. But compliance costs and supply mandates would include fuel supplied to international business aviation operations. | PROPOSED (revised AUG 2026). Supercedes prior 10% proposals. | Updated Japanese SAF Mandate |
| French Solidarity Tax (TSBA) | 1-Jan-2025 | Last Update: Enacted by the French government in March 2025. Next Update: TBD – however the regulation continues to evolve rapidly | The French Aviation Solidarity Tax (TSBA), originally introduced in 2005 and linked to the French Eco Tax framework, applies to all passengers departing from airports located in French territory. From 2025, France has enacted a major redesign and rate increase of the tax, introducing a more granular structure that differentiates charges by destination region, travel class, and aircraft engine type. The reform represents one of the most significant national aviation tax increases in Europe to date. | The tax applies to all flights departing from France, including commercial airlines, charter operations, and business aviation. Business jet flights—particularly long-haul operations and turbojet aircraft—are subject to the highest charges, resulting in a material increase in departure costs for private and charter flights from French airports. Tax rates: 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 | ENACTED | Section 2 : Taxe sur le transport aérien de passagers (Articles L422-13 à L422-40) - Légifrance |
| Swedish Aviation Tax Abolishment | 1-Jul-2025 | Last Update: The Riksdag decided to abolish the act on tax on air travel with effect from 1 July 2025. Airlines no longer pay air travel tax for passengers departing Swedish airports. Next Update: None. Sweden has stated it intends to shift from national to European regulatory measures for aviation. | 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 abolished this tax to boost economic activity and enhance the competitiveness of the Swedish air transport sector. | The tax was abolished on 1 July 2025. Until then it ranged from SEK 76 to SEK 504 per departing passenger depending on destination and applied only to commercial passenger-carrying flights operated by aircraft with 10 or more seats. | ENACTED The abolition took effect 1 July 2025. | Tax on air travel in Sweden | Skatteverket |
| UK Air Passenger Duty (APD) - 2027 Update for Business Aviation Flights | 1-Apr-2027 | Last Update: The UK Government confirmed the higher rate of APD will apply to 5.7 tonnes (12,500lbs) or more equipped to carry fewer than 19 passengers. Next Update: The UK Government plans to legislate these reforms through the Finance Bill 2026, with draft legislation published in advance for technical consultation. | 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 2027 UK Air Passenger Duty (APD) rates introduce notable increases, especially for passengers using business aircraft: - Flights up to 5,500 miles: APD rises from £244 to £1,097 per passenger - Flights over 5,500 miles: APD rises from £253 to £1,141 per passenger The higher rate of Air Passenger Duty (APD) will apply to all aircraft of 5.7 tonnes (12,500lbs) or more equipped to carry fewer than 19 passengers. Currently, business aircraft below 20 tonnes with the same seating capacity are charged at the Standard rate, so this change will affect a large portion of business aviation activity. | PROPOSED | Air Passenger Duty: rates from 1 April 2026 to 31 March 2027 - GOV.UK |
| Arkansas Sustainable Aviation Fuel Incentive Act (HB1303) | Tax years beginning on or after January 1, 2025 | Last Update: This bill was signed into law by Gov. Sanders in April 2025. Next Update: TBD | The law creates a SAF tax credit for producers and refiners. This is an income tax credit of up to 30% of the cost of SAF production equipment, so long as the installed facility costs over $2bil and construction begins by December 31, 2027. | This income tax credit could be claimed by SAF producers located in Arkansas, provided that the SAF meets specific criteria (including that it is derived from wood biomass). | ENACTED | HB1303 Bill Information - Arkansas State Legislature |
| New York Climate Corporate Data Accountability Act (SB9072A) | Scope 1 & 2 Emissions: January 1, 2028 Scope 3 Emissions: January 1, 2029" | Last Update: This bill passed the State Senate in February 2026. Next Update: The bill must pass New York's Senate and Assembly and be signed by the Governor to become state law. | If passed, this law would impose annual climate reporting requirements on large companies doing business within the state (including Scope 1, 2, and 3 emissions). | This bill is generally aligned with the California Climate Disclosure laws adopted in 2023. If passed, this would apply to US businesses, including aircraft operators, with total annual revenues of more than $1 billion, and that do business in New York. Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | PROPOSED | S9072A |
| New York Climate-Related Financial Risk Reporting (SB 3697) | 1-Jan-2028 | Last Update: This bill was introduced to the State Senate in January 2025. Next Update: The bill must pass New York's Senate and House and be signed by the Governor to become state law. | If passed, this law would require large companies doing business within the state to biannually disclose their climate-related financial risk (following the TCFD framework) and measures to reduce this risk. | This bill is generally aligned with the California Climate Disclosure laws adopted in 2023. If passed, this would apply to US businesses, including aircraft operators, with total annual revenues of more than $500 million, and that do business in New York. Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | PROPOSED | NY State Senate Bill 2025-S3697 |
| Colorado's Requiring Certain Entities to Disclose Information Concerning Greenhouse Gas Emissions (HB25-1119) | 1-Jan-2028 | Last Update: This bill was introduced to the State House in January 2025. Next Update: The bill must pass Colorado's Senate and House and be signed by the Governor to become state law. | If passed, this law would impose annual climate reporting requirements on large companies doing business within the state (including Scope 1, 2, and 3 emissions) and require independent 3rd party verification. | This bill is similar to the California Climate Disclosure laws adopted in 2023. If passed, this would apply to US businesses, including aircraft operators, with total annual revenues of more than $1 billion, and that do business in Colorado. Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | PROPOSED | Require Disclosures of Climate Emissions | Colorado General Assembly |
| Danish Passenger Tax on Air Travel | 1-Jan-2025 | Last Update: The tax scheme was proposed in 2023 and enacted in 2024, with its implementation beginning on January 1, 2025, and becoming fully effective by 2030. Next Update: A tax impact evaluation is scheduled for 2027. | The Danish Passenger Tax was introduced to fund green aviation and social initiatives. It supports the launch of a green domestic route in 2025, aims for fully green domestic flights by 2030, and allocates DKK 1 billion (2025-2033) to support aviation’s green transition. | The Danish Passenger Tax applies to all air passengers departing from Denmark, with rates based on flight distance. It affects both commercial airlines and private aviation, though certain flights and passengers are exempt, including:
- Flights departing from Greenland and the Faroe Islands - Infants under two years old - Transit and transfer passengers - Airline staff on duty For 2025, the tax rates are: - DKK 30 for flights within Europe - DKK 250 for medium-haul flights - DKK 300 for long-haul flights The tax is paid monthly by the airline or operator responsible for the flight. | ENACTED | Passenger charges | Skat.dk |
| New Jersey Low Carbon Transportation Fuel Standard (S2318) | One year after the law’s effective date | Last Update: The bill was introduced in the New Jersey Senate in January 2026. Next Update: The bill must pass New Jersey's Senate and House and be signed by the Governor to become state law. | This bill would mandate the creation of a clean fuel standard in New Jersey, 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. If passed as written, SAF produced in New Jersey would qualify to generate credits, lowering the green premium there. | PROPOSED | NJ Legislature |
| Farm to Fly Act (S. 144, H.R. 1719) | TBD | Last Update: Language from this bill was included in the 2026 Farm Bill and passed by the House in April 2026. Next Update: TBD as to whether it will become law in 2026. | This bipartisan bill would have amended the Farm Security and Rural Investment Act of 2002 to make SAF eligible within current USDA Bio-Energy Programs and provide for greater collaboration on aviation biofuels (allowing U.S. crops to be more effectively used to create SAF). Language from the bill was included in the 2026 Farm Bill, anchoring SAF support within federal agricultural policy by explicitly adding it to the biofuels category for the first time. It also directs the Secretary of the USDA to develop a department-wide strategy to advance SAF. | If the Farm Bill passes as written, it would expand opportunities for SAF by codifying USDA support, further connecting SAF to the agricultural industry. Indirectly, this could impact aviation operators by making SAF less expensive and more widely available over time. | PROPOSED | NBAA Cheers House Passage of Farm Bill Calling for New SAF Development | NBAA - National Business Aviation Association |
| Financing Our Energy Future Act | Taxable years beginning after December 31, 2025 | Last Update: A previous iteration of the bill (S.2641, H.R.3690) was introduced in 2023 but did not receive a vote. This 2025 bipartisan bill was reintroduced to the US Senate in February 2025. Next Update: TBD as to whether it will become law in 2025. | This bipartisan legislation would amend the Internal Revenue Code of 1986 to allow renewable energy resources and infrastructure projects to form as master limited partnerships (MLPs), a tax structure currently only available to traditional energy projects. | This law could decrease capital funding costs for businesses producing SAF and other renewable energies by extending corporate tax breaks. Indirectly, this could impact aviation operators by making SAF less expensive and more widely available over time. | PROPOSED | Sens. Moran, Coons Introduce Legislation to Provide Financing Options for New Energy Projects - News Releases - U.S. Senator for Kansas, Jerry Moran |
| Illinois Climate Corporate Accountability Act (HB3673) | 1-Jan-2027 | Last Update: The Bill was introduced in the State House of Representatives in February 2025. Next Update: The bill must pass Illinois' Senate and House and be signed by the Governor to become law. | If passed, this law would impose annual climate reporting requirements on large companies doing business within the state (including Scope 1, 2, and 3 emissions) and require verification by a state emissions registry or a third-party auditor. | This bill is similar to the California Climate Disclosure laws adopted in 2023. If passed, this would apply to US businesses, including aircraft operators, with total annual revenues of more than $1 billion, and that do business in Illinois. Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | PROPOSED | Illinois 104th General Assembly 2025 and 2026 HB3673 |
| Illinois Clean Transportation Standard Act (SB3693) | 1-Jan-2027 | Last Update: The bill was introduced in the State Senate in February 2026. Next Update: The bill must pass Illinois' Senate and House and be signed by the Governor to become state law. | This bill would mandate the creation of a clean fuel standard in Illinois, which would set decreasing carbon intensity targets for certain covered transportation fuels against a 2019 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 standard have yet to be created by the Pollution Control Board. If passed as written, sustainable aviation fuel would qualify to generate credits, lowering the green premium in Illinois. | PROPOSED | Illinois General Assembly - Bill Status of SB3693 |
| New Jersey Climate Corporate Data Accountability Act (SB4117) | 3 years after the Bill becomes Law | Last Update: The Bill was introduced in the State Senate in February 2025. Next Update: The bill must pass New Jersey's Senate and House and be signed by the Governor to become law. | If passed, this law would impose annual climate reporting requirements on large companies doing business within the state (including Scope 1, 2, and 3 emissions) and require verification by an assurance provider. | This bill is similar to the California Climate Disclosure laws adopted in 2023. If passed, this would apply to US businesses, including aircraft operators, with total annual revenues of more than $1 billion, and that do business in New Jersey. Indirectly, this will impact any aviation company serving a customer subject to these reporting requirements. | PROPOSED | State of New Jersey 221st Legislature 4117_I1.PDF |
| Massachusetts Clean Fuel Standard (S2251/H3576 and S2278/H3522) | Does not specify date of implementation | Last Update: These Bills were introduced in the State Senate and House in February 2025. Next Update: A Bill must pass Massachusetts’ Senate and House and be signed by the Governor to become law. | Several bills have been introduced that would create a clean fuel standard, which would set decreasing carbon intensity targets for certain covered transportation fuels against a 1990 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. If passed as written, SAF would qualify to generate credits, lowering the green premium in Massachusetts. | PROPOSED | Massachusetts 194th Legislature Bill S.2251 |
| Minnesota Low Carbon Fuel Standard (HF2847) | Does not specify date of implementation | Last Update: The Bill was introduced in the State House of Representatives in March 2025 and has been sent to committee. Next Update: The bill must pass Minnesota’s Senate and House and be signed by the Governor to become state law. | This bill would mandate the creation of a clean fuel standard, which would set decreasing carbon intensity targets for certain covered transportation fuels against a 2018 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 standard have yet to be created by the Commissioner of Transportation. If passed as written, SAF would qualify to generate credits, lowering the green premium in Minnesota. | PROPOSED | HF 2847 Status in the House for the 94th Legislature (2025 - 2026) |
| Wisconsin SAF Tax Credit (AB222 / SB284) | Taxable years beginning after December 31, 2027 | Last Update: The Bill was amended in late 2025 to only apply to SAF derived from renewable biomass. Next Update: The bill must pass Wisconsin’s Senate and House and be signed by the Governor to become state law. | If passed, this would create an income and franchise tax credit to produce SAF, totalling $1.50 per neat gallon. Qualifying SAF must be 90% derived from renewable biomass and nonpetroleum sources. If the SAF is derived from energy crops, they must be grown domestically in the U.S. | This tax credit could be claimed by SAF producers that pay income or franchise tax in Wisconsin, provided that the SAF meets specific criteria. | PROPOSED | Wisconsin 2025 Assembly Bill 222 |
| Nevada SAF Incentive Program (AB481) | Does not specify date of implementation | Last Update: The Bill was introduced in the State House of Representatives in April 2025. Next Update: The bill must pass Nevada’s Senate and House and be signed by the Governor to become state law. | If passed, a $2.50/gal incentive would be available to US air carriers that purchase SAF in Nevada, so long as it was produced in-state and meets specific criteria. In this case, an "air carrier" is defined as a person who provides commercial air transportation to passengers. | If passed, this incentive could be claimed by US “air carriers” to lower the green premium in Nevada, provided that the SAF purchase meets specific criteria. | PROPOSED | Nevada AB481 Overview |
| Michigan SAF Incentive Program (HB 4424-4425 and SB 235-236) | Tax years beginning on and after January 1, 2025 | Last Update: The Bill was introduced and passed by the State Senate in 2025. Next Update: The bill must pass Michigan’s House and be signed by the Governor to become state law. | If passed, this law would create a $1.50-$2.00/gal tax incentive would be available to SAF producers or blenders. The SAF must be produced or blended in-state and must be purchased for use by aircraft departing from an in-state airport. | This income tax credit could be claimed by SAF producers and blenders located in Michigan, provided that the SAF meets specific criteria. This should increase SAF supply and lower the premium in Michigan. | PROPOSED | Senate Bill 236 of 2025 - Michigan Legislature |
| Iowa SAF Production Tax Credit Program (S.F. 657) | Calendar year 2026 through calendar year 2035 | Last Update: Iowa Gov. Reynolds signed this into law in June 2025. Next Update: The tax credit will be available in 2026. | This law creates a $0.25/gal tax credit for producers that make SAF in Iowa, totaling up to $1mil. | This income tax credit could be claimed by SAF producers located in Iowa, provided that the SAF meets specific criteria. This should increase SAF supply and lower the green premium in Iowa. | ENACTED | Iowa Legislature - BillBook |
| House Extension and Modification of the U.S. Clean Fuel Production Credit (45Z) | January 1, 2025 to December 31, 2031 | Last Update: Amendments to this credit were passed by the U.S. House of Representatives in May 2025. Next Update: The Bill must be passed by the Senate and signed by the President to become U.S. law. | If passed, this would extend and modify the income tax credit originally provided under the 2022 Inflation Reduction Act, giving qualifying “clean fuel” producers access to up to $1/gal (non-aviation fuels) and $1.75/gal (SAF). Amendments from the original law include a four-year extension, new domestic feedstock limitations, and the exclusion of indirect land use changes (ILUC) for purposes of lifecycle greenhouse gas emissions accounting. | This income tax credit could be claimed by U.S. SAF producers, provided that the SAF meets specific criteria. This should increase SAF supply and lower the green premium across the U.S. | PROPOSED | House passes ‘big, beautiful bill’ with 45Z extension | SAF Magazine |
| Linking EU and UK Emissions Trading Systems | The linking is planned to take effect by early 2027. | Last Update: The European Commission has been formally authorized to begin negotiations with the UK to link the two emissions trading systems. Negotiations to link the EU and UK Emissions Trading Systems (ETS) began in May 2025. Next Update: Formal negotiations will now begin to define how the linked ETS will operate. The link between the systems could become operational in January 2027, ideally before the EU’s and UK’s Carbon Border Adjustment Mechanism (CBAM) takes full effect. | The proposal aims to link the EU and UK Emissions Trading Systems (ETS), creating a single carbon market where allowances can be traded across both jurisdictions. This would align carbon pricing, reduce administrative burdens, and eliminate the need for carbon border charges between the UK and EU. It is designed to lower the overall cost of decarbonization while maintaining high climate ambition and supporting trade. | The linking primarily affects entities regulated under the EU and UK ETS, it is particularly relevant for operators currently subject to obligations under both systems. The linkage also impacts compliance teams, verifiers, and authorities involved in emissions reporting and allowance management. | PROPOSED | UK-EU AGREEMENT TO LINK EMISSIONS TRADING SYSTEMS (ETS) |
| Aviation and Innovative Manufacturing in Kansas Act (HB2308) | Tax years beginning on and after January 1, 2025 | Last Update: The bill was introduced in the State House in February 2025 and completed a public hearing in January 2026. Next Update: The bill must pass Kansas' House and Senate and be signed by the Governor to become state law. | If passed, this law would create a series of tax incentives available to qualifying Kansas businesses, including SAF producers. Incentives include training reimbursement, sales tax exemption, investment tax credit, and more. | If passed, this would offer qualifying SAF producers access to tax incentives, reimbursements, and other benefits, potentially making Kansas more attractive for SAF production. | PROPOSED | HB 2308 | Bills and Resolutions | Kansas State Legislature |
| One Big Beautiful Act Modification of the U.S. Clean Fuel Production Credit (45Z) and Hydrogen Production Credit (45V) | January 1, 2025 to December 31, 2029 | Last Update: President Trump signed this bill into law in July 2025, and the updated 45Z SAF tax credit rate ($1/gal) went into effect on January 1, 2026. Next Update: The Department of the Treasury and the IRS issued proposed regulations, which will clarify how SAF producers can use the tax credit, prompting a public comment period and hearing in May 2026. | This modifies the income tax credits originally provided under the 2022 Inflation Reduction Act. Changes include: - Clean Fuel Production Credit (45Z): Gives qualifying “clean fuel” producers extended access to tax credits, including SAF. The original credit value ($1.75/gal) will be available to SAF producers through Dec 30, 2025. From Dec 31, 2025 to Dec 31, 2029, the SAF credit amount lowers to $1/gal. There are also new feedstock limitations, and it excludes indirect land use changes (ILUC) for purposes of lifecycle greenhouse gas emissions accounting. -Hydrogen Production Credit (45V): Projects not under construction by the end of 2027 will no longer qualify. | These tax credits could be claimed by U.S. SAF producers, provided that the SAF meets specific criteria. While tax credits are an important policy designed to increase SAF supply and lower the green premium, the updated value and timeline of these credits may potentially make other renewable fuels more attractive to producers in the near term. | ENACTED | Trump signs bill enacting 2-year extension of 45Z credit | SAF Magazine |
| Pennsylvania SAF Tax Credit and Expanded Hydrogen Credit (HB500) | SAF Tax Credit: fuel produced January 1, 2028 until December 31, 2044 Expanded Hydrogen Credit: hydrogen used from January 1, 2025 to December 31, 2045 | Last Update: The Bill was introduced in the State House in May 2025. Next Update: The bill must pass Pennsylvania's House and Senate and be signed by the Governor to become state law. | If passed, this bill would create a $0.75/gallon SAF tax credit for in-state production from 2028 through 2044. The bill also proposes changing state tax credit eligibility laws to expand the eligible uses of clean hydrogen to include the production of aviation fuel. | If passed, this incentive could be claimed by producers meeting specific criteria, which could incentivize and increase Pennsylvania’s SAF and eSAF supply, reducing the cost for business aviation operators. | PROPOSED | House Bill 500 Information; 2025-2026 Regular Session - The Official Website of the Pennsylvania General Assembly |
| U.S. SAF Information Bill | Does not specify date of implementation | Last Update: This bipartisan legislation was introduced to the U.S. House of Representatives in July 2025. Next Update: The bill must pass the U.S. House and Senate and be signed by the President to become state law. | If passed, this bill would direct the US Energy Information Administration (EIA) to release SAF production data in its Petroleum Supply Monthly report and its Weekly Petroleum Status Report. The EIA would also be required to include data related to the type, origin and volume of feedstock used in the production of SAF, along with the total amount of SAF produced domestically and imported. | The SAF Information Bill aims to improve market transparency. This benefits stakeholders across government and industry by offering better insight into market trends, helping coordinate action to scale domestic SAF production, grow the biofuels sector, and support rural economies. | PROPOSED | Congressman Flood Introduces the Sustainable Aviation Fuel Information Act |
| Denmark SAF State Aid Scheme | July 29, 2025 – December 31, 2027 | Last Update: The European Commission approved this aid scheme in July 2025. Next Update: Details will be published in the EU State Aid Register (Case SA.102731) | Denmark’s €36 million State aid scheme is the first in the EU specifically promoting the use of SAF. The scheme aims to support at least one domestic route operating with 40% SAF, well above the 2% ReFuelEU mandate, through monthly direct grants covering the green premium and related infrastructure expenses. The scheme includes rules to prevent overcompensation and is expected to deliver at least 20 commercial one-way sustainable operations weekly. Grants will support airlines operating domestic flights within Denmark, SAF suppliers, and airport infrastructure providers; however, they will not be available to business aviation. | Grants will support airlines operating domestic flights within Denmark, SAF suppliers, and airport infrastructure providers; however, they will not be available to business aviation. | ENACTED | IP_25_1928_EN.pdf |
| Thailand SAF Blending Mandate | January 1, 2026 | Last Update: The Thai government confirmed new standards for SAF and blend requirements starting January 1, 2026. Next Update: The government plans to establish a SAF working group in 2026 to set appropriate targets and policies, in a public-private partnership. | The Department of Energy Business (Ministry of Energy) has introduced national standards for SAF, including a blend mandate and a SAF working group to determine policies and targets. This requirement is now in force as part of the regulatory framework. The measure is intended to align the aviation sector with ICAO CORSIA, Thailand’s 2050 carbon-neutrality goal, and its 2065 net-zero target. The four phases of its roadmap and mandate are: -2026: 1% -2027-29: 2% -2030-32: 3-5% -2033-on: 5-8% | The rule will apply to fuel suppliers and airlines operating flights departing from Thailand, including both domestic and international operators. | PROPOSED | Thailand mandates 1% SAF blend for jet fuel from January 1, 2026 |
| Revision of the Energy Taxation Directive (ETD) – Proposed Jet Fuel Tax Fails to Advance | N/A | Last Update: The European Commission proposed a major revision to the ETD in 2021 that has been under negotiation since. In November 2025, the latest revision failed to reach a unanimous agreement and did not pass into law. Next Update: TBD. Current aviation fuel tax exemptions under the 2003 ETD remain unchanged. | The ETD was originally adopted to create a framework for taxing energy products across the EU. Aviation fuel used on business and pleasure flights has been historically exempted from taxation, but the Commission’s recently revised proposal intended to change that. If passed, it would have introduced minimum taxation rates for intra-EU passenger flights, specifically targeting aircraft typically used for business and private aviation. | The measure would have taxed jet-A used by aircraft with fewer than 19 seats for both commercial and non-commercial flights, while operators of larger aircraft would be exempt for 10 years. Intra-EU cargo-only flights would have remained exempt. The proposal would have introduced: -A €0.40 per litre tax on Jet A-1 for both private and commercial business aviation -A €0.18 per litre tax on SAF used by business aviation Because the measure failed, current aviation fuel tax exemptions under the 2003 ETD remain unchanged, and no EU-wide fuel excise duty will apply for now. | DID NOT PASS | Revision of the Energy Taxation Directive: Fit for 55 package |
| CORSIA 2024 Sectoral Growth Factor (SGF) | January 1, 2024 (First Phase 2024–2026) | Last Update: ICAO completed its review of the 2024 Sectoral Growth Factor and published a revised final figure in December 2025. The official 2024 SGF is 15.4% (0.15405257), down from the 15.95% first published in October 2025, with total sector offsetting requirements of 55.6 Mt. Next Update: ICAO is expected to publish the 2025 SGF around October 2026. IATA estimates it will fall between 16.1% and 20.9%, with a mid-value of 18.6%. States must notify operators of their 2025 offsetting requirements by 30 November 2026. | ICAO's 2024 CORSIA Sectoral Growth Factor is 15.4%. The factor measures the growth in CO2 emissions from international flights between CORSIA-participating states above 85% of 2019 levels. The baseline for applicable state pairs was set at 305,522,071 tonnes against 2024 emissions of 361,159,641 tonnes. The figure was revised down from the 15.95% first published in October 2025, following an ICAO review that identified the original calculation may not have fully reflected the rules on 'new entrants' - operators temporarily exempt from accruing offsetting obligations. | States and competent authorities use this factor to calculate each aircraft operator's CORSIA offsetting requirement. Operators in the CORSIA programme must offset 15.4% of their 2024 emissions from flights between participating states. The deadline to meet 2024-2026 obligations is January 2028, by cancelling CORSIA-eligible units for that period. CORSIA applies to international flights between participating states only. | ENACTED 2024 SGF confirmed at 15.4% following ICAO's December 2025 revision | CORSIA-Annual-SGF-4ed-2025-web.pdf |
| UAE SAF Mandate | TBD | Last Update: Announced in November 2025. Next Update: Draft regulations expected in 2025. | The United Arab Emirates (UAE) is advancing from voluntary SAF targets toward a binding national SAF mandate. The current General Policy for Sustainable Aviation Fuel (issued 2023) includes voluntary goals—such as producing 700 million litres of SAF annually by 2030 and achieving at least 1% domestically produced SAF use by 2031. Recent government statements and industry reporting indicate that the UAE intends to introduce a mandatory SAF blending requirement for airlines, with draft regulations expected during 2025. Aircraft operators uplifting fuel in the UAE, fuel suppliers, and airport fuel infrastructure operators. Major UAE carriers have already begun securing supply contracts in anticipation of the mandate. | Aircraft operators uplifting fuel in the UAE, fuel suppliers, and airport fuel infrastructure operators. Major UAE carriers have already begun securing supply contracts in anticipation of the mandate. | PROPOSED | General Policy for Sustainable Aviation Fuel | The Official Platform of the UAE Government |
| Belgium Air Travel (Embarkation) Tax Increase | January 1, 2027 | Last Update: Belgium reached a budget agreement in November 2025, which included the tax increase. Next Update: The tax increase goes into effect in 2027, and more implementation details are expected in 2026. | Belgium announced that it will increase its air-travel tax on all flights departing from Belgian airports beginning in 2027. The revised tax aims to support environmental objectives and contribute to Belgium’s transport-infrastructure funding. Revenue from the measure is expected to help finance rail improvements and broader sustainability initiatives. | The updated measure will apply a €10 levy per passenger, regardless of travel distance, impacting commercial and private aircraft operators and travellers. More details are expected as the implementation date approaches, including how the measure may impact different types of travel. | ENACTED | 'Passenger will pay': Airlines blast Belgium's extra flight taxes |
| U.S. Securing America’s Fuels (SAF) Act | January 1, 2026 | Last Update: The OBBB extended but lowered the SAF credit amount in July 2025, and this act was introduced to restore it in December 2025. Next Update: The bill must pass the House, Senate, and be signed by the President to become U.S. law. | In 2025, the US Clean Fuel Production Credit (45Z) was extended under the One Big Beautiful Bill, but the amount was lowered to $1/gal. The SAF Act is bipartisan legislation that, if passed, would restore the full value of the 45Z credit to $1.75/gal and extend it through December 31, 2033, an additional 4 years. | This tax credit could be claimed by U.S. SAF producers, provided that the SAF meets specific criteria. If passed, this legislation would support increasing U.S. SAF supply and lowering the green premium, ensuring it remains an attractive investment in the near term and reducing the cost for aircraft operators, commercial and private. | PROPOSED | Securing America’s Fuels Act (SAF Act) |
| New York Mandatory Greenhouse Gas Reporting Program | First reports due June 1, 2027 for calendar year 2026 | Last Update: The New York State Department of Environmental Conservation (DEC) adopted regulations establishing this mandatory program in December 2025. Next Update: The NYS e-GGRT electronic reporting platform will launch before the first reporting deadline. | This program establishes annual emissions reporting requirements for a wide range of entities operating in New York that meet or exceed specified thresholds. This is a data collection program only and does not require emission reductions or allowances. Reported data must be verified by a DEC-accredited third-party. | The New York programme impacts a wide range of emissions sources, but for aviation specifically, it will impact: - Facilities emitting ≥10,000 MT CO₂e/year - Fuel suppliers delivering any quantity to end users in New York State (including jet fuel) | ENACTED | Mandatory Greenhouse Gas Reporting Program Frequently Asked Questions |
| Netherlands Charter Tax | January 1, 2030 | Last Update: The Dutch Senate confirmed this amendment in December 2025. Next Update: TBD. Industry groups continue to oppose the measure in the hope that a new coalition government may attempt to reverse it before implementation. | This amendment to the Air Travel Tax introduces a new per-passenger charter tax aimed at reducing the environmental impact of private aviation. The tax structure is similar to France’s Solidarity Tax and aligns with the proposed UK APD increase. | This new, higher rate of tax applies to aircraft with 19 passenger seats or fewer, directly affecting business aviation operations. Tax Rates: - Short-haul (2,000 km): €420 - Medium-haul (2,000–5,500 km): €1,015 - Long-haul (> 5,500 km): €2,100 | ENACTED | EBAA Opposes Dutch Charter Tax as Green Deal Barrier to Business Aviation | Aviation International News |
| Wisconsin Aviation Biofuel Manufacturing Zone and Related Tax Credit (AB619) | Tax years beginning after December 31, 2025 | Last Update: This tax credit became law in April 2026. Next Update: The intended beneficiary of the tax credit is expected to produce SAF in 2029. | Wisconsin’s enacted SAF legislation authorizes the Wisconsin Economic Development Corporation to certify one "aviation biofuel" manufacturing project as eligible to claim state income and franchise tax credits. The business must manufacture biofuel, a majority of which must be SAF derived from woody biomass, with at least 80 percent of feedstock sourced from within Wisconsin over a five‑year period. The project will be eligible to claim up to $120 million in tax benefits, with credits available through carry forward if not fully used in a given tax year. | This incentive will support a planned partnership between Wisconsin-based Johnson Timber and German biofuel company Synthec Fuels, potentially resulting in a $120 million of tax credits from the state. SAF production at the facility is expected to begin in 2029. The legislature made a point to note that the manufacturing of aviation biofuels in Wisconsin is essential to maintain and grow the forest products industry, to create jobs, and is in the public’s interest. | ENACTED | Wisconsin Legislature: 2025 Wisconsin Act 164 |
| Swiss Adoption of ReFuelEU | January 1, 2026 | Last Update: Switzerland adopted the Regulation as of January 1, 2026. Next Update: TBD | Switzerland has formally adopted the ReFuelEU SAF mandate, requiring aviation fuel suppliers to meet the minimum 2% SAF blend. The Swiss Federal Office of Civil Aviation (FOCA) has also published technical guidance to support operators on the transition. | Aviation fuel suppliers at Zurich and Geneva airports will need to ensure a minimum 2% SAF blend, ramping up steadily to 70% by 2050. All aircraft operators (including those based outside of the EU) conducting over 500 flights per year from Union airports (including Zurich and Geneva) must report information related to fuel uplifted. | ENACTED | ReFuelEU aviation - Mobility and Transport - European Commission |
| Pennsylvania Clean Fuel Standard (HB2063) | Once passed, the Clean Fuel Standards Board must publish regulations establishing the CFS within two years | Last Update: The bill was introduced in Pennsylvania’s House in December 2025. Next Update: The bill must pass Pennsylvania's House and Senate and be signed by the Governor to become state law. | If passed as written, this bill would establish a clean fuel standard (CFS) intended to reduce transportation greenhouse gas emissions in PA. A CFS 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 the programs in California and Washington). | 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. | PROPOSED | House Bill 2063 Information; 2025-2026 Regular Session - The Official Website of the Pennsylvania General Assembly |
| Japan SAF Tax Credit | 1-Apr-2024 | Last Update: Japan passed this tax reform in March 2024 as part of its GX (Green Transformation) legislation package. Next Update: TBD. Japan is considering additional incentives like reductions in petroleum/coal taxes and import duties for SAF. | Japan's Strategic Fields Domestic Production Promotion Tax System includes a SAF production tax credit worth 30 yen per liter (YPL) for domestically produced or sold SAF. | This tax credit could be claimed by qualifying domestic producers, with the intent to encourage domestic commercial‑scale SAF production and reduce the green premium. | ENACTED | InfluenceMap Japan Sustainable Aviation Fuel (SAF) mandate |
| Aviation Innovation and Global Competitiveness Act | Within 180 days of enactment | Last Update: This bipartisan bill was introduced into the U.S. House and Senate in February 2026. Next Update: The bill must be passed by the House and Senate and signed by the President to become law. | This bipartisan bill would streamline the FAA's type certification process to support new and novel aircraft technologies, including eVTOL aircraft and other alternative‑propulsion systems. It would establish standard expected timelines for certification milestone review, clarify when issue papers are required, expand delegation authority for routine compliance findings, and more. | The bill aims to make AAM certification more transparent, predictable, and efficient, enabling faster and safer introduction of next‑generation aircraft. | PROPOSED | https://nehls.house.gov/sites/evo-subsites/nehls.house.gov/files/evo-media-document/aam-faa-bill.pdf |
| California SAF Tax Credit (Draft Trailer Bill 1365) | For fuel produced after January 1, 2026. Credits can be claimed beginning November 1, 2027 | Last Update: The California Department of Finance released draft bill language in February 2026. Next Update: The language is expected to be incorporated into a bill and taken up as part of annual budget deliberations in Spring 2026. | This bill would create a $1/gal production tax credit for qualifying SAF produced and sold for use in California, with at least a 50% reduction in lifecycle greenhouse gas emissions relative to conventional jet fuel. An additional $0.02/gal is available for each additional 1% reduction in emissions beyond 50%, up to a maximum total credit of $2/gal. | This credit could be used by SAF producers on fuel produced and sold for use in-state, likely stimulating production in California and lowering the green premium for aircraft operators there. | PROPOSED | Sustainable Aviation Fuel Tax Credit Draft TBL |
| EU Taxonomy - Framework to Define Sustainable Investment | Original Regulation: 8 July 2020 Delegated Act: 27 June 2023 | Last Update: The original regulation went into effect in 2020, and in 2023, the Delegated Act expanded the criteria to include transport and aviation. Next Update: Additional technical screening criteria are expected during 2026. | The EU Taxonomy is a classification system from the EU defining which economic activities are considered environmentally sustainable using Technical Screening Criteria (TSC), reviewed at least every 3 years. The original Taxonomy Regulation (2020/852) set general criteria, and the Delegated Act 2023/2485 adds transport-specific rules, including for aviation. From 2028 through 2032, aircraft must be certified to operate on 100% SAF to meet taxonomy screening criteria. Originally business jets were expressely included, but that was overturned in 2026. | Investors, asset managers, and banks in the EU are increasingly required to channel capital into activities classified as ‘environmentally sustainable.' | ENACTED | Delegated regulation - EU - 2023/2485 - EN - EUR-Lex |
| Hawaii Renewable Fuels Production Tax Credit Amendment (HB1695/SB2403) | Taxable years beginning after December 31, 2025, and the 10-year credit window would be reset to July 1, 2026 | Last Update: This amendment was introduced in Hawaii's House in January 2026. Next Update: The bill must be passed by Hawaii's House and Senate and signed by the Governor to become law. | This bill would amend Hawaii's existing Renewable Fuels Production Tax Credit to accelerate local production of low‑carbon fuels, including SAF. If passed as written, it would raise the base credit from $0.20 to $0.35 per 76,000 BTUs and expand the list of eligible fuels. It would add two bonus credits, $1/gal of SAF and $1/diesel-gallon-equivalent for other low-emissions fuels. Finally, it would also establish caps to limit any one producer to no more than 75% of the annual credit pool, and ensure that the SAF bonus credits do not exceed 50% of the pool. Under Hawaii’s existing Renewable Fuels Production Tax Credit, producers can claim the credit for a fixed 10‑year window. The amendment would restart the 10‑year eligibility window to July 1, 2026. | This credit would apply to SAF producers in Hawaii, intended to support local production and agricultural feedstocks, potentially lowering the green premium for aircraft operators there. | PROPOSED | Measure Status Details for HB 1695 |
| Hawaii SAF Tax Credit (HB1694/SB2375/SB2027) | Taxable years beginning after December 31, 2026 through December 31, 2035. | Last Update: The bill was introduced in Hawaii's House in January 2026. Next Update: The bill must be passed by Hawaii's House and Senate and signed by the Governor to become law. | This bill would create a $1/gal production credit for SAF distributed in the state, with at least a 50% reduction in lifecycle greenhouse gas emissions relative to conventional jet fuel. An additional $0.02/gal would be available for each additional 1% reduction in emissions beyond 50%, up to a maximum total credit of $2/gal, with a total annual statewide credit cap of $20 million. Credit will require third‑party‑verified reporting on SAF volumes, feedstocks, emissions data, and related disclosures to the Department of Transportation. | This credit would apply to SAF producers in Hawaii, intended to support local production, potentially lowering the green premium for aircraft operators there. | PROPOSED | Measure Status Details for HB 1694 |
| Kentucky Alternative Jet Fuel Credit (HB869) | Taxable years beginning on or after January 1, 2029, but before January 1, 2035 | Last Update: The bill was signed into Kentucky law in April 2026. Next Update: The credit will go into effect in 2029. | This bill would create a new nonrefundable income tax credit for qualifying producers or blenders of alternative jet fuel, located in Kentucky. Credit levels vary based on the taxpayer's role and origin of the feedstock: - $0.50/gal for feedstock providers supplying eligible feedstocks or synthetic blending components to an alternative jet fuel producer - $1.50/gal for processing feedstocks or blending SBC - $2.00/gal for processing eligible feedstocks or blending SBC with conventional jet fuel to produce agriculturally-based alternative jet fuel, and $2.50/gal when those activities use an eligible feedstock produced in Kentucky Credits may be stacked when the feedstock provider and producer are the same entity, up to a combined cap of $3.00/gallon. The statewide annual aggregate is capped at $20 million. | The bill applies to alternative jet fuel producers, blenders, and feedstock providers located in Kentucky, incentivizing both local production and in-state agricultural supply chains. The credit could reduce the green premium for aircraft operators fueling there. | ENACTED | 26RS HB 869 |
| Massachusetts SAF Tax Credit - FY26 Supplemental Appropriations Bill (H5033) | TBD | Last Update: The bill was introduced in Massachusetts' House in January 2026, which included language for a SAF tax credit. The bill is primarily budget-related and does not yet include detailed statutory text on the SAF credit. Next Update: The bill must be passed by Massachusetts' House and Senate and signed by the Governor to become law. | Within the larger budget bill, this proposal would create a $1.50/gal tax incentive for SAF with at least a 50% reduction in lifecycle greenhouse gas emissions relative to conventional jet fuel. An additional $0.015/gal is available for each additional 1% reduction in emissions beyond 50%, up to a maximum total credit of $2/gal. The credit would be non-refundable against an excise tax imposed on the purchase of fuel for an aircraft departing from Massachusetts-based airports, with a total cumulative cap of $10 million in a given fiscal year. | This credit language will need additional details before we can understand its applicability. However, as written, it could apply to SAF purchasers in Massachusetts, potentially lowering the green premium for aircraft operators there. | PROPOSED | Bill H.5033 |
| New York Zero Emissions Transport Study - Amendment to NY Public Authorities Law (AB1331/S1456) | Effective immediately upon passing, with the study due in 5 years. | Last Update: The Bill was introduced in the State Assembly and Senate in January 2026. Next Update: The bill must pass New York’s Senate and Assembly and be signed by the Governor to become state law. | The bill would direct the New York State Energy Research and Development Authority (NYSERDA) to study SAF production and use, as well as how to make it more accessible across the state. It would also direct NYSERDA to study the use of renewable energy at publicly funded airports, and to create a grant program for flight schools/clubs to install electric aircraft charging. | The study will support SAF production and capabilities in NY State, and the outcomes may shape future incentives/mandates and airport electrification pathways. | PROPOSED | NY State Assembly Bill 2025-A1331 |
| New York SAF Tax Credit (S1229) | January 1, 2027, through January 1, 2033 | Last Update: The Bill was introduced in the State Senate in 2025. Next Update: The bill must pass New York’s Senate and Assembly and be signed by the Governor to become state law. | This bill would establish a SAF production tax credit of $1.25/gal, or $1.50/gal for qualifying certified SAF mixtures, with a cap of $2.4 million per taxpayer annually. It would create a certification for SAF through the New York State Energy Research and Development Authority (NYSERDA). The bill also directs the NY Climate Action Council to assess the impact of SAF production and include SAF usage in its updated scoping plan. | If passed, this incentive could be claimed by producers meeting specific criteria, which could incentivize and increase New York’s SAF supply, reducing the cost for business aviation operators. | PROPOSED | NY State Senate Bill 2025-S1229 |
| New York SAF Tax Credit (S4065/A7308) | Taxable years beginning January 1, 2025 | Last Update: The Bill was introduced in the State Assembly and Senate in January 2025, with amendments made throughout the year. Next Update: The bill must pass New York’s Senate and Assembly and be signed by the Governor to become state law. | This bill would establish a SAF production credit of $1/gal on flights departing New York with at least a 50% reduction in lifecycle greenhouse gas emissions relative to conventional jet fuel. An additional $0.01/gal is available for each additional 1% reduction in emissions beyond 50%, up to a maximum total credit of $2/gal. The credit is refundable if it exceeds tax liability, with an annual statewide cap of $30 million, and cannot be combined with other credits for the same expense. | If passed, this incentive could be claimed by producers on qualifying fuel, potentially reducing the SAF green premium for business aviation operators departing New York airports. | PROPOSED | NY State Senate Bill 2025-S4065C |
| UK Civil Aviation Authority Guidance on Publishing Emissions Information at Point of Sale | Effective immediately | Last Update: Guidance was published by CAA in February 2026. Next Update: CAA will review a range of websites advertising and selling applicable flights in 2027, at which point they may consider a mandatory approach if poor adoption persists. | The CAA released a guidance framework requiring airlines and flight‑selling platforms to display comparable, route‑specific emissions data to passengers at the time of booking. Applicable flights include those that depart from or arrive at UK airports. The guidance lays out principles to follow when calculating and providing environmental information to consumers, with the aim to curb greenwashing and improving transparency. | This will apply to airlines and other organisations selling or advertising applicable flights in the UK (including holiday packages that include applicable flights). | ENACTED (non-statutory) | CAP3112: Consumer Environmental Information: Framework for Implementation and Summary of Responses to the 2024 Consultation | UK Civil Aviation Authority |
| Vermont Clean Fuels Program (S171) | TBD - the stated 1 July 2026 date lapsed when the bill did not advance | Last Update: The bill was introduced in the Vermont Senate in January 2026 but did not advance before the 2026 session ended. The 1 July 2026 effective date in the bill as introduced has therefore lapsed. Next Update: The bill would need to be reintroduced and pass Vermont's Senate and House and be signed by the Governor to become state law. | If passed as written, this bill would establish a clean fuel program intended to reduce transportation greenhouse gas emissions in VT. The program 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 likely be eligible to generate credits on an opt-in basis (similar to the programs in California and Washington). | 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. | PROPOSED | Bill Status S.171 |
| Hawaii Intrastate SAF Mandate (HB1459) | January 1, 2030 | Last Update: The bill was introduced in the Hawaii House in February 2025. Next Update: The bill has stalled since early 2025. It would need to pass Hawaii's Senate and House and be signed by the Governor to become state law. | The bill would mandate minimum SAF use by airlines on intrastate segments, starting at 10% and increasing over time. The fuel would need to meet certain criteria, and airlines would be required to monitor and report fuel usage, or face penalties. | Although unlikely to pass, this mandate would affect commercial airlines operating intra‑Hawaii routes and airport fuel suppliers. | PROPOSED | Hawai‘i State Legislature |
| Colorado SAF Production Facility Credit & Proposed Modification (HB26-1289) | Purchase credit: tax years 2027 through 2032 In-state production bonus: from 1 January 2028 Repeal of the existing production facility credit: 1 January 2027 | Last Update: Governor Polis signed the measure on 3 June 2026, enacting the modification. Next Update: The credit becomes claimable for tax years beginning in 2027; the in-state production bonus follows from 1 January 2028. The Colorado Energy Office administers the reservation system. | Colorado’s existing SAF incentive is an income tax credit tied to the cost of constructing or converting a SAF production facility, available to qualifying taxpayers (primarily SAF producers). An amendment under consideration would repeal the existing credit and replace it with a refundable, income tax credit for SAF purchasers, at $1.50 per gallon. An additional $0.01 per gallon is available for each 1% of carbon‑intensity improvement above 50%, with total annual credits capped at $3 million statewide. | This income tax credit could incentivize the production of SAF in Colorado, but the overall cap is likely too low. | ENACTED Signed 3 June 2026. | HB26-1289 Modification of Certain Tax Expenditures | Colorado General Assembly |
| Florida Vertiports Support (HB1093/SB1362) | 1-Jul-2026 | Last Update: The bill became law in April 2026. Next Update: The law takes effect in July 2026. | This law integrates AAM into Florida's transportation framework. It intends to streamline vertiport approvals through FDOT, create consistency amongst local regulations, and strengthen coordination across public and private stakeholders. It also establishes targeted funding for public vertiports, allowing FDOT to cover up to 100% of project costs without federal funds and up to 80% with them. | This legislation supports the development of facilities needed for electric vertical takeoff and landing (eVTOL) aircraft, including electric air taxis. Increased funding eligibility and regulatory clarity could accelerate the deployment of electric aircraft operations in Florida. | ENACTED | House Bill 1093 (2026) - The Florida Senate |
| Minnesota SAF Tax Credit Restriction (SF 4443/HF 4073) | Taxable years beginning December 31, 2025 | Last Update: The bill was proposed in Minnesota's House and Senate in March 2026. Next Update: The legislation must pass the state House and Senate and be signed by the Governor to become law. | If enacted, this legislation would restrict eligibility for Minnesota’s SAF tax credit ($1.50 per gallon) by excluding taxpayers that either contract with a federal agency to provide air transportation services for immigration enforcement activities, or sell SAF to an air transportation services provider engaged in those activities. | The proposal could affect air transportation service providers contracted to support Immigration and Customs Enforcement (ICE), as well as fuel suppliers that provide SAF to those operators. | PROPOSED | SF 4443 Status in the Senate - 94th Legislature (2025 - 2026) |
| Minnesota Biofuels Education and Promotion Program (SF 2786) | Program implementation TBD Underground gas storage tank requirement applies to any installed after December 31, 2026 | Last Update: The bill was proposed in Minnesota's Senate in March 2026. Next Update: The legislation must pass the state House and Senate and be signed by the Governor to become law. | This legislation would establish a statewide biofuels education and promotion program to increase public awareness of the benefits of biofuels and SAF. The bill creates an advisory council on biofuels education to advise the Commissioner on program goals, activities, oversight, and statewide outreach efforts. If enacted, the Commissioner would be authorized to award grants for projects that support the program’s objectives, in partnership with the advisory council. The bill also requires the Commissioner to submit an annual public report summarizing program activity, funding awarded, market development outcomes, and overall program costs. Additionally, the law would require any underground gasoline storage tank system installed in 2027 and beyond to meet compatibility standards for gasoline containing up to 25% ethanol. | The proposed program would support public education and outreach related to renewable fuels, including SAF, and establish ongoing state reporting to track program activity and market development within Minnesota. | PROPOSED | SF 2786 Introduction - 94th Legislature (2025 - 2026) |
| Temporary Moratorium on Minnesota SAF Tax Credit (HF3619) | Effective immediately upon passing | Last Update: The bill was proposed in Minnesota's House in February 2026. Next Update: The legislation must pass the state House and Senate and be signed by the Governor to become law. | This legislation would temporarily suspend the SAF tax credit until the Minnesota Environmental Quality Board completes a generic environmental impact statement (GEIS) evaluating the environmental impacts associated with SAF production and use. During the moratorium, taxpayers would be unable to claim the credit unless and until the GEIS is completed and the Commissioner provides approval and certification for eligibility. | Although no taxpayer has applied for the SAF tax credit as of April 2026, a temporary suspension could affect investor confidence or near‑term project planning. However, completion of a statewide environmental review could provide additional regulatory clarity and credibility for SAF in Minnesota, depending on the findings of the GEIS. | PROPOSED | HF 3619 Status in the House - 94th Legislature (2025 - 2026) |
| EU ETS Aviation - Proposed Targeted Revision (COM(2026) 616) | January 1, 2027 (phased implementation), January 1, 2029 (main changes) | Last Update: The European Commission published the proposal on 17 July 2026, alongside its Article 28b(2) assessment of CORSIA's effectiveness. Next Update: The proposal is subject to the ordinary legislative procedure and must pass the European Parliament and Council. Co-decision is anticipated to run into 2027. The provisions on business flight scope and implementation timing are likely to change before adoption. | A targeted revision of the EU ETS that reshapes the aviation framework in three ways: it extends geographic scope, revises the rules applicable to business flights, and redesigns the reserved-allowance mechanism supporting sustainable aviation fuels. From 2027: Aircraft operators with less than 10,000 tCO₂ from international flights may lose key geographical exemptions, potentially expanding the emissions subject to EU ETS surrender obligations. From 2029: The aviation geographical scope would be expanded to include flights departing from EEA airports to certain non-EEA destinations within a 5,000 km radius of Frankfurt Airport. For operators with less than 10,000 tCO₂ from international flights, the geographical scope could become significantly broader. A new common de minimis threshold of 1,000 tCO₂ would replace the current distinction between commercial and non-commercial operators, potentially bringing additional business aviation operators into scope. To manage the overlap - roughly 75% of the non-EEA countries in the expanded scope already participate in CORSIA - operators would be able to reduce their EU ETS surrender obligations by accounting for CORSIA offsetting costs already incurred. Business aircraft operators are uniquely singled out in this proposal, affecting exemption thresholds in a way that will disproportionately increase costs for business jet operators, while removing SAF credit incentives for them. Business flights would no longer be eligible for SAF-related EU ETS allowances, except for flights using electric, hydrogen or certain innovative propulsion technologies. | Commercial and non-commercial aircraft operators conducting flights within, to, or from the EEA. Significant impact expected for business aviation operators, particularly those with emissions between 1,000 and 10,000 tCO₂ and operators below the CORSIA threshold. Note this is a proposal, not adopted law, and the business-flight provisions are likely to be amended. | PROPOSED Legislative proposal published by the European Commission on 17 July 2026; subject to the ordinary legislative procedure and not yet adopted. | Reducing emissions from aviation - Climate Action, European Commission |
| Australia Low Carbon Liquid Fuel (LCLF) Demand Mechanism - Proposed SAF Mandate | No obligation before 2029. Phase 1 (volumetric) 2029-2035; Phase 2 (carbon intensity) from 2035 | Last Update: On 18 August 2026 the Department of Climate Change, Energy, the Environment and Water (DCCEEW) launched the 'Securing Australia's Cleaner Fuels Industry' consultation on the design of a demand mechanism to accelerate uptake of low carbon liquid fuel, including SAF. Next Update: The consultation closes on 15 September 2026, with DCCEEW expected to publish its response thereafter and implement any changes by 2029. | A proposed two-phase obligation on fuel suppliers. In Phase 1 obligated entities would meet fixed volumetric SAF requirements during a market formation period, before transitioning to carbon-intensity targets in Phase 2, where entities gain greater flexibility and SAF options delivering greater lifecycle emissions reductions are preferred. Phase 1 offers two pathways. On the lower volumetric pathway, 150-200 ML SAF in 2030 rising to 850-1,200 ML by 2035. On the higher pathway, 300-450 ML in 2030 rising to 1,700-2,400 ML by 2035. Phase 2 proposes an annual carbon-intensity decline of roughly 1% to 2.7% for LCLF generally, with a separate and as-yet unspecified benchmark for SAF. For any shortfall in SAF volume or CI reduction, an obligated entity would surrender carbon credits or pay a buy-out price to government. DCCEEW has not proposed a buy-out price level, nor set out review cycles or trigger events. Credit banking would be banned in Phase 1 and permitted in Phase 2. The minimum CI reduction threshold could be set at around 40-70% below the relevant fossil fuel baseline. The measure is demand-side and sits alongside the existing supply-side support: a decade-long AUD 1.1 billion Cleaner Fuels Program of grants to domestic LCLF producers. DCCEEW's position is that supply-side assistance alone is unlikely to attract the investment needed. Notably, the obligation is a fixed annual volume rather than a percentage of fuel supplied - even at the highest 2030 target of 450 ML against conservative domestic demand of 7.7 billion litres, the effective rate is roughly 5.8%, below the UK's 10% and just under the EU's 6%. | Obligated entities would be fuel suppliers, not aircraft operators. Unlike ReFuelEU, no operator reporting duty and no per-flight obligation is contemplated. Exposure is financial: cost pass-through on jet fuel uplifted in Australia from 2029, with the buy-out price acting as an effective ceiling on that pass-through once set. | PROPOSED Consultation open until 15 September 2026. This is a consultation on a conceptual framework, not draft legislation. | Securing Australia's Cleaner Fuels Industry Consultation | DCCEEW |
| Brazil Emissions Trading System (SBCE) - Sectoral Coverage and MRV | Air transport is in Stage 1 of a three-stage rollout concluding in 2027, 2029 and 2031 | Last Update: The Ministry of Finance opened a public consultation on 28 July 2026 on an ordinance setting the first list of economic activities required to begin monitoring emissions, following a preliminary proposal presented in May 2026 to the SBCE's Permanent Technical Advisory Committee. The consultation closed on 28 August 2026. Next Update: The government is targeting finalisation by December 2026. | Brazil's national cap-and-trade and MRV carbon market, established by Law 15,042/2024. It is not aviation-specific. The draft ordinance designates air transport as one of the sectors in Stage 1 of a three-stage rollout, alongside pulp and paper, iron and steel, cement, primary aluminium, oil and gas exploration and production, and oil refining. The ordinance maps covered sectors to specific CNAE codes, Brazil's official system for classifying business activities. Entities above 10,000 tCO2e per year would face reporting duties; those above 25,000 tCO2e per year may later face emissions limits and allowance obligations. | It is not yet confirmed which business aviation operators are captured. The scheme applies at operator or installation level against tCO2e thresholds designed to catch a relatively small number of large emitters. Indirectly, any operator fuelling in Brazil could see pass-through costs once compliance obligations. | PROPOSED The underlying Law 15,042/2024 is enacted; this MRV instrument is a draft ordinance that completed public consultation on 28 August 2026. | Ministry of Finance - public consultation on sectoral coverage of the regulated carbon market |
| Japan GX-ETS | April 1 2026 (FY 2026) | Last Update: The amendment to the GX Promotion Act was enacted on 28 May 2025, making participation mandatory for companies emitting 100,000 tonnes of CO2 or more annually from FY2026. | Japan's national ETS, run as a baseline-and-credit system with traded allowances and upper and lower price limits, became mandatory in FY2026. Inclusion thresholds cover companies with annual CO2 emissions of 100,000 tonnes or more, including aviation, but only if the company is registered/domicilied within Japan. Corporate aircraft could be included in a company's compliance scope if the main company meets this threshold. | Only applies to Japanese companies, and the threshold is likely to only catch large airlines, or companies with business aircraft. | ENACTED | Japanese ETS Becomes Mandatory |
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.
Need Help Monitoring and Reporting?
Visit our Regulatory Compliance program to learn how we can help keep you in compliance with regulatory programs. Contact us with any questions or to get started.