Aviation: the SAF Turn Becomes Regulatory

The time for announcements is over: since January 1, 2025, the incorporation of Sustainable Aviation Fuels (SAF) into kerosene has become a legal requirement in Europe. The United States is heavily subsidizing production, the United Kingdom is adopting its own mandate, ICAO is strengthening CORSIA, and Airbus is aiming for 100% SAF compatibility by the end of the decade.
In this new context, leaders in air transport, energy, and chemicals are no longer facing a branding decision, but an industrial, financial, and human resources equation to solve.

As summarized by Maximilien de Boyer, Practice Director Aerospace, Defense & Security at NAOS International: “SAF is no longer a ‘nice to have.’ It’s a compliance license that reshuffles the cards in terms of cost, supply chains, and critical skills.

This article offers an operational overview of this turning point: key regulations, supply-demand tension and costs, technology maturity, economic impacts (ETS, mandate), and consequences on jobs and recruitment.

From Promise to Law: The era of the mandate

The ReFuelEU Aviation regulation (EU 2023/2405) mandates fuel suppliers at all EU airports to include a minimum SAF rate: 2% starting in 2025, 6% in 2030, 20% in 2035, 34% in 2040, 42% in 2045, and 70% in 2050. It also sets a sub-quota for e-kerosene (synthetic fuels, RFNBO): an average of 1.2% for 2030–2031 (min. 0.7% per year), 2% for 2032–2034, then 5% in 2035, 10% in 2040, 15% in 2045, and 35% in 2050. The regulation also includes a refueling requirement: each operator must load at least 90% of the fuel needed for departures from the EU to avoid economic “tankering.” Fines indexed to the SAF/kerosene price gap apply in case of non-compliance.

On carbon pricing, the EU has tightened its EU ETS: a gradual end to free quotas (-25% in 2024, -50% in 2025) with 100% auctioning starting in 2026 for intra-EEA flights; 20 million allowances are reserved as an incentive for greener fuels.

Overall, the CORSIA offsetting trajectory is intensifying: following the pilot phase (2021–2023), phase one runs 2024–2026, and phase two 2027–2035, with a new baseline set at 85% of 2019 emissions starting in 2024.

Several countries are also accelerating: the UK (national SAF mandate), France (minimum incorporation since 2022, scaling up to 2025), Japan (target of 10% by 2030). These signals show that regulatory alignment goes beyond the EU and spans all continents.

Supply tension and cost shock: The new economic reality

While the obligation starts at 2% in Europe in 2025, supply remains scarce. IATA estimates that global production could double in 2025 to reach 2 Mt, around 0.7% of total airline consumption; in 2024, the share was around 0.5%. The cost differential remains high: on average 3.1× the price of Jet A-1 in 2024, creating a global surcharge of $1.6 billion (projected $4.4 billion in additional SAF-related costs in 2025).

In Europe, annual SAF production capacity is estimated just above 1 Mt, mostly via the HEFA pathway (used oils, fats). E-kerosene (Power-to-Liquid) still needs to scale up industrially.

International dynamics remain uneven: investment announcements but also industrial recalibrations and underinvestment risks; conversely, Asia could see a short-term surplus, leading to export flows if local demand lags.

Technological maturity and certification: 50% today, 100% tomorrow

Today, “drop-in” SAFs are ASTM D7566 certified for blends up to 50% (depending on the pathway). 100% approval is not yet widespread, although 100% test flights have taken place and authorities are working on increasing the thresholds.

Airbus is testing 100% SAF flights and confirms it is targeting 100% SAF compatibility for all its aircraft by 2030. This goal supports the growth of mandates and prepares the shift to synthetic fuels made with renewable hydrogen and captured CO₂ (RFNBO).

In terms of production pathways, HEFA dominates in the short term (limited feedstocks: used oils, fats), while Fischer-Tropsch (biomass-to-liquid) and Alcohol-to-Jet are maturing. E-kerosene (Power-to-Liquid) is key for the European RFNBO sub-quota, but its cost remains the highest at this stage.

Result: for 2025–2030, securing HEFA supplies and first RFNBO batches aligned with sub-targets will be decisive for complying with the regulatory mix, while managing cost vs. impact.

Scissor effect for airlines : SAF Mandate + EU ETS = New P&L

Carbon cost (EU ETS) and the SAF premium add up. The EU has confirmed the end of free allowances by 2026 for intra-EEA aviation, while ReFuelEU enforces minimum SAF rates per airport. Penalties tied to the price gap between SAF and kerosene strengthen the incentive for real incorporation rather than simple offsetting.

The regulation allows flexibility for 2025–2034: suppliers can average their SAF volumes across the EU over the period (mass balance), and the EU controls refueling to prevent tankering. For carriers, this will lead to new contractual models (multi-airport, certifiable “book-and-claim,” fuel adjustment clauses) and deeper integration of Finance/Procurement/Compliance.

In France, the early incorporation effort (since 2022) and national ambitions (public investment via “France 2030,” target: 500,000 t/year capacity by 2030) set the path, although EU alignment remains the dominant framework for 2025 and beyond.

Value Chain & Talent: A battle of engineering, operations, and compliance

The rise of SAF is reshaping the professional landscape:

Production & Processes: process engineers, F-T unit managers (biomass-to-liquid), ATJ specialists, e-fuels project managers (electrolysis, CO₂ capture, synthesis), unit commissioning/start-up, advanced maintenance.

Energy & Networks: renewable electricity buyers, PPA experts, grid connection engineers, intermittency management to secure PtL unit load factors.

Quality & Certification: ASTM D7566/D1655 leads, fuel quality assurance, metrology, labs, engine testing (materials compatibility, additives, lubricants).

Supply Chain & Airport Logistics: blending specialists, storage, mass-balance traceability, depot–pipeline–hydrant interfaces.

Carbon & Compliance: LCA analysts (RED II/III), MRV ETS, CORSIA, environmental lawyers, regulatory risk controllers (ReFuelEU penalties, delivery clauses).

Finance & Strategy: structuring long-term contracts, jet and SAF price hedging, airport pooling alliances, upstream co-investments.

Commercial & B2B Marketing: credible book-and-claim offerings, “Sustainable Corporate Travel” packages, client ESG reporting.

Cross-cutting sought-after skills: process safety, digital/OT, data quality, supply planning, multi-site management, CAPEX oversight (FEED/EPC), complex industrial negotiation. Salary tensions are already rising for electrolysis, CO₂ engineering, and fuel quality profiles.

On the company side, three HR trends are emerging:

  • Re-skilling fuel & operations teams to integrate ASTM standards, traceability, MRV ETS/CORSIA.

  • Project staffing for the first e-fuel plants (rollout 2026–2030), with cross-industry competition (chemicals/energy/hydrogen).

  • Governance: cross-functional Sustainable Fuel Committees (Ops, Finance, Procurement, Legal, QHSE), reporting to the Executive Committee to arbitrate CAPEX/OPEX, backed by KPIs (€/tCO₂ avoided, % SAF, ETS costs).

Steering the transition with proof

The move to obligation changes everything. In Europe, the ReFuelEU agenda and ETS tightening require an industrial approach:

  • Secure supply (HEFA short-term, RFNBO ramp-up) and multi-horizon contracts (2025–2030–2035).

  • Internalize critical skills (process, quality, compliance, carbon data) and professionalize governance.

  • Build a robust financial strategy (carbon price, SAF premium, public incentives) with a global view (EU/UK/US/CORSIA).

The message is clear: SAF is no longer a CSR project—it’s a strategic infrastructure. General management teams orchestrating the value chain, from engineering to talent, will gain the advantage as quotas rise to 6% in 2030 and 20% in 2035.

The 2025–2035 decade is one of industrial credibility. Those who combine supply contracts, operational excellence, and talent appeal will set the new standards of competitiveness,” concludes Maximilien de Boyer.